Instruction (Historical) No. 2/2026

Instruction No. 2/2026 BO No. 3/2026 Supplement • 2026/03/26 .................................................................................................................................................................................................. Topics Supervision :: Supervision Mod. 99999911/T – 01/14

Index Text of the Instruction Annex I - FAP Questionnaire (Portuguese version and English version) Annex II - IMAS Form for Constitutions (Portuguese version and English version) Annex III - IMAS Form for Constitutions – National Specificities (Portuguese version) Annex III - IMAS Form for Constitutions – National Specificities (English version) Annex IV - Declaration for compliance with the duty of information in the context of the constitution process of entities subject to authorization by the Bank of Portugal (Portuguese version) Annex IV - Declaration for compliance with the duty of information in the context of the constitution process of entities subject to authorization by the Bank of Portugal (English version) Annex V - IMAS Form for Acquisition or Increase of Qualified Participations (Portuguese version and English version) Annex VI - IMAS Form for Acquisition or Increase of Qualified Participations – Additional Elements – Acquisition Without Control (Portuguese version) Annex VI - IMAS Form for Acquisition or Increase of Qualified Participations – Additional Elements – Acquisition Without Control (English version) Annex VII - IMAS Form for Acquisition or Increase of Qualified Participations – National Specificities (Portuguese version) Annex VII - IMAS Form for Acquisition or Increase of Qualified Participations – National Specificities (English version) Annex VIII - IMAS Form for Establishment of Branch (Portuguese version and English version) Annex IX - IMAS Form for Amendment to Passport of Already Established Branch (Portuguese version and English version) Annex X - IMAS Form for Closure of Branch (Portuguese version and English version) Annex XI - IMAS Form for Notification for the Exercise of Free Provision of Services (Portuguese version and English version) Annex XII - IMAS Form for amendments to the Notification for the exercise of Free Provision of Services (Portuguese version and English version) Annex XIII – Declaration for compliance with the duty of information in the context of the prior notification of establishment of a branch or provision of services in an EU or EEA Member State (Portuguese version) Annex XIII – Declaration for compliance with the duty of information in the context of the prior notification of establishment of a branch or provision of services in an EU or EEA Member State (English version)

Instruction No. 2/2026 BO No. 3/2026 Supplement • 2026/03/26 Topics Supervision :: Supervision .................................................................................................................................................................................................. Mod. 99999911/T – 01/14

Text of the Instruction Subject: Processing of procedures via the Portal of the Information Management System of the European Central Bank

The Portal of the Information Management System of the European Central Bank (referred to as Information Management System for the SSM, hereinafter identified as “IMAS Portal”) is an online platform, made available and managed directly by the European Central Bank (hereinafter identified as “ECB”), which allows the submission, consultation, and exchange of information, electronically and with guarantees of the authenticity of the interlocutors' identities by appropriate means, between supervisory authorities and supervised entities within the scope of procedures under the competence of the ECB, with the ECB being the entity responsible for managing the IMAS Portal, defining the terms of use of this service, and guaranteeing its operation.

The main objective of the IMAS Portal is to promote the harmonization of assessment conditions within the Single Supervisory Mechanism (hereinafter identified as “SSM”), without prejudice to the national substantive regime applicable to each specific case. To this end, this service was developed in a way to guarantee (i) the simplification of the processing of procedures covered by its scope, contributing to the speed in handling the respective processes, and (ii) transparency with supervised entities regarding the phases in which their respective processes are located.

However, the IMAS Portal does not alter the respective attributions and responsibilities of the ECB and the Bank of Portugal as the national competent authority, nor the cooperation established in Council Regulation (EU) No. 1024/2013 of 15 October 2013 (SSM Regulation) and in ECB Regulation (EU) No. 468/2014 of 16 April 2014 (hereinafter identified as “SSM Framework Regulation”).

Bank of Portugal Instruction No. 7/2021 of 15 April (hereinafter identified as “Instruction No. 7/2021”) aimed to make mandatory the processing, via the IMAS Portal, of requests for authorization to exercise the functions of members of administrative and supervisory bodies, holders of essential control functions, and managers of branches established in countries that are not Member States of the European Union of Significant Institutions classified according to the SSM Framework Regulation (hereinafter “Significant Institutions”).

At the time of entry into force of Instruction No. 7/2021, the use of the IMAS Portal was limited to the aforementioned procedures. However, currently, the use of the IMAS Portal covers other procedures, including: (i) Common procedures, namely authorization procedures for access to the activity of credit institutions, and prior notification of acquisition or increase of a qualified participation in a credit institution; (ii) Procedures relating to the exercise of activity through branches and the free provision of services in a Member State of the European Union by Significant Institutions; and (iii) Authorization and dispensation procedures for financial companies, as provided for in Chapter IV-A of Title II of the General Regime of Credit Institutions and Financial Companies, approved by Decree-Law No. 298/92 of 31 December (hereinafter identified as “RGICSF”), in the case of groups of significant credit institutions.

Given this new context, it is necessary to alter the national legal framework for the use of the IMAS Portal in order to extend the scope of its use. To this end, it was decided to concentrate in a single Instruction the regulation relating to the processing of procedures that take place on this platform.

Thus, on the one hand, this Instruction partially revokes Instruction No. 7/2021, in the part relating to the regulation of the submission, via the IMAS Portal, by institutions subject to the supervision of the ECB within the SSM, of requests for authorization to exercise the functions of members of administrative and supervisory bodies, holders of essential control functions, and managers of branches established in countries that are not Member States of the European Union, with the same now being regulated through this Instruction.

In this way, the aforementioned requests, the decision-making competence of which belongs to the ECB, continue to be presented, by the institutions covered, via the IMAS Portal, continuing the information necessary to comply with the regime established in Articles 30 and following of the RGICSF, regulated by Bank of Portugal Instruction No. 23/2018 of 5 November, to be provided by the candidates and the supervised entities in that service through structured fields made available in an online form, as well as in the questionnaire made available there.

For its part, the authorization procedures for access to the activity of credit institutions and prior notification of acquisition or increase of a qualified participation in a credit institution, the decision-making competence of which belongs to the ECB, also become mandatorily presented via the IMAS Portal, when submitted by entities subject to the supervision of the Bank of Portugal or the ECB, and the information necessary, as well as the respective formal requirements, to comply with the regimes established, respectively, in Articles (i) 16 and following of the RGICSF, regulated by Commission Implementing Regulation (EU) No. 2022/2581 of 20 June 2022 (hereinafter identified as “Implementing Regulation No. 2022/2581”) and by Commission Delegated Regulation (EU) No. 2022/2580 of 17 June 2022, (ii) 102 and following of the RGICSF, regulated by Bank of Portugal Notice No. 6/2021 of 2 November, to be provided in that service by applicants and supervised entities through structured fields made available in an online form.

Also, procedures related to the exercise of activity through branches and free provision of services in a Member State of the European Union by Significant Institutions, the decision-making competence of which belongs to the ECB, become mandatorily presented via the IMAS Portal when submitted by credit institutions with headquarters in Portugal, as well as by credit institutions with headquarters in Member States of the European Union or in a State belonging to the European Economic Area that are established in Portugal in the form of a branch, whenever the institution chooses to use electronic means for the submission of its notification or request, and the information necessary, as well as the respective formal requirements, to comply with the regimes established, respectively, in Articles 36 and following, 43, and 51, all of the RGICSF, regulated by Commission Delegated Regulation (EU) No. 1151/2014 of 4 June 2014 and by Commission Implementing Regulation (EU) No. 926/2014 of 27 August 2014 (hereinafter identified as “Implementing Regulation No. 926/2014”), to be provided in that service by applicants and supervised entities through structured fields made available in an online form.

Regarding the authorization and dispensation procedures for financial companies and mixed financial companies, in the case of significant groups, taking into account that, in these cases, the competent authority for deciding on the request for authorization or dispensation is the ECB without the need for cooperation of national competent authorities, the use of the IMAS Portal for the purpose of submitting the request for authorization or dispensation is of a voluntary nature.

Without prejudice to the aforementioned in the previous paragraphs: (i) The Bank of Portugal recommends the use of the IMAS Portal by other persons, natural and legal, who, not being covered by the obligation of Article 3, intend to submit, via this channel, one of the procedures provided for herein, thus optimizing the integrity and integration of the submitted information, as well as procedural speed and agility. Thus, all those who use the IMAS Portal are included in the subjective scope of this Instruction; (ii) The other procedures or communications not covered by this Instruction must continue to be submitted via the currently in force channels, namely through the Relevant Information System of Supervised Entities (SIRES) service, as provided for in Bank of Portugal Instruction No. 11/2023 of 15 May (Instruction No. 11/2023).

Finally, Instruction No. 11/2023 is amended, to remove from its scope of application the procedures that are now regulated in this Instruction, and therefore, to be processed via the IMAS Portal. Thus, the Bank of Portugal determines, in the exercise of the competence attributed to it by Article 17 of its Organic Law, approved by Law No. 5/98 of 31 January, in its current wording, and under Article 30(8), Article 33-A(3), Article 102(4), and Article 116(f) of the RGICSF, in its current wording, Article 1(2) of Implementing Regulation No. 2022/2581, in its current wording, and Article 3(2)(c) of Implementing Regulation No. 926/2014, in its current wording, the following:

CHAPTER I General Provisions

Article 1. Object This Instruction establishes the mandatory and voluntary processing, via the service of the Portal of the Information Management System of the European Central Bank (referred to as Information Management System for the SSM, hereinafter identified as “IMAS Portal”), of the procedures referred to in Articles 3 and 4, respectively, and defines the elements that must accompany the requests relating to the procedures regulated.

Article 2. Subjective Scope 1 - Entities with headquarters in Portugal subject to the supervision of the Bank of Portugal or the European Central Bank (hereinafter identified as “ECB”), as well as credit institutions with headquarters in Member States of the European Union or in a State belonging to the European Economic Area that are established in Portugal in the form of a branch must submit the procedures referred to in Article 3 via the IMAS Portal. 2 - Within the scope of this Instruction, institutions subject to direct supervision by the ECB are the Significant Institutions classified according to the SSM Framework Regulation, approved by ECB Regulation (EU) No. 468/2014 of 16 April 2014. 3 - Natural persons and legal persons not subject to the supervision of the Bank of Portugal or the ECB may submit the procedures referred to in this Instruction via the IMAS Portal.

Article 3. Mandatory Processing via the IMAS Portal 1 - The following procedures are mandatorily processed via the IMAS Portal: a) Authorization for the exercise of functions of members of administrative and supervisory bodies and holders of essential control functions, when submitted by institutions subject to direct supervision by the ECB; b) New assessment of holders of essential functions, as provided for in Article 33-A(5) of the General Regime of Credit Institutions and Financial Companies, approved by Decree-Law No. 298/92 of 31 December (hereinafter identified as “RGICSF”), when submitted by institutions subject to direct supervision by the ECB; c) Authorization for the exercise of functions of managers of branches established in countries that are not Member States of the European Union, when submitted by institutions subject to direct supervision by the ECB; d) Authorization for the constitution of credit institutions, as provided for in Article 16 of the RGICSF, when submitted by entities subject to the supervision of the Bank of Portugal or the ECB; e) Prior notification of acquisition or increase of a qualified participation in a credit institution, as provided for in Article 102 of the RGICSF, when submitted by entities subject to the supervision of the Bank of Portugal or the ECB. 2 - When Institutions choose to use electronic means, in accordance with Article 3(1)(b) of Commission Implementing Regulation (EU) No. 926/2014 of 27 August 2014, amended by Commission Implementing Regulation (EU) 2022/193 of 17 November 2021 (hereinafter identified as “Implementing Regulation No. 926/2014”), the following procedures are mandatorily processed via the IMAS Portal: a) Prior notification of establishment of a branch in a Member State of the European Union or in a State belonging to the European Economic Area, when submitted by a credit institution subject to direct supervision by the ECB with headquarters in Portugal, as provided for in Article 36 of the RGICSF; b) Prior notification of changes to the elements communicated in the context of the prior notification of establishment of a branch in a Member State of the European Union or in a State belonging to the European Economic Area, when submitted by a credit institution with headquarters in Portugal subject to direct supervision by the ECB, as provided for in Article 40 of the RGICSF, with the exception of communications relating to the element indicated in Article 36(d) of the RGICSF, which continue to be processed via the Relevant Information System of Supervised Entities service (hereinafter identified as “SIRES”); c) Prior notification of provision of services in another Member State of the European Union or in another State belonging to the European Economic Area, when submitted by a credit institution with headquarters in Portugal subject to direct supervision by the ECB, as provided for in Article 43 of the RGICSF; d) Prior notification of changes to the elements communicated in the context of the prior notification of provision of services in another Member State of the European Union or in another State belonging to the European Economic Area, when submitted by a credit institution with headquarters in Portugal subject to direct supervision by the ECB, as provided for in Article 43 of the RGICSF; e) Prior notification of changes to the elements communicated in the context of the notification of establishment of branches in Portugal, when submitted by a credit institution authorized in a Member State of the European Union or in a State belonging to the European Economic Area, in accordance with Article 51 of the RGICSF.

Article 4. Voluntary Processing via the IMAS Portal 1 - In the case of groups of significant credit institutions, procedures relating to the authorization and dispensation of authorization of financial companies and mixed financial companies, as provided for in Article 35-B of the RGICSF, may be submitted via the IMAS Portal. 2 - The procedures referred to in Article 3, when submitted by natural persons or by legal persons other than those referred to in the corresponding subparagraphs of that provision, may be submitted via the IMAS Portal.

Article 5. Applicable Regime 1 - The provisions of Bank of Portugal Instruction No. 23/2018 of 5 November, amended by Bank of Portugal Instruction No. 7/2021 of 15 April and by Bank of Portugal Instruction No. 13/2025 of 15 October (hereinafter identified as “Instruction No. 23/2018”), apply to requests for authorization for the exercise of functions of members of administrative and supervisory bodies, holders of essential control functions, and managers of branches established in countries that are not Member States of the European Union submitted by institutions subject to direct supervision by the ECB, with the specificities resulting from the provisions of this Instruction. 2 - The provisions of Commission Implementing Regulation (EU) No. 2022/2581 of 20 June 2022 (hereinafter identified as “Implementing Regulation No. 2022/2581”) and Commission Delegated Regulation (EU) No. 2022/2580 of 17 June 2022 (hereinafter identified as “Delegated Regulation No. 2022/2580”), apply to authorization procedures for access to the activity of credit institutions, with the specificities resulting from the provisions of this Instruction. 3 - The provisions of Bank of Portugal Notice No. 6/2021 of 2 November (hereinafter identified as “Notice No. 6/2021”), apply to prior notifications of acquisition or increase of a qualified participation, with the specificities resulting from the provisions of this Instruction. 4 - The provisions of Commission Delegated Regulation (EU) No. 1151/2014 of 4 June 2014, amended by Commission Delegated Regulations (EU) No. 2022/192 and No. 2022/2403 of the Commission of 20 October 2021 and 16 August 2022, respectively (hereinafter identified as “Delegated Regulation No. 1151/2014”) and Implementing Regulation No. 926/2014, apply to procedures relating to branches and free provision of services in a Member State of the European Union by Significant Institutions, the decision-making competence of which belongs to the ECB, with the specificities resulting from the provisions of this Instruction.

Article 6. Exclusions 1 - Procedures relating to members of administrative and supervisory bodies, holders of essential control functions, and managers of branches established in countries that are not Member States of the European Union for purposes other than those provided for in subparagraphs a) to c) of Article 3(1) are not covered by the IMAS Portal, namely the following: a) Communication relating to subsequent facts, as provided for in Articles 32 and following of the RGICSF and in Articles 3(3) to (5) of Instruction No. 23/2018; b) Special registration or amendment thereof, as provided for in Articles 66 to 69 of the RGICSF; c) Prior notification for the purpose of opposition or non-opposition to the accumulation of offices as provided for in Article 33 of the RGICSF and Article 7 of Instruction No. 23/2018. 2 - The following procedures relating to the acquisition or reduction of a qualified participation are not covered by the IMAS Portal: a) Subsequent communications to be made in accordance with Article 104(1) and (3) of the RGICSF and Articles 5 and 6 of Notice No. 6/2021; b) Prior notifications of reduction of qualified participation to be made in accordance with Article 107(1) of the RGICSF and Article 7 of Notice No. 6/2021. 3 - The prior notification of amendment of the element referred to in Article 36(1)(d) is not covered by the IMAS Portal, in accordance with Article 40 of the RGICSF.

Article 7. Elements of instruction of requests for authorization for the exercise of functions within the IMAS Portal 1 - Requests for authorization for the exercise of functions covered by the obligation provided for in subparagraphs a) to c) of Article 3(1) are instructed with the elements identified in subparagraphs b) to f) of Article 2(1), (2), and (3), which must be submitted together with the completion of the online form available on the IMAS Portal