Portugal
Legal update – 4th Quarter 2025
In the fourth 2025 edition of the Banking, Finance and Capital Markets Newsletter, we highlight the following updates:
- Regulation of the Regime on the Assignment and Servicing of Bank Loans (“RCGCB”): Bank of Portugal Notice 6/2025 of December 3 regulates the RCGCB following the approval of Decree-Law 103/2025 of September 11, which transposes Directive (EU) 2021/2167 and establishes requirements for loan servicers and purchasers. The RCGCB entered into force on December 10, 2025.
- Implementation of the MiCA Regulation in Portugal: Law 69/2025 of December 22 (i) implements the MiCA Regulation in Portugal; and (ii) establishes the competent authorities, the penalties regime, and the transitional framework for cryptoasset issuers and service providers. The law entered into force on December 27, 2025, and provides clarity on the continuity of activities until July 1, 2026, or until a decision on authorization requests is made.
Finally, we highlight the following developments:
- Ongoing negotiations regarding the European Commission’s package to fully integrate the EU’s financial markets. Proposed amendments include changes to the EMIR, MiFIR and MiCA, as well as to other sectoral directives. These amendments are intended to eliminate barriers to integration, enhance supervision and simplify charging.
- A proposed review of the SFDR, which is currently under appraisal by the European Parliament and the Council. This review aims to streamline and improve the effectiveness of sustainable finance disclosures.