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 and a growing Lisbon tech scene. If personal tax is part of the decision, note that the NHR regime closed to new residents from 2024. Its successor, IFICI, is narrower and covers people who move to work in research, innovation and certain qualified jobs. Portugal also hosts one of the oldest European crypto retail markets.

Capital, scope and process

• PI capital. EUR 20k / 50k / 125k per PSD2 Article 7.
• EMI capital. EUR 350k per EMD2.
• Small payment institution regime. Article 37 of the RJSPME (Decreto-Lei 91/2018) and Portaria 239/2019 offer a lighter authorisation to PIs with head office in Portugal whose payment volume averages no more than EUR 3 million a month, with EUR 50,000 share capital. It covers account, transfer, card and acquiring services only, so money remittance, payment initiation and account information fall outside it. There is no equivalent for EMIs, firms using it cannot passport, and full authorisation must be requested within 30 days of exceeding the limits.

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. Application filed with the Banco de Portugal under Article 19 of the RJSPME.
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. Head office and effective management must be in Portugal, and part of the main business must be carried out there (Article 18 of the RJSPME).

MiCA and PSD3 context

Portugal implemented MiCA through Law 69/2025, published on 22 December 2025 and in force since 27 December 2025. Crypto firms registered with the Banco de Portugal before 30 December 2024 could keep operating until 1 July 2026, or until a decision on their MiCA application if that came first. CMVM and Banco de Portugal share supervisory roles under MiCA depending on service type.

For payments, Portuguese PIs and EMIs are expected to move to the PSD3 and PSR regime around 2028. The IBAN-name check (Verification of Payee) has applied to all euro credit transfers, standard and instant, since 9 October 2025. PIs and EMIs must be able to receive SEPA Instant payments from 9 January 2027 and send them from 9 April 2027.

Ship a Portuguese PI or EMI product with Crassula

Crassula provides the core-banking platform: ledger, IBANs, cards through pre-integrated issuers, SEPA and SEPA Instant, KYC onboarding through connected providers and client limits. Balance and transaction reports give your finance and compliance teams the data for safeguarding checks and Banco de Portugal reporting, and we help write the IT, security, outsourcing and DORA sections of your application.

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