Portugal crypto license 2026 — Banco de Portugal CASP authorisation
Portugal implemented MiCA late, with Lei 69/2025 of 22 December 2025. Banco de Portugal authorises CASPs and supervises their prudential requirements and governance; the CMVM gives a reasoned opinion on each application and supervises conduct. The transitional period ended on 1 July 2026.
Last reviewed by the Crypto Law Index editorial desk
Banco de Portugal grants the licence; the CMVM gives an opinion
Portugal implemented MiCA a year after the regime started to apply. Lei n.º 69/2025, published on 22 December 2025, splits the work between two authorities. Banco de Portugal authorises crypto-asset service providers and supervises their prudential requirements and governance, as it does for issuers of asset-referenced and e-money tokens. The CMVM issues a reasoned opinion on each application, identifying anything that would stand in the way of a favourable decision, and then supervises the conduct duties that apply to every CASP, along with custody and certain specific services.
The opinion has deadlines. The CMVM has 10 days when the question is whether an application is complete, and 15 days to give its view on granting or refusing once Banco de Portugal has confirmed completeness. If it says nothing within those periods, it is treated as having no objection.
Earlier versions of this page said the CMVM authorises Portuguese CASPs under a Law 27/2024. That described a design that was never enacted. If you are reading guidance that sends a Portuguese application to the CMVM, it was written before Lei 69/2025.
The transitional period, and where that leaves the old register
Before MiCA, Portugal had a crypto-asset register at Banco de Portugal under its AML law, Lei 83/2017. Article 30 of Lei 69/2025 let firms on that register on 30 December 2024 keep operating until 1 July 2026, or until their MiCA application was decided if that came first. ESMA lists Portugal at 18 months, the full period MiCA allows. It has now ended: a former registrant without MiCA authorisation has no basis to provide crypto-asset services in Portugal.
The register was never a licence. A firm moving across had to produce the same governance, ICT, prudential, AML and consumer-protection file as a new applicant.
Planning a Portuguese file without a track record
MiCA fixes the outer periods. Article 63 gives the authority 25 working days to assess whether an application is complete and 40 working days to decide on a complete one; one information request can pause the clock for up to 20 working days. What Portugal lacks is evidence of how those periods play out in practice: Banco de Portugal has held the authorising role only since December 2025, and the two-authority procedure adds a step that single-supervisor jurisdictions do not have.
The MiCA capital floors are the same here as anywhere in the EU — €50,000 to €150,000 by class, or a quarter of fixed overheads if higher. We could not verify a standing fee tariff or Portugal-specific substance guidance under the new law, so treat any precise Portuguese fee or timeline quoted to you as an adviser's estimate until the authority confirms it.
Portugal's CASP authorisation is the licence granted by Banco de Portugal under MiCA Regulation (EU) 2023/1114 (Articles 59 and 63), as implemented by Lei n.º 69/2025 of 22 December 2025, after the CMVM has given a reasoned opinion on the application.
Fast facts
| Parameter | Value |
|---|---|
| Authorising authority | Banco de Portugal — CASP authorisation, prudential requirements and governance |
| Conduct supervisor | CMVM — reasoned opinion on each application; supervises conduct duties, custody and specific services |
| Legal basis | MiCA Regulation (EU) 2023/1114 + Lei n.º 69/2025 (Diário da República, 22 December 2025) |
| CMVM opinion deadlines | 10 days on completeness, 15 days on grant or refusal after Banco de Portugal confirms completeness; silence counts as no objection |
| Initial capital | €50,000 / €125,000 / €150,000 by Class 1 / 2 / 3 service set, MiCA Annex IV |
| VASP-to-CASP transition | Firms registered with Banco de Portugal on 30 December 2024, with activity started and notified, could continue until 1 July 2026 (Lei 69/2025). The period is over |
| AML supervisor | Banco de Portugal, under Lei n.º 83/2017 |
Top counsel for Portugal CASP work
Firms below are ranked according to the published CLPAI methodology. Featured selections cover firms with documented Portugal engagement, regardless of where they are headquartered.
Frequently asked questions about Portugal CASP authorisation
Who authorises CASPs in Portugal under MiCA?
Banco de Portugal. Lei 69/2025 makes it responsible for authorising crypto-asset service providers and supervising their prudential requirements and governance. The CMVM gives a reasoned opinion on each application and supervises conduct.
Is the CMVM the competent authority for Portuguese CASPs?
Not for authorisation. Under Lei 69/2025 the CMVM issues a reasoned opinion during the procedure and supervises conduct duties, custody and specific services, while Banco de Portugal grants or refuses the licence.
Can firms on the old Banco de Portugal register still operate?
No longer. Firms registered on 30 December 2024 with activity started and notified could continue until 1 July 2026 or until their application was decided, whichever came first. That transitional period has ended.
What is the minimum capital for a Portuguese CASP?
The MiCA Annex IV floors apply: €50,000 for Class 1, €125,000 for Class 2 and €150,000 for Class 3, or a quarter of fixed overheads if higher.
Pitfalls and nuances in Portugal
1 Working from guidance that names the CMVM as the licensing authority
Before Lei 69/2025 several guides, including earlier versions of this page, said the CMVM would authorise CASPs under a 'Law 27/2024'. The enacted law gives authorisation to Banco de Portugal and an opinion and conduct role to the CMVM. File with the right authority and check the date on anything you read.
2 Confusing the AML register with authorisation
The pre-MiCA Banco de Portugal register was an AML registration under Lei 83/2017. It never authorised regulated crypto-asset services, and the transitional period that let registered firms keep operating ended on 1 July 2026.
3 Budgeting a timeline from other jurisdictions
Banco de Portugal has authorised CASPs under MiCA only since December 2025, so there is little caseload to plan from. MiCA's statutory periods apply, but a two-authority procedure with a CMVM opinion adds coordination that a single-supervisor jurisdiction does not have.
Practitioners in Portugal
Named lawyers from the Crypto Law Index practitioners directory whose jurisdictional coverage includes Portugal. Editorial picks, sourced from public records.
Regulator and primary sources
The supervisor of CASP authorisations in Portugal is Banco de Portugal (authorisation and prudential supervision), with the Comissão do Mercado de Valores Mobiliários (CMVM) for conduct. The legal basis is MiCA Regulation (EU) 2023/1114, implemented in Portugal by Lei n.º 69/2025 of 22 December 2025. Visit www.bportugal.pt for the regulator's official guidance, application forms, and supervisory expectations.
For where every EU and EEA state stands — its authority, its national act and when its transitional period ended — see the MiCA implementation tracker.