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Portugal: fintech & payments regulation

Regulated

Portugal fintech & payments: BDP supervision under PSD2/AMLA; VASP registration required

Lead regulator:
Banco de Portugal
Key law:
Law No. 83/2017 (transposing PSD2)
Last updated:
2026-07-12

Portugal maintains a fully regulated environment for fintech and payments, with the Banco de Portugal (BDP) serving as the primary supervisor for payment institutions, electronic money institutions, and credit institutions. The regulatory framework is anchored in Law No. 83/2017, which implements the EU Payment Services Directive 2 (PSD2), alongside specific BDP notices detailing prudential and conduct standards.

Virtual Asset Service Providers (VASPs) are also regulated, requiring mandatory registration with the BDP under Article 112-A of Law No. 83/2017 to align with anti-money laundering directives. The central bank actively updates operational rules for payment systems, including the Interbank Clearing System (SICOI) and TARGET-PT, while enforcing strict reporting and cybersecurity obligations.

Recent regulatory direction emphasizes transparency, such as the identification of ultimate beneficiaries in payment references, and the facilitation of instant euro credit transfers. The BDP continues to refine authorization procedures and reporting templates to ensure robust oversight of the digital payments ecosystem.

Who regulates

  • Banco de Portugal

    Primary supervisor for payment institutions, electronic money institutions, credit institutions, and VASP registration.

    [1][2][3]

Core laws & rules

  • Law No. 83/2017 (2017)

    National law transposing the EU Payment Services Directive 2 (PSD2), establishing the framework for payment institutions, e-money institutions, and VASP registration.

    [3][2]

Licensing & registration

  • Payment Institution / Electronic Money Institution

    Authorization procedures, evaluation criteria, and registration requirements are regulated by BDP Notice No. 2/2021, which updates prudential and conduct supervision standards.

    [2]

  • Virtual Asset Service Provider (VASP)

    Entities providing services with virtual assets must register with the BDP under Article 112-A of Law No. 83/2017, following specific registration procedures outlined in BDP Notice No. 3/2021.

    [3]

Restrictions & warnings

  • Payment service providers must identify the ultimate beneficiary in payment reference and direct debit transactions to enhance transparency and prevent misuse.

    [4]

  • Entities must comply with specific reporting obligations regarding payment elements, disclosure, cybersecurity, and operational resilience.

    [5]

Direction of travel

  • The BDP is actively updating operational rules for payment systems (e.g., SICOI, TARGET-PT) and enforcing requirements for instant euro credit transfers, indicating a focus on modernization and security.

    [6][7][8]

Sources

  1. Notice No. 3/2023 · 2023-01-01
  2. Notice No. 2/2021 · 2021-01-01
  3. Notice No. 3/2021 · 2021-01-01
  4. Notice No. 4/2024 · 2024-01-01
  5. Notice No. 5/2025 · 2025-01-01
  6. Circular Letter No. CC/2024/00000051 · 2024-11-28
  7. Instruction (Historical) No. 9/2025 · 2025-06-26
  8. Instruction (Archive) No. 3/2023 · 2023-02-23

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This guide is compiled automatically from 8 primary-source documents published by Portugal's regulators, reviewed by RegAlert, and refreshed monthly (last updated 2026-07-12). It is not legal advice — always confirm requirements with the regulator or local counsel before acting.