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Portugal EMI and PI License in 2026: Banco de Portugal Guide

A 2026 deep dive into the Portuguese EMI and PI licence: Banco de Portugal authorisation, capital EUR 20k-EUR 350k, 3-month statutory clock, Portuguese-resident director, CMVM for crypto and PSD3 path.

Portugal EMI and PI License in 2026: Banco de Portugal Guide
Portugal EMI and PI License in 2026: Banco de Portugal Guide
Portugal EMI and PI License in 2026: Banco de Portugal Guide

Portugal's payments and e-money regime

The Banco de Portugal is the Portuguese central bank and the supervisor for credit institutions, PIs and EMIs. The CMVM (Comissão do Mercado de Valores Mobiliários) covers securities markets; CMVM and Banco de Portugal share responsibility for MiCA CASP.

Portugal is the smaller Iberian sibling of Spain but offers a distinct proposition: lower operating costs, English-friendly administration in most Banco de Portugal desks, and the Golden Visa / NHR tax regimes that have pulled founders into Lisbon. Portugal also hosts one of the oldest European crypto retail markets.

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Capital, scope and process

  • PI capital. EUR 20k / 50k / 125k per PSD2 Article 7.
  • EMI capital. EUR 350k per EMD2.
  • Small PI / Small EMI. Available as a domestic track under Article 32 PSD2.
  1. Incorporation. Portuguese SA or Lda, registered office in Portugal, paid-up capital in a Portuguese credit institution.
  2. File preparation. Business plan, programme of operations, governance, AML/CFT (Law 83/2017), safeguarding plan, ICT/DORA framework, outsourcing register, fit-and-proper files.
  3. Submission. Via the Banco de Portugal authorisation portal. Primarily Portuguese-language with English annexes accepted.
  4. Statutory clock. 3 months from complete file for PI and EMI.
  5. Real timeline. 6 to 10 months end-to-end for a PI, 9 to 14 for an EMI.
  6. Substance. At least two directors; at least one Portuguese-resident. Physical office and local staffing expected.

MiCA and PSD3 context

Portugal adopted Law 69/2025 in January 2026 to transpose MiCA. The transitional window for pre-MiCA Portuguese crypto operators runs to 1 July 2026. CMVM and Banco de Portugal share supervisory roles under MiCA depending on service type.

For payments, Portuguese PIs and EMIs migrate to the unified PSD3 regime in 2027. IBAN-name check already mandatory for SEPA Instant since 9 October 2025.


Ship a Portuguese PI or EMI product with Crassula

Crassula provides the core-banking platform aligned with Banco de Portugal expectations: ledger, IBANs, cards, SEPA rails, KYC and AML (Law 83/2017), safeguarding, DORA ICT and regulator-ready reporting.


FAQ

Banco de Portugal for authorisation and prudential supervision. CMVM covers securities markets and shares MiCA CASP responsibilities.

Statutory 3 months from complete file. Real-world 6 to 10 months for a PI, 9 to 14 for an EMI.

Primarily yes; English annexes are accepted for technical content. Customer-facing documents for Portuguese consumers must be in Portuguese.

Portugal transposed MiCA via Law 69/2025 in January 2026. Transitional window for pre-MiCA firms ends 1 July 2026. CMVM and Banco de Portugal share supervisory roles.

Crassula provides the core-banking platform aligned with Banco de Portugal expectations: ledger, IBANs, cards, SEPA rails, KYC/AML, safeguarding, DORA ICT and regulator-ready reporting.

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