Cryptocurrency license in Portugal conditions and procedure

Content
In 2024, the volume of transactions with virtual assets in Europe exceeded €1.2 trillion, and Portugal entered the top 5 EU jurisdictions in terms of cryptocurrency sector growth. But behind this impressive growth lies a paradox: more than 60% of international crypto companies face licensing refusals due to non-compliance with Banco de Portugal’s requirements and errors in AML/KYC policies. Why do some projects obtain a cryptocurrency license in Portugal in 4 months and scale all over the EU, while others cannot complete the procedure for years and lose investments?

What truly underlies Portugal’s investment attractiveness for the cryptocurrency business? How to avoid common mistakes, ensure the international expansion of a crypto business, and use the free provision of services principle to enter EU markets? I see daily how entrepreneurs underestimate the nuances of cryptocurrency regulation in Portugal and miss strategic opportunities.

In this article, I will not just explain how to get a crypto license in Portugal but provide a practical guide: from choosing a business model and preparing documents to implementing compliance procedures and optimizing taxation. 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

Illustration for the section 'Cryptocurrency License in Portugal' in the article 'Cryptocurrency License in Portugal – conditions and procedure'
Cryptocurrency license in Portugal becomes a key element for companies and investors seeking to legally operate with digital assets in the country. The development of national regulation and the introduction of European standards like MiCA are significantly changing the rules for the entire cryptocurrency market.

Cryptocurrency Regulation in Portugal

Portugal: one of the few EU countries where cryptocurrency regulation is built on a combination of national legislation and pan-European standards. The Banco de Portugal plays a crucial role in licensing cryptocurrency businesses, issuing licenses for activities with virtual assets (virtual assets) since 2021 in accordance with the EU Directive 5AMLD (2018/843), the Anti-Money Laundering Law (AML Law), and FATF standards.

Banco de Portugal not only controls the registration of cryptocurrency companies but also their ongoing financial monitoring, the implementation of internal AML/KYC policies, and transaction transparency. 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.
Special attention is given to the legalization of income obtained through criminal means and interaction with European regulators. The regulator requires not only formal compliance with Directive 5AMLD but also the real implementation of international FATF standards, which is reflected in requirements for corporate structure, compliance officer, and internal audit.

Licensing of Crypto Exchanges and Platforms

A cryptocurrency license in Portugal is mandatory for companies engaged in:

  • exchange of cryptocurrency for fiat and back (crypto exchange license Portugal)
  • operations between different types of virtual assets
  • providing custodial (storage) services
  • activities of crypto exchanges and peer-to-peer platforms
  • conducting ICO/IEO, issuance and maintenance of stablecoins, DeFi products
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

Illustration for the section 'Registration of a Cryptocurrency Company in Portugal' in the article 'Cryptocurrency License in Portugal – conditions and procedure'
Registering a cryptocurrency company in Portugal is a multi-step process, including the choice of a legal form, obtaining the relevant license, and complying with local regulatory requirements. For a successful business launch, it is important to consider the requirements for corporate structure and real presence, 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

Registering a cryptocurrency company in Portugal requires strict compliance with the substance principle, requiring real business presence in the country. Key requirements include:

  • having a Portuguese legal address and office
  • at least one resident director (EU or Portuguese citizen)
  • corporate structure crypto company with transparent share allocation and leadership responsibility
  • a minimum capital for a crypto company: starting from 50,000 EUR (the amount may be higher for exchanges and custodial services)
  • confirmation of the sources of funds and the legality of investments
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 document package for registering a cryptocurrency company and applying for a crypto license in Portugal includes:

  • statutes and founding documents
  • crypto company business plan with financial forecasts, liquidity analysis, and business model description
  • internal AML/KYC policies, procedures of Due Diligence of clients, and a description of the internal control system
  • information about beneficiaries, ownership structure, and corporate governance
  • confirmation of the presence of a compliance officer with relevant experience
  • office lease agreement, confirmation of substance
  • bank certificates about depositing the minimum capital
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.

Timelines, Cost, and Reasons for License Denial

The procedure for obtaining a cryptocurrency license in Portugal consists of several stages:

  1. registration of a legal entity and opening a bank account
  2. Preparation and submission of the complete document package to Banco de Portugal
  3. Preliminary audit and requests for additional information from the regulator
  4. Decision-making and license issuance
The timeframe for obtaining a crypto license in Portugal usually amounts to 4–6 months but can increase if document revisions or additional beneficiary checks are required. The cost of a cryptocurrency license in Portugal consists of state fees (from 10,000 EUR), document preparation expenses, legal support, and compliance audit.
Main reasons for license denial: insufficient detail in the business plan, weak internal AML/KYC policies, opaque ownership structure, lack of substance, and errors in client due diligence. 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

Illustration for the section 'AML/KYC for Crypto Business in Portugal' in the article 'Cryptocurrency License in Portugal – conditions and procedure'
AML/KYC for crypto business in Portugal is not just a formality but an integral part of the legal operation of companies involved with virtual assets. The strict requirements of Portuguese regulators imply the implementation of comprehensive standards, detailing of internal policies, and assigning the compliance officer role as a key figure in the anti-money laundering and counter-terrorism financing system.

Internal Policies and the Role of Compliance Officer

For successful operation of the cryptocurrency business in Portugal, it is critically important to develop and implement AML/KYC internal policies complying with both national legislation and international FATF standards. 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.

Compliance with FATF and 5AMLD Standards

Since 2021, Portugal has implemented the provisions of the EU Directive 5AMLD (2018/843), tightening the AML/KYC requirements for crypto companies. To fully comply with FATF and 5AMLD standards, it is necessary to:

  • ensure transaction transparency and traceability of all operations with virtual assets
  • conduct regular checks for money laundering derived from criminal activities
  • 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

Illustration for the section 'Taxes on Cryptocurrency in Portugal' in the article 'Cryptocurrency License in Portugal – conditions and procedure'
Taxes on cryptocurrency in Portugal have significantly changed in recent years: now certain operations with digital assets are subject to taxation, and it is important to consider the holding period of crypto assets and the peculiarities of different types of income. Let’s take a look at how cryptocurrency taxation is structured in Portugal and what legal optimization methods exist.

Taxation and Its Optimization

Portugal is traditionally considered one of the most lenient jurisdictions in the EU regarding cryptocurrency taxation. Personal incomes from cryptocurrency operations are not subject to personal income tax. However, for legal entities, the standard corporate tax (CIT) rate of 21% applies, plus municipal surcharges. The Portuguese Tax and Customs Authority (AT) requires transparent accounting of all operations and compliance with EU standards.
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, smart tax planning and choosing optimal business structures create an additional advantage for investors looking to obtain a residence permit through crypto business.

Residency Through Crypto Business, Advantages for Investors

Opening a cryptocurrency company in Portugal unlocks the opportunity for obtaining residency through crypto business (residence by investment), which is especially relevant for investors from the CIS and Asia. To achieve this, one needs to:

  • register a company with an actual presence and contribute minimum capital
  • confirm investments and business activity
  • 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

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Crypto business in Portugal: practical aspects cover the key steps for launching and legalizing activities with digital assets. In this section, we disassemble 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. Most banks require:

  • confirmation of substance (office, personnel, actual activity)
  • the presence of a Banco de Portugal license for working with virtual assets
  • 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

Banco de Portugal sets high technological requirements for crypto exchange and custodial service platforms. Among the key ones:

  • the presence of backup systems and operation log audits
  • protection of user and investor data
  • integration of financial monitoring and reporting tools
  • regular IT infrastructure audits
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:

  • non-compliance with AML/KYC and internal control requirements
  • insufficient transparency of the corporate structure
  • errors in the preparation of documents for licensing
  • 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 continues to evolve: the country combines flexibility concerning digital assets with the implementation of new European standards and the tightening of some rules for companies and investors. New requirements affect different areas of the crypto industry, including DeFi and stablecoins, impacting business models, Licensing, and user protection.

Regulatory Changes for DeFi and Stablecoins

In 2025, further tightening of regulations for stablecoins and DeFi projects is expected in Portugal. The regulator is planning to introduce new investor protection standards, strengthen technological infrastructure requirements, and integrate with pan-European fintech initiatives. 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.

Pros and Cons of Doing Business in Portugal

Criterion Portugal Lithuania Estonia
License acquisition time 4-6 months 3-4 months 2-3 months
Substance requirements Office, staff Office, director Office, resident director
Minimum capital From 50,000 EUR From 125,000 EUR From 12,000 EUR
Residency possibility Yes No No
Banking services Difficult, but possible Limited Limited
Portugal stands out for its investment attractiveness, the possibility of obtaining residency, and the flexibility of its corporate structure. Nonetheless, the licensing process is more complex and requires deep compliance. In COREDO’s practice, successful international expansion cases were based on a combination of licensing in Portugal and using the free provision of services principle to enter EU markets.

Practical Tips for Entrepreneurs

A cryptocurrency license in Portugal opens strategic opportunities for international business: access to the EU market, flexibility of corporate structure, tax advantages, and migration benefits. 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:

  • Conduct an audit of the business model and corporate structure considering Banco de Portugal’s requirements
  • Develop a detailed business plan and internal AML/KYC policies
  • Appoint an experienced compliance officer and implement an internal control system
  • Prepare complete document packages and ensure real presence (substance)
  • Organize a preliminary compliance audit and proactively interact with the regulator
  • Structure the business considering tax optimization and the possibility of international expansion
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.
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