COREDO – EU Legal & Compliance Services Expert legal consulting, financial licensing (EMI, PSP, CASP under MiCA), and AML/CFT compliance across the European Union. Headquartered in Prague, we provide seamless regulatory solutions in Germany, Poland, Lithuania, and all 27 EU member states.
Gregory Lutsenko
29.08.2025 | 6 min read
Updated: 20.10.2026
Since 30 December 2024 the MiCA Regulation has applied in the EU, and in Portugal Law No. 69/2025 of 22 December 2025 ensures its implementation. A registration with Banco de Portugal under the former AML/CFT rules no longer replaces an authorisation: the transitional period for such companies ended on 1 July 2026. Crypto-asset services now require CASP authorisation under MiCA. What does this mean for anyone planning a crypto business in Portugal?
What has really changed for the cryptocurrency business in Portugal? Who grants the authorisation now, how much capital is needed, how does the EU passport work and how is crypto income taxed? I see daily how entrepreneurs rely on outdated overviews and prepare documents for a regime that no longer exists.
In this article, I will not just explain how to get a crypto license in Portugal under MiCA. I will provide a practical guide: from choosing services and the capital class to the application, compliance procedures and taxes. If you want not only to register a cryptocurrency company in Portugal but to build a sustainable international business - read to the end. Here you will find answers to key questions, get real cases from COREDO, and receive practical recommendations.
Cryptocurrency License in Portugal
Cryptocurrency license in Portugal today means authorisation as a crypto-asset service provider (CASP) under Regulation (EU) 2023/1114, that is, MiCA. The Regulation has applied since 30 December 2024 and sets uniform EU requirements for such companies. The national Law No. 69/2025 designates the competent authorities, divides tasks between them and lays down sanctions.
Cryptocurrency Regulation in Portugal
Portugal: one of the EU countries where cryptocurrency regulation is built on a combination of an EU-wide regulation and a national law. Law No. 69/2025 was published in the Diário da República on 22 December 2025. It designates two competent authorities: Banco de Portugal and the Securities Market Commission (CMVM). Banco de Portugal is responsible for CASP authorisation, their prudential requirements and governance, and for issuers of ART and EMT tokens. The CMVM is responsible for public offers of other crypto-assets, the rules for specific crypto-asset services and the prevention of market abuse.
The application for CASP authorisation is filed with Banco de Portugal, which forwards it to the CMVM within two working days. If the CMVM sees obstacles, it sends a reasoned opinion to Banco de Portugal. Banco de Portugal communicates the authorisation decision. The CMVM, in turn, supervises how CASPs treat clients: fair conduct, safekeeping of assets, complaints and conflicts of interest. In COREDO's practice, we have repeatedly faced situations where even a strong business plan did not compensate for formal violations in client due diligence or insufficient detail in internal compliance procedures. This is why preparation for licensing begins with a deep audit of the business model and internal control.
Providing crypto-asset services without authorisation is prohibited: Law No. 69/2025 classifies it as a very serious administrative offence (contraordenação muito grave). The fine for a legal person ranges from 25,000 to 5,000,000 EUR. The upper limit rises to three times the economic benefit obtained or to 5% of turnover, whichever is higher.
Licensing of Crypto Exchanges and Platforms
CASP authorisation is needed by a company that provides at least one of the services listed in MiCA to clients on a professional basis:
- custody and administration of crypto-assets on behalf of clients (custodial services)
- operation of a trading platform for crypto-assets (crypto exchange)
- exchange of crypto-assets for fiat and for other crypto-assets (crypto exchange license Portugal)
- execution of orders, reception and transmission of client orders, placing of crypto-assets
- advice, portfolio management and transfers of crypto-assets on behalf of clients
(before Law No. 69/2025 entered into force) Banco de Portugal clearly delineates the types of activities requiring licensing and imposes separate technological requirements on the platform: investor and user protection, transaction transparency, IT infrastructure resilience, and the presence of fraud prevention procedures. Solutions developed by COREDO for clients in the DeFi and custodial services sector always include modular compliance architecture, allowing business scaling without regulatory risks.
Registration of a Cryptocurrency Company in Portugal
Registering a cryptocurrency company in Portugal involves two steps: setting up a legal entity and obtaining CASP authorisation. Registering the company alone gives no right to provide crypto-asset services. The requirements for structure and real presence come primarily from MiCA and are detailed in the following subsections.
Let's move on to the key aspects of forming a corporate structure and the requirements for the actual presence of the company.
Corporate Structure and Real Presence: Requirements
MiCA and Law No. 69/2025 require a CASP to have a real presence in the EU, not just a formal address. Key requirements include:
- a registered office in an EU country where the company provides at least part of its crypto-asset services; to apply to Banco de Portugal, the office must be in Portugal
- a place of effective management in the EU and at least one director resident in the EU
- a corporate structure of the crypto company with transparent ownership, including holders of qualifying holdings
- minimum capital under Annex IV of MiCA: 50,000, 125,000 or 150,000 EUR depending on the services
- a management body whose members meet the MiCA requirements on good repute and qualifications
The experience of COREDO shows that formal fulfilment of these requirements is not enough: the regulator evaluates the real activities of the office, the presence of employees, business activity, and integration into the local business environment. In several cases, the COREDO team provided recruitment and training of local staff, assisted in opening a bank account for the crypto company, and built corporate management taking into account Banco de Portugal's requirements.
Documents for Obtaining a Crypto License
The application for CASP authorisation is filed with Banco de Portugal, and its content is set by Article 62 of MiCA. The document package includes:
- articles of association, details of the legal form and the company's contact details
- a programme of operations listing the crypto-asset services and describing the business model
- a description of internal control, risk management and AML/KYC policies, including client Due Diligence
- information on managers, holders of qualifying holdings and governance arrangements
- proof of prudential safeguards, that is, capital under Annex IV of MiCA
- technical documentation of ICT systems and security arrangements
- the procedure for segregating clients' crypto-assets and funds and the complaints-handling procedure
In COREDO's practice, detailed elaboration of the business plan and internal compliance documentation allowed clients to successfully pass the application review stages and obtain a cryptocurrency license in Portugal on the first try (before Law No. 69/2025 entered into force).
Timelines, Cost, and Reasons for License Denial
The procedure for obtaining a cryptocurrency license in Portugal under MiCA consists of several stages:
- registration of a legal entity and preparation of the application under Article 62 of MiCA
- Submission of the application to Banco de Portugal, which forwards it to the CMVM
- Completeness check and requests for additional information from the regulator
- Decision to grant or refuse the authorisation
MiCA gives the regulator 25 working days to check whether the application is complete and 40 working days to decide after receiving a complete application. A request for additional information may suspend this period, but for no more than 20 working days. In practice, the overall timeline depends on the quality of the package and the time needed for revisions. Law No. 69/2025 does not specify fees, so the filing conditions should be checked with Banco de Portugal at the date of application. Other costs consist of document preparation, legal support, compliance and capital.
If the application remains incomplete by the set deadline, the regulator may refuse to review it. Main reasons for denial: a weak programme of operations, formal AML/KYC policies, an opaque ownership structure, insufficient capital and lack of substance. COREDO's practice confirms: thorough preparation and proactive engagement with the regulator minimize the risk of denial.
Moving to the next stage: the implementation and adherence to AML/KYC procedures is a mandatory requirement for the successful operation of crypto businesses in Portugal.
AML/KYC for Crypto Business in Portugal
AML/KYC for crypto business in Portugal is not just a formality but an integral part of the legal operation of companies involved with crypto-assets. A description of internal control and risk management is part of the authorisation application itself. That is why the compliance officer role and the anti-money laundering and counter-terrorist financing policies must be in place before filing.
Internal Policies and the Role of Compliance Officer
For a CASP operating in Portugal, it is critically important to have internal AML/KYC policies that comply with Law No. 83/2017 on AML/CFT and with the MiCA governance requirements. Key elements include:
- appointing an experienced compliance officer with the authority to control and train staff
- implementing client due diligence procedures (KYC, transaction monitoring, risk assessment)
- regular internal audits and reporting of crypto companies
- automation of financial monitoring processes and identification of suspicious activities
The COREDO team implemented comprehensive internal control systems integrated with the IT platform for clients, allowing not only compliance with Banco de Portugal's requirements but also increased trust from investors and banking partners.
AML/CFT after MiCA: Law No. 83/2017 and Transfer Rules
Before MiCA, virtual asset companies registered with Banco de Portugal under Article 112.º-A of Law No. 83/2017 on AML/CFT. Law No. 69/2025 expressly links CASPs to Law No. 83/2017 and to Regulation (EU) 2023/1113 on information accompanying transfers of funds and crypto-assets. To meet the AML/KYC requirements in full, it is necessary to:
- ensure transaction transparency and traceability of all operations with crypto-assets
- send information on the originator and the beneficiary together with each crypto-asset transfer
- update internal AML/KYC policies according to legislative changes and market best practices
- integrate automated monitoring and reporting systems
COREDO's compliance solutions enable not only current requirements compliance but also quick adaptation to new regulatory standards, which is critical for business sustainability.
Taxes on Cryptocurrency in Portugal
Taxes on cryptocurrency in Portugal have significantly changed in recent years: part of crypto-asset income is now subject to personal income tax, and the holding period matters. Let's take a look at how cryptocurrency taxation is structured in Portugal for individuals and for companies.
Taxation and Its Optimization
Law No. 24-D/2022 of 30 December 2022 added to the IRS Code the income from the disposal for consideration of crypto-assets that are not securities. Gains on crypto-assets held for 365 days or more are, as a rule, excluded from taxation. The positive balance of other such operations is taxed at a special rate of 28%, but Portuguese residents may opt for aggregate taxation. For companies, the general IRC rate is 19% for tax periods beginning in 2026, 18% in 2027 and 17% from 2028. The overall tax burden must be calculated for the specific company and its shareholders.
In COREDO's practice, we recommend clients use the free provision of services principle for optimizing tax obligations during international expansion and structuring the business to apply double taxation avoidance agreements. It is important to consider tax risks associated with the classification of operations and income sources and to timely implement financial monitoring procedures.
Thus, the tax consequences are worth calculating before launch: for the company, for its shareholders and for clients. This is especially important for investors who are also considering a move to Portugal.
Residency and Crypto Business: What Investors Should Know
CASP authorisation gives the right to provide crypto-asset services, but not the right to reside. A residence permit is obtained separately under Portuguese immigration law, and its conditions should be checked at the date of application. At the same time, MiCA requires at least one CASP director to be resident in the EU. When planning, it is therefore worth deciding in advance to:
- determine which of the directors will reside in the EU and manage the company
- confirm the company's real activity in Portugal: office, staff, clients
- comply with the requirements regarding transparency of structure and sources of funds
COREDO's implemented projects show that combining Portugal’s investment attractiveness and flexible migration programs allows not only to legalize EU presence but also to scale the business to the entire European market.
Crypto Business in Portugal: Practical Aspects
The practical aspects of crypto business in Portugal cover the key steps for launching activities with digital assets. In this section, we look at operational nuances, including opening a bank account, one of the first and most important stages for any cryptocurrency company in the Portuguese market.
Opening an Account for Crypto Companies
Banking services for crypto companies in Portugal: one of the most complicated tasks for new market entrants. Banks usually ask for:
- confirmation of substance (office, personnel, actual activity)
- CASP authorisation under MiCA, since the former registration with Banco de Portugal is no longer sufficient
- implementation of internal AML/KYC policies and a transparent ownership structure
The COREDO team supports clients at all stages: from document preparation to personal meetings with banks and building relationships with financial institutions. In several cases, comprehensive preparation and process transparency enabled our clients to successfully open a bank account for the crypto company and ensure sustainable banking services.
Requirements for Crypto Exchange Platforms
MiCA sets organisational and technological requirements for CASPs and adds specific rules for individual services. Among the key ones:
- technical documentation of ICT systems and security arrangements as part of the application
- operating rules of the trading platform and an order execution policy, where these services are provided
- segregation of clients' crypto-assets and funds and a custody policy
- a plan for the orderly wind-down of activities
Solutions developed by COREDO for clients include implementing modular platforms with scaling capability, allowing not only to meet licensing requirements but also to react quickly to market changes and regulator requests.
Risks and Mistakes When Working with Regulators
Key risks of conducting crypto business in Portugal relate to:
- operating without CASP authorisation after the end of the transitional period
- non-compliance with AML/KYC and internal control requirements
- insufficient transparency of the corporate structure
- errors in preparing the application and delays in opening bank accounts
COREDO's practice shows that the best results are achieved through proactive collaboration with the regulator, regular updates of compliance procedures, and the implementation of internal audits. We recommend conducting a preliminary compliance audit before filing an application and using independent consultations to minimize legal risks of cryptocurrency operations.
Cryptocurrency Regulation in Portugal
Cryptocurrency regulation in Portugal is now built on MiCA: the uniform EU rules are complemented by a national law on competent authorities and sanctions. Licensing, business models and client protection change along with it, including the rules for stablecoins.
Stablecoins and Other Crypto-Assets under MiCA
Under MiCA, stablecoins are regulated as asset-referenced tokens (ART) and e-money tokens (EMT). In Portugal, their issuers are supervised by Banco de Portugal. Public offers of other crypto-assets and market abuse fall to the CMVM. COREDO's practice shows that corporate structure flexibility and readiness for fast updates to internal policies are key factors of business resilience in a changing regulatory environment.
Portugal, Lithuania and Estonia under MiCA: What Is the Same
| Criterion | Portugal | Lithuania | Estonia |
|---|---|---|---|
| Basis for operating as a CASP | Authorisation under Art. 63 MiCA | Authorisation under Art. 63 MiCA | Authorisation under Art. 63 MiCA |
| Minimum capital (Annex IV MiCA) | 50,000 / 125,000 / 150,000 EUR | 50,000 / 125,000 / 150,000 EUR | 50,000 / 125,000 / 150,000 EUR |
| Decision period for a complete application | 40 working days | 40 working days | 40 working days |
| Services in other EU countries | Notification under Art. 65 MiCA | Notification under Art. 65 MiCA | Notification under Art. 65 MiCA |
| Transitional period for existing providers (ESMA list) | 18 months | 12 months | 18 months |
Under MiCA, the capital, the review period and the procedure for operating in other EU countries are the same in all three countries. The transitional periods in all three countries have already expired. The difference now lies in the competent authority, taxes, banking infrastructure and the practice of dealing with the regulator.
Practical Tips for Entrepreneurs
A cryptocurrency license in Portugal under MiCA opens access to the EU market: after notification under Art. 65 MiCA, a Portuguese CASP may also provide services in other EU countries. On the other hand, success depends on thorough preparation, implementing effective compliance procedures, and competent legal support for the crypto business.
Practical steps for obtaining a crypto license:
- Define the list of crypto-asset services and the capital class under Annex IV of MiCA
- Develop a programme of operations, a business plan and internal AML/KYC policies
- Appoint management that meets the MiCA requirements and implement an internal control system
- Prepare a complete document package under Article 62 of MiCA and ensure real presence (substance)
- File the application with Banco de Portugal and respond promptly to the regulator's requests
- Calculate in advance the taxes of the company and its shareholders and the plan for entering other EU markets
COREDO's experience shows: comprehensive business support, process transparency, and a strategic approach to licensing form the basis for long-term success and risk minimization for cryptocurrency companies in Portugal.