Crypto licence in PortugalOverview
Before MiCA, crypto businesses in Portugal registered with the Banco de Portugal for AML purposes under Law 83/2017. Law 69/2025, approved by Parliament on 5 December 2025 and in force from 23 December 2025, designates the national competent authorities for MiCA and adapts the Securities Code. A companion statute, Law 70/2025, brings the EU Transfer of Funds Regulation and its crypto Travel Rule into the Portuguese AML framework.
The Portuguese model divides supervision by subject matter. The Banco de Portugal authorises CASPs and is responsible for prudential and governance requirements, outsourcing, orderly wind-down, acquisitions of qualifying holdings and significant CASPs, as well as asset-referenced and e-money tokens. The CMVM supervises conduct of business, safeguarding of client assets and funds, market abuse, white papers for other crypto-assets, and specific services such as custody, trading platforms, exchange, order handling and advice.
Applications are filed with the Banco de Portugal, which forwards them to the CMVM. The CMVM has 10 days to comment on completeness and 15 days after the Banco de Portugal's confirmation to give its opinion on whether authorisation should be granted. These steps sit within MiCA's overall 25 plus 40 working-day framework.
Entities registered with the Banco de Portugal that had started activity could continue until 1 July 2026 or until a MiCA decision, whichever came first. Changes to corporate purpose, activities or shareholding during the transition caused the registration to lapse. With the transition closed, Portugal is now a straightforward MiCA jurisdiction with two experienced regulators.
Key benefits
- Authorisation by the central bank, valued by banking partners
- Single EU licence passportable to all Member States
- Clear statutory allocation of competences between Banco de Portugal and CMVM
- Portuguese-speaking gateway to Brazil and Lusophone markets
- Competitive operating costs and a growing technology talent base
- Combinable with Portuguese residence planning for founders
Requirements
- Portuguese legal person with place of effective management in the EU and at least one EU-resident director
- Minimum capital or prudential safeguards per MiCA Article 67
- Fit-and-proper management body and qualifying shareholders
- Programme of operations, business plan and governance framework
- Client-asset and client-fund safeguarding arrangements meeting CMVM expectations
- AML/CFT framework under Law 83/2017, including the Travel Rule as amended by Law 70/2025
- ICT and operational resilience consistent with DORA
- Outsourcing policy and orderly wind-down plan
- Complaints handling and conflicts-of-interest policies
Licence options & capital
Class 1 CASP
EUR 50,000 minimum capital
Reception and transmission of orders, execution of orders on behalf of clients, placing of crypto-assets, transfer services, advice and portfolio management. Suitable for brokerage, advisory and transfer services without custody.
Class 2 CASP
EUR 125,000 minimum capital
Any Class 1 service plus custody and administration of crypto-assets for clients and exchange of crypto-assets for funds or for other crypto-assets.
Class 3 CASP
EUR 150,000 minimum capital
Any Class 2 service plus operation of a trading platform for crypto-assets. Prudential safeguards must equal the higher of the fixed amount or one quarter of the previous year's fixed overheads.
Step-by-step process
- 1
Pre-assessment
Define services, target markets and the regulatory perimeter, and confirm which elements fall under the Banco de Portugal and which under the CMVM.
- 2
Entity and governance
Incorporate or adapt the Portuguese company, appoint directors and key function holders, and establish local premises.
- 3
Application file
Prepare the MiCA application, policies and business plan in Portuguese, reflecting both regulators' areas of focus.
- 4
Filing with Banco de Portugal
Submit the application; the Banco de Portugal shares it with the CMVM, which comments on completeness within 10 days.
- 5
Assessment and CMVM opinion
Following completeness, the CMVM issues its opinion within 15 days and the Banco de Portugal completes its assessment within MiCA deadlines.
- 6
Authorisation and passporting
Launch services, begin reporting to both authorities and notify other Member States where services will be offered.
Typical documents
- Articles of association and commercial registry certificate
- Programme of operations and three-year business plan
- Evidence of capital or prudential safeguards
- Fit-and-proper questionnaires, CVs and criminal records for directors
- Qualifying shareholder information and source-of-funds evidence
- AML/CFT policies and risk assessment
- Custody, safeguarding and client-fund policies
- ICT security, outsourcing and business continuity documentation
- Wind-down plan and complaints procedure
How Legal Wealth helps
Legal Wealth structures Portuguese CASP projects around the dual-regulator model, preparing an application that speaks to the Banco de Portugal's prudential focus and the CMVM's conduct agenda. We coordinate corporate set-up, governance and AML, and where founders are also considering Portuguese residence, we align the licensing timetable with their personal and family planning, with discretion throughout.
Enquire with Legal WealthFrequently asked questions
Who grants the crypto licence in Portugal?
The Banco de Portugal grants CASP authorisation after receiving the CMVM's opinion. The CMVM then supervises conduct of business and client-asset safeguarding alongside the Banco de Portugal's prudential supervision.
Can a Banco de Portugal-registered VASP still operate?
No. Registered firms could continue only until 1 July 2026 or until a MiCA decision. Since then, MiCA authorisation is required.
What law implements MiCA in Portugal?
Law 69/2025, published on 22 December 2025, implements MiCA, while Law 70/2025 implements the Transfer of Funds Regulation.
Must the application be in Portuguese?
Supervisory correspondence is conducted in Portuguese, so the core application and policies should be prepared in Portuguese.
How much capital is needed?
MiCA sets EUR 50,000, EUR 125,000 or EUR 150,000 depending on the services, or one quarter of the previous year's fixed overheads if higher.
Last reviewed: 2026-10. Requirements, fees and timelines change. Information is general, reviewed on the date shown, and is not legal or tax advice.
