Banco de Portugal Tightens Rules for Credit Intermediaries in 2026

Anyone working in credit intermediation in Portugal will have noticed that 2026 is going to be a different year. The Banco de Portugal (Portuguese Central Bank) is preparing a thorough revision of the rules governing the sector, with a direct impact on every entity that currently helps families find financing. More transparency, more mandatory alternatives, more supervision. For many professionals, this is the biggest change since the regime itself was created in 2017. For those who are prepared, it is also an opportunity to stand out in a more demanding market.

More than 6,000 entities under review

The universe of credit intermediation in Portugal is far larger than what appears in the mainstream press. Beyond the classic intermediaries who specialise in mortgages, it also encompasses companies offering car finance at point of sale, finance houses, entities that present proposals to end clients and many others. In total, the regulator has more than six thousand entities in its sights, and the proposal currently being prepared by the Banco de Portugal was reported in April this year by the newspaper Público.

This breadth is important to understand because it means the conversation is no longer solely about the large national networks. It now also involves independent intermediaries, family-run offices, small high-street practices and every structure that, in practice, does the work of connecting the client to the bank.

The central issue: obligation to present more than one proposal

The heart of the reform lies in the requirement that each client should receive a genuine set of alternatives before signing the contract. Today, many intermediaries have formal agreements with around five banking institutions, but in practice end up channelling the majority of applications to just one or two. This may be due to convenience, a stronger commercial relationship or more advantageous financial incentives. Whatever the reason, the result is that the client almost never gets to see the true range of options available to them.

The regulator’s proposal is straightforward: when the intermediary has a protocol with several banks, they must present a representative range of those banks in the simulations shown to the client. According to Ricardo Sousa, Director of the Behavioural Supervision Department at the Banco de Portugal, the aim is for each consumer to be able to effectively compare the available alternatives before making the most important financial decision of their life.

In practice, this means it is no longer sufficient for the professional to approach the client with a single simulation ready to sign. It becomes mandatory to show multiple proposals, explain the differences, and document that this comparison was carried out.

Transparency on commissions — a long-awaited topic

Another of the changes being prepared concerns information about how much the intermediary earns from each proposal. The commercial relationship between banks and intermediaries is based on commissions that vary according to the product, the amount and the institution. The fact that this remuneration is not currently fully visible to the end client has been identified as one of the main weaknesses of the current system.

With the new revision, the regulator wants consumers to clearly understand how much the professional receives, by whom they are paid and how that remuneration may or may not influence the recommendation they receive. It is not about banning commissions, which remain the standard form of payment in the sector throughout Europe, but rather about removing the issue from a grey area and placing it squarely on the table.

Prevention of conflicts of interest and new training requirements

The third major strand of the reform touches on a less discussed but equally relevant point: professional qualifications. Intermediaries have been required to hold certified training since the current regime came into force in 2017, but the regulator now wants to raise the bar. New requirements for continuous qualification are expected, along with tighter mechanisms to identify and prevent situations where the client’s interest may conflict with the intermediary’s commercial interest.

In addition, the Banco de Portugal has been stepping up its inspection activity. Around 400 supervisory actions are carried out annually on intermediaries across the country, and this volume is set to increase as the sector grows.

Why this is, in fact, good news for the best professionals

At first glance, any regulatory tightening looks like a headache for those working in the sector. More paperwork, more requirements, more time spent on bureaucracy. But if we look at this market’s track record over the past ten years, the truth is that every regulatory leap ended up benefiting the professionals who were already doing things properly and eliminating those who were cutting corners.

In 2024, credit intermediaries were responsible for approximately 56% of mortgage contracts entered into in Portugal and around 57% of the total volume, which equates to some 17.9 billion euros in financing. These figures show that the sector is more than mature — it is now the main gateway to mortgage lending in Portugal. With such a central position in the financial system, it is only natural that the regulator should want to ensure that work is carried out to clear and uniform standards.

Professionals who already work with multiple banks, who document each process thoroughly and who offer an honest comparison to the client will not need to change much. They may even emerge stronger, because the new reality will expose those who were taking shortcuts.

The practical problem: how to comply with all of this on a daily basis

The great difficulty of any new rule is not agreeing with it. It is putting it into practice during a busy week, with twenty or thirty processes running in parallel, each with its own client, its own documentation, its own banking deadlines and its own list of documents to gather.

In practice, what the new rules will require is:

• Being able to prove that multiple proposals were presented to each client, with records kept
• Documenting the commissions involved in each process, with traceability
• Maintaining a complete history of communications, simulations and decisions
• Centralising all client documentation in a single location accessible in the event of an inspection
• Continuously updating information on partner banks’ products

Those still working with loose folders on the computer, Excel spreadsheets and lost email exchanges will feel this change as an earthquake. Those who already have organised processes, with every step recorded in a dedicated tool, will see it as merely an update to their workflow.

What to do next

There is no need to wait for the final legislative text to begin preparing. There are concrete steps that any intermediary can start putting into practice today:

Effectively diversify partner banks. If you are registered with five banks but only send applications to two, begin building a commercial relationship with the remainder. Run simulations, learn the products, be prepared to show genuine alternatives to the client.

Create a documented comparison procedure. Each client should receive a visible comparison between at least three alternatives, with the difference in total cost expressed in euros and in years. This comparison should be kept on file.

Review how you communicate commissions. Having a standard clause in the intermediation contract, written in plain language, about how much you receive from each banking institution is already half the battle.

Centralise your entire operation in a specialised CRM. Dispersed information is the greatest enemy of compliance. A good intermediation CRM aggregates clients, processes, documentation, simulations, communications and history in a single place, with guaranteed traceability. Above all, it enables you to demonstrate to the Banco de Portugal, in the event of an inspection, that the work was done in accordance with the law.

Train your team. When the new rules come into force, employees who know the new framework and apply it naturally will be worth their weight in gold.

Conclusion

The revision of the credit intermediary regime that the Banco de Portugal is preparing is not a bogeyman — it is a confirmation of something that has been anticipated for some time: the sector has grown, gained enormous weight in the Portuguese economy, and therefore must operate like any other regulated financial activity, with clear processes, documented evidence and full transparency for the end client. Professionals who already work this way emerge stronger. Those who still operate informally now have a clear deadline to get organised.

CRM Crédito was built precisely to meet this type of requirement: centralise everything, document every step, facilitate proposal comparison and give the intermediary peace of mind in the face of any inspection. If you do not yet have a tool that matches the new rules, now is the right time to find one.

Related reading

• Credit Intermediary in Portugal: The Complete Guide — the single reference on credit intermediation in Portugal.
• Obligations of the Credit Intermediary in Portugal (2025) — the legal baseline the new rules are reinforcing and expanding.
• Want to Become a Credit Intermediary? With Legal Support, Everything Becomes Easier — how legal support makes meeting the new requirements much simpler.