This Practical Guide on Cryptoassets in Portugal provides a clear and accessible overview of the new regulatory framework for cryptoassets in the European Union and, more specifically, in Portugal.
Following the entry into force of Regulation (EU) 2022/858 on a pilot regime for market infrastructures based on distributed ledger technology, implemented in Portugal through amendments to the Securities Code (“CVM”) introduced by Decree-Law 66/2023 of August 8, and, more recently, Regulation (EU) 2023/1114 on markets in crypto-assets (“MiCA”) and its national implementing legislation (Law 69/2025 of December 22), Portugal now has a structured regulatory framework governing the issuance, provision of services and supervision of cryptoassets and tokenized financial instruments. See our Legal Flash, Law Implementing the MiCA Regulation in Portugal.
This guide is intended for financial institutions, cryptoasset service providers (“CASPs”), issuers, institutional investors and other market participants seeking to understand the regulatory obligations, authorization and notification procedures, and tax and reporting requirements arising from this new regulatory landscape.
From a holistic and multidisciplinary perspective, the guide also addresses criminal and administrative matters, including the penalty regime applicable to breaches of the MiCA Implementing Law—fines, ancillary penalties and preventive measures such as the seizure of cryptoassets—as well as the interaction between cryptoasset-related conduct and offenses already established under Portuguese criminal law, particularly fraud and money laundering.
It also discusses key considerations for employers wishing to pay employees in cryptoassets, including the legal requirements for paying salaries and bonuses in this form.
Index:
PART I — General overview: Glossary and target audience
CHAPTER 1 — Introduction and purpose of the guide
CHAPTER 2 — Glossary
CHAPTER 3 — Target audience
PART II — FAQs by segment
MODULE A — Cryptoasset service providers
MODULE B — Credit institutions: Notification for cryptoasset services and issuance of EMTs
MODULE C — Tokenization of financial instruments 1
MODULE D — Taxation and accounting: CIT, PIT, and DAC 8 radar
MODULE E — Administrative offenses and criminal offenses
MODULE F — Labor