Fintech licenses in Portugal: EMI, payment institution and MiCA

Whether your project is a payments fintech, an issuer of wallets or prepaid cards or a crypto-asset exchange / platform, Portugal offers an entry point to the EU single market under the same directives and regulations as the rest of the EU (PSD2 today, PSD3/PSR tomorrow, and MiCA for crypto-assets). These are the reasons many projects choose it:

• EU passport: an EMI or PI license or a CASP authorization obtained in Portugal lets you operate in all 27 Member States through the free provision of services or a branch, without new authorizations.
• Harmonized regulatory framework: the Portuguese regime transposes the same EU rules, so your application is fully recognizable and reusable in other EU markets.
• A benchmark supervisor: Banco de Portugal (and the CMVM for crypto-asset conduct) are solid authorities with clear criteria.
• A growing fintech ecosystem and cultural and linguistic closeness to Spain and Latin America.
• The same firm on both sides of the border: we coordinate your project in Spain and Portugal with an integrated Iberian and European approach.

Choosing between Portugal, Spain or another Member State is not trivial: it depends on your business model, your investors, your operations and your timeline. We help you make that decision on sound criteria and carry it out from start to finish.

The Instituição de Moeda Eletrónica (IME) is the Portuguese equivalent of the EMI license: it allows you to issue electronic money (e-purses, prepaid cards, stored balances) as well as provide payment services. It is governed by the Legal Framework for Payment Services and Electronic Money (Regime Jurídico dos Serviços de Pagamento e da Moeda Eletrónica, RJSPME), approved by Decree-Law No. 91/2018, which transposes PSD2.

• Regulator: Banco de Portugal, which grants authorization case by case and carries out prudential and conduct supervision.
• Minimum initial capital: €350,000, in line with the harmonized EU electronic money regime.
• Safeguarding of funds: you must segregate client funds and maintain internal control and anti-money laundering (AML/CFT) mechanisms.
• Timeline: Banco de Portugal has a reference period of 3 months from receipt of the complete application to reach a decision.
• EU passport: once authorized, the IME can operate throughout the EU by notifying the host supervisor.

If your volume is still low, consider a simplified regime as a lower-cost entry point before the full license: we explain it in our guide to the simplified electronic money institution.

The Instituição de Pagamento (IP) is the equivalent of the Spanish payment institution license: it provides payment services on a professional basis without issuing electronic money. It is also governed by the RJSPME (Decree-Law No. 91/2018) and supervised by Banco de Portugal.

• Services covered: transfers, direct debits, card payments, money remittance, payment initiation (PISP) and account information (AISP).
• Minimum initial capital (PSD2 regime): €20,000 for money remittance; €50,000 for payment initiation (PISP); €125,000 for all other payment services.
• PISP/AISP: payment initiation services also require professional indemnity insurance or an equivalent guarantee.
• Safeguarding and AML/CFT: segregation of client funds, internal control and anti-money laundering, just like the IME.
• Timeline and registration: a reference decision period of 3 months and entry in the public register of Banco de Portugal.

Access to payment services (open banking) and the upcoming PSD3/PSR directly affect these entities; if your model is PISP or AISP, see also our page on PISP, AISP and open banking.

The MiCA Regulation governs crypto-asset service providers (CASPs) across the EU. Portugal passed its implementing law (Law No. 69/2025) at the end of 2025, which designates the competent authorities and sets out the procedure. For details on the EU regulation, see our page on MiCA and crypto-assets.

Portugal has adopted a “twin peaks” supervisory model, with powers split between two regulators:

• Banco de Portugal — prudential supervision. It authorizes and revokes CASPs (in coordination with the CMVM), supervises prudential and governance requirements, asset-referenced tokens (ARTs) and e-money tokens (EMTs/stablecoins), and retains AML/CFT powers. The CASP authorization application is filed with Banco de Portugal.
• CMVM (Comissão do Mercado de Valores Mobiliários) — conduct supervision. It is responsible for public offers of crypto-assets other than ARTs and EMTs, market abuse and the conduct obligations of CASPs toward their clients.

• CASP services: custody and administration, operation of trading platforms, exchange of crypto-assets for funds or other crypto-assets, execution of orders, placing, reception and transmission of orders, advice and portfolio management.
• Minimum capital (MiCA Annex IV): €50,000, €125,000 or €150,000, depending on the class of services you want to provide.
• EU passport: CASPs authorized in Portugal can provide services throughout the EU through the free provision of services or a branch.
• Transitional period: previously registered VASPs must plan their migration to CASP authorization within the applicable transitional deadlines.

If your project combines payments and crypto (for example, a wallet with a euro balance and the buying and selling of crypto-assets), you should analyze the electronic money and CASP categories together. We cover this in crypto-assets and blockchain.