COREDO > Financial Licence in Portugal

Financial Licence in Portugal

Portugal is one of the most attractive fintech jurisdictions in the European Union, combining a modern regulatory environment, advanced digital infrastructure, and access to the single European market. Portuguese financial licences allow companies to provide payment, investment, and other regulated services throughout the EEA under the passporting regime.

Since 2016, COREDO has been assisting clients with obtaining financial licences in Portugal, providing full support — from selecting the appropriate licence and preparing documentation to liaising with Banco de Portugal and securing authorisation.

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Cost of the service
from 60 000 EUR

Regulatory Framework

Portugal’s financial sector is regulated by two key authorities. Banco de Portugal (Bank of Portugal) supervises banks, electronic money institutions and payment institutions. CMVM (Comissão do Mercado de Valores Mobiliários — Securities Market Commission) regulates the activities of investment firms, brokers and asset managers.

The core of the regulatory framework comprises:

RJSPME (Regime Jurídico dos Serviços de Pagamento e da Moeda Eletrónica) — Decree-Law No. 91/2018 of 12 November 2018, which transposed PSD2 Directive (2015/2366/EU) on payment services into Portuguese law.
PSD2 (Directive 2015/2366/EU) — regulates payment institution activities, establishing requirements for capital, AML/KYC and the safeguarding of client funds.
EMD2 (Directive 2009/110/EC) — establishes the legal framework for electronic money institutions, including the minimum regulatory capital of EUR 350,000.
MiFID II (Directive 2014/65/EU) — regulates investment services and the activities of investment firms under CMVM supervision.
CRD IV (Directive 2013/36/EU) — establishes prudential requirements for credit institutions, including the minimum share capital requirement for banks of EUR 5,000,000.

Licence passporting is ensured by Article 28 of PSD2 for payment institutions and Article 3 of EMD2 for EMIs. Portuguese licences grant the right to provide services across all 30 EEA states by notifying Banco de Portugal of the intention to operate in the host member state.

Types of Financial Licences in Portugal

Portuguese legislation provides for several types of financial licences, each corresponding to a specific activity profile:

Licence Type	Description	Min. Regulatory Capital	Review Period	Regulator
EMI (Electronic Money Institution)	Issuance of electronic money, e-wallet management, payment services	EUR 350,000	3–12 months	Banco de Portugal
PI (Payment Institution) — full range	Full range of payment services (transfers, direct debit, acquiring)	EUR 125,000	3–12 months	Banco de Portugal
PI — payment initiation (PIS)	Online payment initiation (Open Banking)	EUR 50,000	3–12 months	Banco de Portugal
PI — money remittance	Money remittance services	EUR 20,000	3–12 months	Banco de Portugal
Investment Firm (MiFID II)	Brokerage, portfolio management, investment advisory	EUR 50,000–730,000	6–12 months	CMVM
Credit Institution (banking licence)	Deposit-taking, lending, full range of banking services	EUR 5,000,000	12–18 months	Banco de Portugal + ECB

Important: the minimum regulatory capital and the cost of COREDO’s services are different amounts. The regulatory capital must remain on the company’s balance sheet as own funds throughout the entire period of activity. The cost of COREDO’s services is a separate expense for legal support.

Advantages of the Jurisdiction

Portugal combines the stability of the EU legal system with practical advantages for financial businesses.

EEA passporting.

A licence from Banco de Portugal or CMVM automatically grants access to the market of all 30 EEA countries through the PSD2, EMD2 and MiFID II passporting mechanism. The company notifies the host country’s regulator — and can immediately commence operations without the need for re-licensing.

Portugal FinLab.

A joint initiative of Banco de Portugal and CMVM providing fintech companies with an informal consultative dialogue with regulators during the product development stage. This reduces regulatory uncertainty and accelerates the preparation of licence applications.

Technology Free Zones (ZLT).

Portugal’s digital strategy provides for the creation of dedicated zones with adapted regulatory regimes for innovative sectors, including fintech. This creates additional incentives for technology-driven financial companies.

Competitive operating costs.

Compared to the United Kingdom, Germany and France, Portugal offers lower operating costs — from rental rates to the cost of qualified personnel — while maintaining access to the EU market.

Advanced digital infrastructure.

Lisbon is among the European cities with the most developed infrastructure for digital companies, as confirmed by its regular presence in top European fintech ecosystem rankings.

Stable legal system.

Portugal has been an EU member since 1986, consistently implementing EU directives and ensuring legal certainty for foreign investors.

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General Requirements for Obtaining a Licence

The requirements of Banco de Portugal and CMVM for financial licence applicants are based on EU directives and are uniform across all EU jurisdictions; however, Portugal establishes a number of specific procedural requirements.

Legal form.

Companies obtaining an EMI or PI licence in Portugal must be incorporated as a joint-stock company (sociedade anónima) or a limited liability company (sociedade por quotas). The registered office and head office must be located in Portugal.

Minimum regulatory capital.

Established by EU directives: EMI — EUR 350,000, PSP/PI depending on the type of services — from EUR 20,000 to EUR 125,000. For a banking licence — at least EUR 5,000,000.

Corporate governance.

Appointment of at least two directors with experience in the financial market, clean criminal records and good reputation is required. Banco de Portugal conducts a fit & proper assessment for all key persons of the company.

Business plan and financial projections.

A detailed business plan must be submitted describing the operational model, target market, cash flow projections for three years and risk analysis.

AML/CFT compliance.

The company must have developed policies and procedures for anti-money laundering and combating the financing of terrorism, appoint a designated officer (MLRO) and pass the regulator’s review.

Safeguarding of client funds.

Payment institutions and EMIs are required to ensure segregation of client funds: either in a separate bank account at an EU credit institution or through insurance.

IT infrastructure.

A description of the software solutions used, information security policies, business continuity plans (BCP) and disaster recovery plans (DRP) is required.

Operational resources.

Banco de Portugal assesses the availability of sufficient technical, human and organisational resources for the proper conduct of licensed activities.

Cost of COREDO Services

COREDO provides a full range of legal services for obtaining a financial licence in Portugal. The cost includes: initial legal analysis of the structure, preparation of corporate and regulatory documents, development of the business plan and financial projections, drafting of internal policies (AML/KYC, compliance), support of interactions with Banco de Portugal and CMVM.

Service	Cost	Source
AEMI Licence (PSP/EMI) in Portugal	from EUR 60,000 + VAT	CP

The exact cost is determined individually based on the complexity of the structure, the composition of shareholders and the selected licence type. To receive a personalised commercial proposal, submit an enquiry via the form below.

Payment Terms

Payment for COREDO’s services is made in stages:

40%

advance payment upon signing the agreement and commencing work on the project;

40%

upon preparation of the complete document package and submission of the application to Banco de Portugal;

20%

upon receipt of the licence and completion of the project.

This payment structure enables the client to monitor progress at each stage and avoid paying for work before it has been completed.

List of Documents

The following set of documents is required for submitting a financial licence application in Portugal:

Incorporation documents — articles of association, certificate of registration (Certidão Comercial);

Business plan — description of the business model, target market, competitive analysis, revenue and expense projections for 3 years;

Financial projections — balance sheet, profit and loss statement, cash flow forecast;

Shareholder documents — passports, proof of residence, fit & proper questionnaires;

Director documents — CVs, education diplomas, criminal record certificates, fit & proper questionnaires;

AML/CFT policies — AML programme, KYC/CDD procedures, counter-terrorist financing policy;

IT documentation — software description, security certificates, data protection policy (GDPR);

Product and service descriptions — detailed description of payment products, tariffs, target audience;

Corporate structure chart — organisational chart indicating all ultimate beneficial owners (UBO);

Source of funds documentation — bank statements confirming the lawful origin of share capital;

Key supplier agreements — processing partners, IT solution providers, correspondent banks;

Client fund safeguarding policy — description of the segregation mechanism (safeguarding);

Insurance policy (if this method of client fund protection is chosen);

Prior notification consent — notification form to Banco de Portugal regarding the intention to establish a payment institution.

Licence Acquisition Procedure

The licensing process in Portugal comprises several clearly defined stages:

Preliminary Assessment and Consultation (1–2 months)

Analysis of the business model, corporate structure and compliance with Banco de Portugal requirements. Determination of the optimal licence type. If necessary — participation in dialogue with the regulator within the Portugal FinLab framework to obtain preliminary clarifications.

01

Company Registration (2–4 weeks)

Registration of the legal entity in Portugal (if necessary), opening of a corporate bank account, depositing of share capital. The company must have a registered office in Portugal.

02

Document Preparation (2–3 months)

Development of the complete document package: business plan, financial projections, internal policies (AML/KYC, compliance, IT security), collection of personal documents of directors and shareholders for fit & proper assessment.

03

Notification and Application Filing (2–4 weeks)

Submission of a prior notification to Banco de Portugal regarding the intention to establish a payment institution or EMI. Following the regulator’s assessment of the project — submission of the complete document package for authorisation.

04

Application Review (3–12 months)

Banco de Portugal reviews the application within three months of receiving the complete set of documents, but no later than 12 months from the date of initial filing. During the review, the regulator may request additional information and clarifications.

05

Total: the estimated timeline from the start of work on the project to obtaining the licence is 6–14 months, depending on the complexity of the structure and the speed of fit & proper verification.

Our Experts

Financial licensing projects in Portugal are led by experienced COREDO specialists:

Pavel Kos

Head of Legal at COREDO. Joined the company in June 2017 and has been heading the legal team since July 2020. Specialises in financial licensing, corporate law and regulatory support for projects across the EU.

Basang Ungunov

Lawyer at COREDO. Has been with the company since June 2022. Specialises in financial and corporate law, legal opinions and regulatory matters.

Frequently Asked Questions

Which regulator issues financial licences in Portugal?

Banco de Portugal issues licences for payment institutions (PI) and electronic money institutions (EMI). CMVM licenses investment firms and brokers operating in the securities sector under MiFID II.

Can a Portuguese licence be used to operate across Europe?

Yes. A Portuguese EMI or PI licence allows the provision of services across all 30 EEA states through the passporting mechanism provided for by PSD2 (for PI) and EMD2 (for EMI). It is sufficient to submit a notification to Banco de Portugal — and the regulator itself informs the supervisory authority of the host country.

What is the minimum share capital for an EMI licence in Portugal?

EMD2 Directive establishes a single minimum for the entire EU: EUR 350,000. For payment institutions, the minimum capital ranges from EUR 20,000 to EUR 125,000 depending on the type of payment services provided.

How long does it take to obtain a licence?

Banco de Portugal is required to make a decision within three months of receiving the complete set of documents, but no later than 12 months from the date of the initial application. In practice, taking into account the preparatory stage and company registration, the total timeline is 6–14 months.

Is physical presence in Portugal mandatory?

Yes. Banco de Portugal requires a genuine head office in Portuguese territory. The company must have local operational resources: staff, premises and infrastructure. Nominal presence is not accepted by the regulator.

What is Portugal FinLab and how does it assist with licensing?

Portugal FinLab is a joint initiative of Banco de Portugal and CMVM that provides fintech companies with the opportunity for informal dialogue with regulators at the product design stage. Participation in FinLab allows companies to clarify the regulatory status of innovative business models before submitting a formal application, thereby reducing the risk of refusal.

Can a foreign company obtain a licence in Portugal?

Yes. Foreign shareholders may hold 100% of the Portuguese company. However, the legal entity — the licence applicant — must be incorporated in Portugal and have a genuine presence in the country. Directors undergo a fit & proper assessment regardless of nationality.

What is the cost of COREDO's services for obtaining a licence in Portugal?

The cost of AEMI licence (EMI/PSP) support in Portugal starts from EUR 60,000 + VAT. The final price depends on the complexity of the corporate structure, the composition of shareholders and the scope of services required. Submit an enquiry to receive a personalised commercial proposal.

Get a Consultation

If you are considering Portugal as a jurisdiction for obtaining a financial licence, COREDO is ready to assess your structure, select the optimal licence type and take on the entire process — from document preparation to obtaining Banco de Portugal authorisation.