2026-02-24
Added · Updated
Instruction No. 1/2026 revokes and replaces Instruction No. 17/2018 to regulate the Credit Liability Central (CRC) in alignment with Decree-Law No. 103/2025 and EU Directive 2021/2167. It expands the scope of participating entities to include credit managers, crowdfunding lenders, and certain foreign entities, while mandating the reporting of daily credit events and additional monitoring data such as the debt service-to-income ratio. The instruction establishes detailed obligations for information communication, rectification within five days, debtor notification, and access to centralized data for credit assessment and risk monitoring.
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Instruction No. 1/2026
BO No. 2/2026 Supplement • 2026/02/24
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Topics
Credit Liabilities :: Credit Liability Central Mod. 99999940/T – 01/14 Index Text of the Instruction
Annex I to the Instruction – Characterization of information blocks, frequencies and reporting deadlines
Annex II to the Instruction – Description of variables
Annex III to the Instruction – Definition of domain tables
Annex IV to the Instruction – Information on branches abroad of participating entities
Text of the Instruction
Subject: Regulation of the Credit Liability Central This Instruction has as its main objective the revocation and replacement of Instruction No. 17/2018, of 27 August, which regulates the operation of the Credit Liability Central (“CRC”), in order to incorporate the necessary changes for the implementation of the provisions of Decree-Law No. 103/2025, of 11 September (“Decree-Law No. 103/2025”), which transposed Directive (EU) 2021/2167 of the European Parliament and of the Council of 24 November 2021 and establishes a harmonized framework for access to and the exercise of the activity of managing non-performing bank credits, as well as a set of requirements for credit acquirers (Regime for the Assignment and Management of Bank Credits, hereinafter “RCGCB”), and for the revision of the CRC regime.
Under the RCGCB, a duty is established for institutions and credit managers to communicate to the CRC the credits subject to assignment and the information elements relating to these credits provided for in applicable legislation and regulation, namely the information provided for within the scope of the CRC. In this way, it is necessary (i) to widen the scope of application to include credit managers as new participating entities, (ii) to add additional information for the purposes of monitoring credits subject to assignment and (iii) to exempt participating entities from the duty to report information on assignments provided for in Article 9 of the RCGCB, given that the Bank of Portugal will, in accordance with what is required in this Instruction, receive all information provided for in this regard at its headquarters.
Instruction No. 1/2026 BO No. 2/2026 Supplement • 2026/02/24 Topics Credit Liabilities :: Credit Liability Central
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Mod. 99999940/T – 01/14
Decree-Law No. 103/2025 also approves a new CRC regime, due to the need to update the current legislative framework, revoking the previous regime, and notably updating the definition of participating entities, the information subject to centralization and the scope of centralization reporting.
In the definition of participating entities, in addition to the entities provided for by the RCGCB, the list is expanded to include (i) entities authorized in other Member States and granting credit in Portugal under the free provision of services regime, (ii) crowdfunding financing service providers regarding credits arising from loans they have promoted and (iii) credit institutions, payment institutions, electronic money institutions and alternative credit investment funds constituted in another Member State and for which credits originally granted in Portugal have been assigned may also be designated by the Bank of Portugal as participating entities.
Regarding the information subject to centralization, the obligation to communicate daily credit events is introduced, making it necessary to define them and their respective reporting rules.
Regarding the communication of centralization, the possibility is introduced for participating entities to access information on centralization relating to the 12 months prior to the last available centralization.
Within the scope of this revision, the following changes are also introduced: (i) incorporation into the text of the Instruction of the reporting requirements applicable to the information to be communicated to the Bank of Portugal, (ii) introduction of an additional requirement regarding the ratio between the total amount of monthly installments associated with all loans held by the borrower and their net monthly income after taxes and mandatory Social Security contributions (debt service-to-income ratio, in the English acronym DSTI), for the purposes of monitoring the Bank of Portugal’s Recommendation regarding new credit contracts concluded with consumers, (iii) introduction of an additional requirement for the purposes of monitoring credit intermediaries, whose legal regime is established by Decree-Law No. 81-C/2017, of 07 July and (iv) introduction of an additional requirement for the assessment of the characteristics of credit products.
Thus, having Decree-Law No. 103/2025 revoked the legal regime relating to the CRC, approved by Decree-Law No. 204/2008, of 14 October, it is considered more appropriate to revoke Instruction No. 17/2018 and adopt this Instruction, in order to ensure greater legal clarity of the regulation.
This Instruction was subject to public consultation, in accordance with Article 101 of the Administrative Procedure Code, approved by Decree-Law No. 4/2015, of 7 January, and the National Data Protection Commission was consulted.
In these terms, in the exercise of the competence conferred upon it by Article 17 of its Organic Law, approved by Law No. 5/98, of 31 January, in its current wording, by paragraph 6 of Article 2, by paragraphs 1 and 3 of Article 4 and by paragraphs 1, 2, 4 and 5 of Article 6 of the new CRC regime, which is contained in Annex II to Decree-Law No. 103/2025, of 11 September, by Regulation (EU) 2016/867 of the European Central Bank, of 18 May, on the collection of granular data relating to credit and credit risk, and by paragraph 3 of Article 9 and point (a) of Article 55 of the Regime for the Assignment and Management of Bank Credits, which is contained in Annex I to Decree-Law No. 103/2025, of 11 September, the Bank of Portugal determines the following:
Chapter I
General Provisions
Article 1.
Object
This Instruction regulates the operation of the Credit Liability Central (CRC), which aims to centralize financial, accounting and risk information on credit liabilities, actual and potential, arising from credit operations carried out by participating entities, in any form or modality, from which individuals, legal entities or equivalent entities, resident or non-resident in national territory, are beneficiaries.
Article 2.
Scope of Application
1 - This Instruction applies to participating entities which are:
a) Credit institutions, financial companies, payment institutions and electronic money institutions with headquarters in Portugal; b) Credit institutions and financial institutions with headquarters abroad authorized to grant credit in Portugal through a branch; c) Entities referred to in the preceding subparagraphs authorized in other Member States and granting credit in Portugal under the free provision of services regime; d) Alternative credit investment funds constituted in Portugal; e) Crowdfunding financing service providers regarding credits arising from loans they have promoted; f) Credit managers or institutions authorized in Portugal to carry out credit management activities in the name and on behalf of assignees under the Regime for the Assignment and Management of Bank Credits, approved as Annex I to Decree-Law No. 103/2025, of 11 September, as well as credit managers authorized in other Member States operating in Portugal through the establishment of a branch or under the free provision of services regime, regarding credits granted in Portugal; g) Other entities designated by the Bank of Portugal:
i. With a permanent establishment in Portugal and exercising credit granting functions under special regimes;
Instruction No. 1/2026 BO No. 2/2026 Supplement • 2026/02/24 Topics Credit Liabilities :: Credit Liability Central
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Mod. 99999940/T – 01/14
ii. With a permanent establishment in Portugal, not included in subparagraph f), and exercising other functions associated with the assignment and management of credits originally granted in Portugal;
iii. Being credit institutions, payment institutions, electronic money institutions and alternative credit investment funds constituted in another Member State and for which credits originally granted in Portugal have been assigned.
2 - Participating entities are obliged to communicate to the Bank of Portugal the information referred to in Article 6, with the Bank of Portugal being responsible for centralizing and disseminating information.
3 - Participating entities that communicate the information referred to in Article 6 appear on the list published on the Bank of Portugal’s website.
Chapter II
Duty to Communicate
Article 3.
Scope of Information
Participating entities are obliged to provide the Bank of Portugal with all information elements relating to the characterization of credit, as well as, where applicable, all advanced, financial, accounting and risk information regarding liabilities arising from credit operations granted:
a) In Portugal, to residents or non-residents in national territory, by their headquarters, subsidiaries, agencies and branches; b) Abroad, to residents in national territory, by their branches abroad; c) Abroad, to non-residents in national territory, by their branches abroad, when expressly requested by the Bank of Portugal.
Article 4.
Covered Operations
All credit operations in which at least one of the following conditions is met must be communicated to the CRC, in accordance with the description in Article 6:
a) They imply credit risk for the participating entity; b) They constitute an asset of the participating entity; c) They are recognized under the applicable accounting standard and have already originated credit risk for the participating entity in the past; d) They are managed by the participating entity and the creditor is not a participating entity in the CRC.
Article 5.
Excluded Operations
1 - The following types of operation must be excluded from communication to the CRC:
a) Debts forgiven by participating entities; b) Credit granted in discount of bills that have been subject to restructuring, for which only the credit granted in discount of the new bill must be communicated; c) Debt securities in the portfolio of participating entities. 2 - Contracts with an initial amount of less than 50 EUR must be excluded from communication to the Bank of Portugal. Participating entities must begin to communicate information relating to said contracts if credit increases occur that result in an outstanding amount equal to or greater than 50 EUR.
Article 6.
Information to be Communicated to the Bank of Portugal 1 - The information that participating entities must communicate to the CRC is organized into information blocks, according to their characteristics and nature:
a) Static information – the base structure of CRC information, characterized by stability over time, although it may be subject to occasional changes. The following information blocks are included in this type:
i. Block 1 – Entity;
ii. Block 2 – Contract/instrument;
iii. Block 3 – Protection;
iv. Block 4 – Complementary to the contract;
b) Periodic information – information whose reporting has a predefined frequency: daily, monthly or quarterly. The following blocks are included in this type:
i. Block 5 – Financial information;
ii. Block 6 – Accounting information;
iii. Block 7 – Entity risk information;
iv. Block 8 – Instrument risk information;
v. Block 9 – Advanced information.
Instruction No. 1/2026 BO No. 2/2026 Supplement • 2026/02/24 Topics Credit Liabilities :: Credit Liability Central
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Mod. 99999940/T – 01/14
2 - The characterization of information blocks, variables, frequencies and reporting deadlines results from Annex I, the description of variables from Annex II and the definition of domain tables from Annex III.
3 - Regarding branches abroad of participating entities, the information to be sent to the CRC depends on the country of location of the branch and the type and residence of the debtor, with the information blocks to be communicated identified in Annex IV, in accordance with the above. 4 - Amounts to be communicated to the Bank of Portugal are expressed in euros, with two decimal places. 5 - Rates and other percentage values must be communicated on a base 100, with five decimal places.
Article 7.
Rectification of Communicated Information
1 - Whenever a participating entity, on its own initiative or at the request of the debtor or guarantor/surety, verifies that there has been an omission or inaccuracy in any past or present communication, it is obliged to proceed with the respective rectification, sending the necessary communications to the Bank of Portugal for this purpose. 2 - The rectification of information communicated to the Bank of Portugal must be carried out by participating entities within a maximum period of five business days. 3 - The period for rectification is calculated from the moment the participating entity becomes aware of the omission or the improper communication of any information. 4 - For the purposes of the preceding number, the following are considered, namely, declarations passed by the participating entity to its clients acknowledging the error or omission, or attesting to the regularization of a certain liability, as well as communications sent to them following complaints presented by clients, whether in the Complaints Book of the participating entity itself or through the Bank of Portugal.
Chapter III
Information to Debtors
Article 8.
Duty to Inform
1 - Participating entities must, upon the conclusion of the credit contract and on an auditable medium, inform debtors and guarantors/sureties about facts capable of generating communications to the CRC.
2 - Participating entities must inform debtors of the start of communication of a credit contract with amounts due or written off to assets, prior to its sending to the CRC.
3 - In the case of guarantors or sureties who are called upon to replace debtors in the payment of the credit, participating entities must inform them of this situation and should only communicate them in a situation of default or write-off to assets if the payment of the credit has not been made within the established period for this purpose.
Article 9.
Period for Retaining Proof of Information Provided to Debtors Proof of the provision of information to debtors or guarantors/sureties in accordance with Article 8 must be retained, on any auditable medium, for a period of five years, calculated from the date on which the information was provided.
Chapter IV
Centralization
Article 10.
Definition and Scope of Centralization
1 - Centralization is the process of aggregating information on credit liabilities, for each individual, legal entity or equivalent entity, involved in a credit contract as a debtor, guarantor or surety.
2 - The monthly centralization carried out and disseminated by the Bank of Portugal covers the following elements:
a) Information communicated by participating entities, relating to credit liabilities on a contract/instrument to contract/instrument basis, with their respective characterization; b) Data extracted from information sent to the Bank of Portugal by the Ministry of Justice regarding insolvency declarations of individuals and legal entities, in accordance with point (c) of paragraph 6 of Article 38 of the Insolvency and Corporate Recovery Code, approved by Decree-Law No. 53/2004, of 18 March. 3 - Centralization does not cover all information reported to the Credit Liability Central. 4 - The process of disseminating centralized information excludes non-recourse factoring contracts, until at least 90 days have elapsed after the maturity of the invoices or bills of exchange, and credits in the form of deposits.
Article 11.
Distribution of Centralized Information
1 - The Bank of Portugal makes available, monthly, to the participating entities referred to in points (a) to (d) and subpoint (i) of point (g) of Article 2, the centralization of credit liabilities relating to debtors and guarantors/sureties communicated by them, without any identification of the participating entities responsible for the information or the indication of the locality where the credit was contracted. 2 - The information received by the Bank of Portugal in accordance with point (b) of paragraph 2 of Article 10 is included in the centralized information with the indication of the judicial act associated with the process.
Article 12.
Deadline for Dissemination of Centralized Information The centralized information referred to in the previous article is distributed with monthly frequency, until the end of the month following that to which the data relate.
Article 13.
Dissemination of Rectifications to Centralized Information The Bank of Portugal periodically disseminates to participating entities rectifications to the centralized information on debtors or guarantors/sureties previously communicated by them. These rectifications cover information received after the distribution of their respective centralizations.
Article 14.
Access to Centralized Information
1 - In addition to the provision of centralized information provided for in Article 11, access to the centralized information of potential clients is provided to the participating entities referred to in points (a) to (e) and subpoint (i) of point (g) of Article 2, provided they have obtained from them a request for credit granting or authorization to carry out this consultation. 2 - The information on credit liabilities made available to participating entities within the scope of centralized information consultations relates to the last month of distributed centralization, in its most up-to-date version, i.e., incorporating rectifications made after that distribution. 3 - When requested, the participating entities referred to in points (a) to (e) and subpoint (i) of point (g) of Article 2 may consult the centralized information of potential clients relating to the last 12 months prior to the last centralization or to daily events occurring since the last centralization, provided they have obtained from them a request for credit granting or authorization to carry out this consultation. 4 - In the context of a credit renegotiation, the participating entities referred to in points (f) and in subpoints (ii) and (iii) of point (g) of Article 2 may consult the centralized information in accordance with the preceding numbers, with the express consent of the debtor for this purpose. 5 - The Bank of Portugal also provides access to the centralization of credit liabilities to insurance companies that, in accordance with the legal and regulatory provisions in force, are authorized to operate credit and surety insurance provided for in Decree-Law No. 183/88, of 24 May, while debtors with commercial credits granted by the insured remain as active parties in credit and surety insurance. 6 - Individuals, legal entities or equivalent entities have the right to know their information, centralized and disseminated by participating entities, including the identification of the participating entities responsible for the information. Observing the existence of errors or omissions, they may request their rectification or update from the participating entity responsible for the communication to the Bank of Portugal.
Article 15.
Deadline for the Bank of Portugal’s Response to Requests for Centralized Information The deadline for responding to requests for centralized information provided for in the previous article varies depending on how the consultation is carried out:
a) File transfer – occurs by the next business day after receipt of the request; b) Online consultation or web services – occurs immediately, with the system available seven days a week, between 8:00 and 24:00.
Article 16.
Information Security
1 - When the consultation of centralized information is based on a request for credit granting or the express authorization of the client, participating entities ensure, prior to the consultation, the adequate identification of the data subject. 2 - Participating entities must adopt technical and organizational measures for the traceability and audit of individual access to the information of the Credit Liability Central.
Article 17.
Period for Retaining Information
1 - For the purposes of the centralization of credit liability information and its dissemination, periodic information communicated under this Instruction has a retention period of five years.
2 - For the purposes of centralization
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