Circular Letter No. CC/2026/00000018

Circular Letter No. CC/2026/00000018
Mod. 99999924/T – 01/14
Subject: Recommended Procedures in the Context of Handling Complaints

1. The model for receiving and handling complaints submitted by banking customers has evolved in recent years, notably as a result of legislative changes and technological developments.

2. Currently, in addition to the provisions of the legal regime for the complaints book, approved by Decree-Law No. 156/2005 of September 15, and the rules that assign the Banco de Portugal the competence to assess complaints directly addressed to it1, the procedures and deadlines transmitted to institutions through Circular Letter No. 25/2008/DSB, published in the Official Gazette No. 4/2008, and Circular Letter No. 6/2008/DSB, published in the Official Gazette No. 2/2008, remain in force. However, the content of the aforementioned Circular Letters is, in several aspects, misaligned given the developments that have occurred since then, particularly highlighting the progressive digitalization of the complaint management process, driven notably by the introduction of the electronic format of the Complaints Book.

3. It thus appears necessary to review the procedures that should govern the relationship between the Banco de Portugal and supervised entities2 in the context of analyzing complaints submitted by customers, adjusting them to the current regulatory framework and existing systems, in order to ensure greater uniformity and predictability in the relationship between both parties, and contribute to a more efficient management of this process.

4. In this context, the Banco de Portugal recommends that supervised entities observe a set of procedures to be followed (i) in the handling of complaints directly sent to it and (ii) in the context of requests for additional clarification made during the analysis of these complaints, as well as following complaints submitted through the Complaints Book.

5. This Circular Letter revokes Circular Letter No. 25/2008/DSB and Circular Letter No. 6/2008/DSB.

6. Thus, in the exercise of the competence attributed to it by Article 17 of its Organic Law, approved by Law No. 5/98 of January 31, the Banco de Portugal transmits to supervised entities a set of procedures to be followed in the management and analysis of banking customer complaints, as provided for in the following paragraphs:

1 In particular, Article 77-A of the General Regime of Credit Institutions and Financial Companies, approved by Decree-Law No. 298/92 of December 31 (“RGICSF”), and Article 143 of the Legal Regime of Payment Services and Electronic Money, approved by Decree-Law No. 91/2018 of November 12 (“RJSPME”).
2 Namely, Credit Institutions, Financial Companies, Payment Institutions, Electronic Money Institutions, Credit Intermediaries, Credit Managers, and Crypto-asset Issuers.

Mod. 99999924/T – 01/14

A. Procedures to be observed in complaints directed directly to the Banco de Portugal

A.1. After registration and preliminary analysis, the Banco de Portugal forwards complaints directly addressed to it (by post or through its network of Branches) to the complained entity via the BPnet service.

A.2. The complained entity analyzes the complaint within a maximum period of 15 business days from its receipt, and communicates, within that period, to the complainant the result of the analysis performed.

A.3. In the response addressed to the complainant, the complained entity expressly indicates (i) whether it considers that there was or was not non-compliance on its part, presenting the respective justification, and (ii) when the complaint is upheld, the measures adopted to remedy the identified situation.

A.4. Within the same period of 15 business days, the complained entity sends a copy of the response sent to the complainant to the Banco de Portugal, as well as any additional elements considered relevant for the assessment of the complaint, in accordance, where applicable, with models previously made available by the Banco de Portugal.

B. Procedures to be observed in additional requests

B.1. After analyzing the response to complaints (whether those directly addressed to the Banco de Portugal or those submitted through the Electronic Complaints Book), and if it considers that the information and elements provided do not allow assessing the conformity of the complained entity's actions with the applicable regulatory framework, the Banco de Portugal requests the due clarifications, submitting an additional request via the BPnet service.

B.2. The complained entity responds to the additional request, providing the clarifications and making available the requested elements, within a maximum period of 5 business days or in another extended period defined by the Banco de Portugal.