Instruction No. 02/2026

Instruction No. 2/2026 Official Gazette 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 Incorporations (Portuguese version and English version) Annex III - IMAS Form for Incorporations – National Specificities (Portuguese version) Annex III - IMAS Form for Incorporations – National Specificities (English version) Annex IV - Declaration for compliance with the duty of information in the context of the incorporation process of entities subject to authorization from Banco de Portugal (Portuguese version) Annex IV - Declaration for compliance with the duty of information in the context of the incorporation process of entities subject to authorization from Banco de Portugal (English version) Annex V - IMAS Form for Acquisition or Increase of Qualified Holdings (Portuguese version and English version) Annex VI - IMAS Form for Acquisition or Increase of Qualified Holdings – Additional Elements – Acquisition Without Control (Portuguese version) Annex VI - IMAS Form for Acquisition or Increase of Qualified Holdings – Additional Elements – Acquisition Without Control (English version) Annex VII - IMAS Form for Acquisition or Increase of Qualified Holdings – National Specificities (Portuguese version) Annex VII - IMAS Form for Acquisition or Increase of Qualified Holdings – National Specificities (English version) Annex VIII - IMAS Form for Branch Establishment (Portuguese version and English version) Annex IX - IMAS Form for Amendment to the Passport of an Already Established Branch (Portuguese version and English version) Annex X - IMAS Form for Branch Closure (Portuguese version and English version) Annex XI - IMAS Form for Notification for the Exercise of Freedom to Provide Services (Portuguese version and English version) Annex XII - IMAS Form for changes to the Notification for the exercise of Freedom to Provide Services (Portuguese version and English version) Annex XIII – Declaration for compliance with the duty of information in the context of prior notification of branch establishment 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 prior notification of branch establishment or provision of services in an EU or EEA Member State (English version)

Instruction No. 2/2026 Official Gazette No. 3/2026 Supplement • 2026/03/26 Topics Supervision :: Supervision .................................................................................................................................................................................................. Mod. 99999911/T – 01/14 Text of the Instruction Subject: Processing of procedures through the European Central Bank's Information Management System Portal

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

The IMAS Portal's main objective is to promote the harmonization of assessment conditions within the Single Supervisory Mechanism (hereinafter referred to as “SSM”), without prejudice to the national substantive regime applicable to each specific case. To this end, this service was developed to ensure (i) the simplification of the instruction of procedures covered by its scope, contributing to the speed of processing the respective procedures, and (ii) transparency with supervised entities regarding the stages of their respective procedures.

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

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

As of the effective date 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 holding in a credit institution;

(ii) Procedures relating to the exercise of activity through branches and the freedom to provide services in a European Union Member State by Significant Institutions; and

(iii) Authorization and exemption procedures for financial companies, as provided in Chapter IV-A of Title II of the General Regime for Credit Institutions and Financial Companies, approved by Decree-Law No. 298/92, of 31 December (hereinafter referred to as “RGICSF”), in the case of groups of significant credit institutions.

In view of this new context, it is important to amend 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 run their course on the aforementioned platform.

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

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

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

Also, procedures related to the exercise of activity through branches and freedom to provide services in a European Union Member State by Significant Institutions, for which the decision-making competence belongs to the ECB, become mandatory to be submitted through the IMAS Portal when submitted by credit institutions headquartered in Portugal, as well as by credit institutions headquartered in European Union Member States 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 submitting its communication or request, with the necessary information, as well as the respective formal requirements, to comply with the regimes established, respectively, in Articles 36 et seq., 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 referred to as “Implementing Regulation No. 926/2014”), to be provided in that service by applicants and supervised entities through structured fields available in an online form.

As for the authorization and exemption procedures for financial companies and mixed financial companies, in the case of significant groups, considering that, in these cases, the competent authority for deciding the authorization or exemption request is the ECB without the need for cooperation from national competent authorities, the use of the IMAS Portal for submitting the authorization or exemption request is voluntary.

Without prejudice to the provisions of the preceding paragraphs:

(i) Banco de Portugal recommends the use of the IMAS Portal by other individuals and legal entities who, not being covered by the obligation of Article 3, intend to submit, through this channel, one of the procedures provided herein, thereby optimizing the integrity and integration of the information submitted, as well as procedural speed and streamlining. Thus, all those who use the IMAS Portal are included in the subjective scope of this Instruction;

(ii) Other procedures or communications not covered by this Instruction must continue to be submitted through the currently in force channels, namely through the Supervised Entities Relevant Information System (SIRES) service, under the terms provided in Banco de Portugal Instruction No. 11/2023 of 15 May (Instruction No. 11/2023).

Finally, Instruction No. 11/2023 is amended to remove from its scope the procedures that are now regulated in this Instruction, and therefore, to be processed through the IMAS Portal. Thus, Banco de 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, through the European Central Bank's Information Management System Portal service (designated as Information Management System for the SSM, hereinafter referred to as “IMAS Portal”), of the procedures referred to in Articles 3 and 4, respectively, and defines the elements that must instruct the requests relating to the regulated procedures.

Article 2 Subjective scope

1 - Entities headquartered in Portugal subject to the supervision of Banco de Portugal or the European Central Bank (hereinafter referred to as “ECB”), as well as credit institutions headquartered in European Union Member States 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 through the IMAS Portal. 2 - Within the scope of this Instruction, institutions subject to direct ECB supervision are Significant Institutions classified according to the SSM Framework Regulation, approved by ECB Regulation (EU) No. 468/2014 of 16 April 2014. 3 - Individuals and legal entities not subject to the supervision of Banco de Portugal or the ECB may submit the procedures referred to in this Instruction through the IMAS Portal.

Article 3 Mandatory processing via IMAS Portal

1 - The following procedures are mandatorily processed through the IMAS Portal: a) Authorization for the exercise of functions by members of administrative and supervisory bodies and holders of essential control functions, when submitted by institutions subject to direct ECB supervision; b) Re-evaluation of essential function holders, under the terms provided in Article 33-A(5) of the General Regime for Credit Institutions and Financial Companies, approved by Decree-Law No. 298/92, of 31 December (hereinafter referred to as “RGICSF”), when submitted by institutions subject to direct ECB supervision; c) Authorization for the exercise of functions by managers of branches established in countries that are not European Union Member States, when submitted by institutions subject to direct ECB supervision; d) Authorization for the incorporation of credit institutions, under the terms provided in Article 16 of the RGICSF, when submitted by entities subject to the supervision of Banco de Portugal or the ECB; e) Prior notification of acquisition or increase of a qualified holding in a credit institution, under the terms provided in Article 102 of the RGICSF, when submitted by entities subject to the supervision of Banco de Portugal or the ECB.

2 - When Institutions choose to use electronic means, under the terms of 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 referred to as “Implementing Regulation No. 926/2014”), the following procedures are mandatorily processed through the IMAS Portal: a) Prior notification of branch establishment in a European Union Member State or in a State belonging to the European Economic Area, when submitted by a credit institution subject to direct ECB supervision headquartered in Portugal, under the terms provided in Article 36 of the RGICSF; b) Prior notification of changes to the elements communicated in the context of prior notification of branch establishment in a European Union Member State or in a State belonging to the European Economic Area, when submitted by a credit institution headquartered in Portugal subject to direct ECB supervision, under the terms provided 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 through the Supervised Entities Relevant Information System (hereinafter referred to as “SIRES”) service; c) Prior notification of the provision of services in another European Union Member State or in another State belonging to the European Economic Area, when submitted by a credit institution headquartered in Portugal subject to direct ECB supervision, under the terms provided in Article 43 of the RGICSF; d) Prior notification of changes to the elements communicated in the context of prior notification of the provision of services in another European Union Member State or in another State belonging to the European Economic Area, when submitted by a credit institution headquartered in Portugal subject to direct ECB supervision, under the terms provided in Article 43 of the RGICSF; e) Prior notification of changes to the elements communicated in the context of branch establishment in Portugal, when submitted by a credit institution authorized in a European Union Member State or in a State belonging to the European Economic Area, under the terms of Article 51 of the RGICSF.

Article 4 Voluntary processing via IMAS Portal

1 - In the case of groups of significant credit institutions, procedures relating to the authorization and exemption from authorization of financial companies and mixed financial companies, as provided in Article 35-B of the RGICSF, may be submitted through the IMAS Portal. 2 - The procedures referred to in Article 3, when submitted by individuals or legal entities other than those referred to in the corresponding paragraphs of the said provision, may be submitted through the IMAS Portal.

Article 5 Applicable regime

1 - The provisions of Banco de Portugal Instruction No. 23/2018, of 5 November, amended by Banco de Portugal Instruction No. 7/2021, of 15 April, and by Banco de Portugal Instruction No. 13/2025, of 15 October (hereinafter referred to as “Instruction No. 23/2018”), with the specificities resulting from the provisions of this Instruction, are applicable to requests for authorization for the exercise of functions by members of administrative and supervisory bodies, holders of essential control functions, and managers of branches established in countries that are not European Union Member States submitted by institutions subject to direct ECB supervision.

2 - The provisions of Commission Implementing Regulation (EU) No. 2022/2581 of 20 June 2022 (hereinafter referred to as “Implementing Regulation No. 2022/2581”) and Commission Delegated Regulation (EU) No. 2022/2580 of 17 June 2022 (hereinafter referred to as “Delegated Regulation No. 2022/2580”), with the specificities resulting from the provisions of this Instruction, are applicable to authorization procedures for access to the activity of credit institutions.

3 - The provisions of Banco de Portugal Notice No. 6/2021, of 2 November (hereinafter referred to as “Notice No. 6/2021”), with the specificities resulting from the provisions of this Instruction, are applicable to prior notifications of acquisition or increase of a qualified holding.

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 20 October 2021 and 16 August 2022, respectively (hereinafter referred to as “Delegated Regulation No. 1151/2014”) and Implementing Regulation No. 926/2014, with the specificities resulting from the provisions of this Instruction, are applicable to procedures relating to branches and freedom to provide services in a European Union Member State by Significant Institutions, for which the decision-making competence belongs to the ECB.

Article 6 Exclusions

1 - Procedures concerning members of administrative and supervisory bodies, holders of essential control functions, and managers of branches established in countries that are not European Union Member States with purposes other than those provided for in Article 3(1)(a) to (c) are not covered by the IMAS Portal, namely the following: a) Communication regarding subsequent facts, under the terms of Articles 32 et seq. of the RGICSF and Article 3(3) to (5) of Instruction No. 23/2018; b) Special registration or amendment thereof, under the terms of Articles 66 to 69 of the RGICSF; c) Prior communication for purposes of opposition or non-opposition to accumulation of positions under the terms of Article 33 of the RGICSF and Article 7 of Instruction No. 23/2018.

2 - The following procedures concerning the acquisition or decrease of a qualified holding are not covered by the IMAS Portal: a) Subsequent communications to be made under Article 104(1) and (3) of the RGICSF and Articles 5 and 6 of Notice No. 6/2021; b) Prior communications of decrease of a qualified holding to be made under Article 107(1) of the RGICSF and Article 7 of Notice No. 6/2021.

3 - The prior communication of changes to the element referred to in Article 36(1)(d), under the terms of Article 40 of the RGICSF, is not covered by the IMAS Portal.

Article 7 Elements for instructing authorization requests for the exercise of functions within the scope of the IMAS Portal

1 - Authorization requests for the exercise of functions covered by the mandatory requirement provided for in Article 3(1)(a) to (c) are instructed with the elements identified in Article 2(1)(b) to (f), (2) and (3) of Instruction No. 23/2018, which must be submitted together with the completion of the online form available on the IMAS Portal