Circular Letter No. CC/2025/00000003: Understandings and Best Practices on Account and Payment Card Contract Termination, Account Change Service, and Joint Account Treatment After Holder Death

Circular Letter No. CC/2025/00000003
Sent to:
Credit Institutions, Financial Societies, Payment Institutions, and Electronic Money Institutions.
Mod. 99999975/T – 01/14
Subject: Understandings and best practices to be observed in the termination of deposit and payment account and card contracts, the provision of the account change service, and the treatment of joint accounts after the death of one of their holders

1. In the exercise of its supervisory powers over the conduct of credit institutions, financial societies, payment institutions, and electronic money institutions ("institutions"), the Banco de Portugal has received a high number of complaints related to the termination of current deposit account, payment account, and payment card contracts and to restrictions imposed on the movement of joint accounts after the notification of the death of one of their holders. These circumstances reflect the existence of distinct practices and interpretative doubts regarding the applicable legal framework, in particular the Legal Regime for Payment Services and Electronic Money ("RJSPME"), approved by Decree-Law No. 91/2018 of November 12, hindering its adequate compliance and jeopardizing the rights conferred on banking customers.