--- title: "Portugal Crypto Regulation Monitor | cryptoassets.gi" canonical: https://cryptoassets.gi/jurisdictions/portugal/ source_html: /jurisdictions/portugal/index.html description: "Portugal crypto asset regulation: 8 categories, 38 sourced findings, updated 2026-10-25. Licensing, token classification, stablecoins, tax treatment." generated_at: 2026-11-07T14:19:44Z content_sha256: 0fdd58d66a1c65cfc065a87e1708bc2f4705202359c0ed33a499ab1b895579d7 generator: "fe-fleet/md-twin@1.0" --- # Portugal Crypto & Digital Asset Regulation schema crypto-v2.0.0 trajectory: not yet assessed regulated overlaps: [Sentinel (AML/CFT)](https://sentinel.gi/jurisdictions/portugal/), [World Payments](https://payments.gi/jurisdictions/portugal/) Last updated 2026-10-25 · 8 categories · 38 sourced findings · 39 sources in the cumulative register Download report (PDF) Expand all Evidence re-verified: 2026-10-25 · Position last changed: 2026-10-25 · Record history & provenance ▾ Methodology & record provenance: Module confidence is derived from the underlying claims (source tier and primary excerpt retention), while statutory legal force is tracked independently. Review status: AI-synthesised · Tier-1/2 verified · As-of date: 2026-10-26 [Open in Co-Pilot ↗](/reports/?type=copilot&j=PORTUGAL)[Build Report](/reports/?j=PORTUGAL)[Compare](/compare/?j=PORTUGAL) Framework posture Regulated 8 of 9 modules populated · AI-synthesised · Tier-1/2 verified Lead supervisory authority Crypto-asset service providers (CASPs) operating in Portugal Primary statutory & supervisory perimeter Next milestone (> 2026-10-26) 2026-Q4 Further PT full CASP authorisations expected beyond Bison Bank Module coverage & confidence 8 / 9 modules assessed 0 Confirmed · 8 Probable · 0 Uncertain · 1 Not yet assessed 8 Categories 0 Moved this cycle 0 Key judgments 4 Open gaps 38 Findings 11 Tier-1 sources Confidence mix 8 unpopulated (sums to 8 rendered categories; click to filter) No categories moved this cycle. Law made at European Economic Area (Bloc) level that applies in Portugal is covered once, on the [European Economic Area (Bloc)](/jurisdictions/european-economic-area-bloc/) page. This page covers Portugal’s own layer: implementation, national authorities, national options and local enforcement. ## Jurisdiction lead brief ###### Latest update · 25 October 2026 #### Lead Signal Portugal's crypto-asset licensing regime reached a structural turning point with the close of its Markets in Crypto-Assets transitional window. Under article 6 of Lei n.º 69/2025, entities that had registered with Banco de Portugal before 30 December 2024 and had commenced duly-notified virtual-asset activity were permitted to keep operating until 1 July 2026 or final authorisation, whichever came first. That date has now passed. The practical test of how the regime is handling the firms that relied on that carve-out is the authorisation count on the European Securities and Markets Authority's interim crypto-asset service provider register, which as of a file dated 7 October 2026 shows only one Portugal-supervised entity holding full authorisation. Operating as a crypto-asset service provider in Portugal without authorisation after the end of the transitional period is treated as a very serious administrative offence (contraordenação muito grave) under the domestic implementing framework, though the precise fine schedule for that offence category has not been independently located. The combination of a hard compliance deadline that has already passed and a thin authorisation count creates a live supervisory-throughput question for any firm with Portuguese crypto-asset exposure. #### Other Developments No additional crypto licensing development beyond the transitional-deadline and authorisation-count findings above has been identified for Portugal. #### Cross-Monitor Connections The authorisation-pipeline bottleneck described here is a shared structural fact with payments-system oversight of Portuguese digital-asset service providers, where the same ESMA register and the same transitional-deadline date are the operative evidence. It also carries a financial-integrity dimension: a jurisdiction with a clear licensing requirement but an unclear pace of granting authorisations is a jurisdiction where the population of firms operating between the end of transitional cover and the grant of full authorisation deserves monitoring, independent of any confirmed enforcement action. No enforcement action, sanction, or illicit-finance nexus against any Portugal-supervised crypto entity has been identified. #### Outlook The figure to watch is whether the Portugal-supervised authorisation count moves meaningfully beyond one in subsequent register updates, or whether it remains flat while applications stay pending. A sustained flat count would support reading this as a durable capacity constraint at Banco de Portugal and the Comissão do Mercado de Valores Mobiliários rather than a timing artefact of the October snapshot. The exact contraordenação fine schedule for unauthorised post-deadline activity, and the own-funds figures applied through the Portuguese authorisation process under MiCA article 67 and Annex IV, remain gaps to close in a future cycle. 3 earlier updates not shown here. ###### Standing brief · as of 4 August 2026 Written before the update above. Where they differ, the update is the more recent position. #### Lead Signal Portugal's MiCA implementation reached full operational status this cycle, but the compliance picture it reveals is uneven. The Article 143(3) transitional (grandfathering) window that had allowed pre-existing Portuguese crypto-asset service providers to continue operating pending authorisation formally closed on 1 July 2026, confirmed by ESMA's public statement of 23 June 2026. Any legacy provider that has not by now secured MiCA authorisation from CMVM is required to have wound down crypto-asset services in Portugal. Set against that closure, ESMA's interim MiCA register showed zero authorised CASPs in Portugal as of mid-2026 — versus 57 in Germany and 26 each in France and the Netherlands. That authorisation-count finding rests on a single T4 news source corroborated by two further T4 outlets rather than a directly cited primary register extract, so it is held at Probable rather than Confirmed confidence under the crypto guardrail's Confidence Floor rule. Together, the two findings describe a jurisdiction where the legal architecture is fully built — CMVM and Banco de Portugal hold a clear, EU-confirmed supervisory split, reinforced domestically by Lei n.º 69/2025's grant of Article 94 sanctioning powers — but where authorisation throughput has not yet caught up with the closed transitional deadline. What is not established from current sourcing is whether any unauthorised legacy entity has in fact continued operating past 1 July 2026, or what enforcement posture the two supervisors have taken; that remains an open question for the next research pass. #### Other Developments Beneath the licensing headline, Portugal's token-classification, stablecoin, and consumer-protection frameworks are comparatively settled. MiCA's ART/EMT/other-token taxonomy applies directly with limited national discretion, security tokens and most NFTs sit outside MiCA's authorisation perimeter, and ART/EMT issuers face a full reserve-adequacy and redemption-right regime supervised by Banco de Portugal. Consumer-facing obligations — white-paper liability, a statutory withdrawal right for retail purchasers buying direct from issuers, and custody-segregation duties for CASPs — are binding EU law enforced by CMVM. Tax treatment is the one area where the evidentiary base itself, not the regime, is thin. Portugal's reported 28% capital-gains rate on crypto held under 365 days, with exemption thereafter, rests on T4 secondary sourcing rather than a verified primary Código do IRS citation, prompting a confidence downgrade to Uncertain on both figures this cycle. A separate 2019-vintage ruling exempting crypto trading and crypto-denominated pay from VAT has not been reaffirmed post-MiCA and is similarly held at Uncertain confidence. Against that thinner ground, one tax obligation is now firmly in force: from 1 January 2026, EU crypto-asset service providers operating in Portugal must report client transaction data under the DAC8 directive for cross-border tax-information exchange, sourced directly to the EUR-Lex directive text. Cross-border transfer rules are similarly EU-derived and stable: the travel rule under Regulation (EU) 2023/1113 requires verified originator/beneficiary information on transfers, with enhanced verification triggered above EUR 1,000 from self-hosted wallets, and Russia-nexus crypto-asset securities remain restricted under the EU sanctions regulation. No Portugal-specific outbound retail restriction beyond these EU-wide requirements was identified, though this is recorded as a negative finding reflecting this pass's research limits rather than a confirmed clearance. #### Cross-Monitor Connections Two overlap flags carry forward from this cycle. AML/CFT obligations for Portuguese CASPs — travel-rule compliance, KYC/CDD, and sanctions screening — are consolidated under the financial-integrity monitor per fleet architecture; this cycle performed no original illicit-finance analysis and instead carries a structural placeholder referencing that subscription, with detailed evidentiary work maintained on the financial-integrity side. Separately, the stablecoin issuance/reserve regime and the new DAC8 cross-border tax-reporting obligation both carry payments-adjacent and tax-information-exchange dimensions relevant to the world-payments monitor's framing, given ART/EMT redemption mechanics and cross-border reporting flows intersect with payments-system considerations tracked there. #### Outlook The near-term marker to watch is enforcement follow-through on the closed Article 143(3) window: whether CMVM and Banco de Portugal take visible action against any legacy entity still operating without authorisation, and whether Portugal's authorisation count moves off zero. A second open item is evidentiary rather than regulatory — closing the sourcing gap on Portugal's capital-gains and VAT tax treatment with primary Código do IRS and Autoridade Tributária citations, and resolving whether Portugal's staking, DeFi-lending, mining, and node-operation activities fall within or outside the CASP licensing perimeter, none of which has been researched this cycle. The composed record for this jurisdiction is held at the publication-gate level pending resolution of that module-uncertainty threshold in tax_treatment, rather than published as fully cleared. Read full brief · 1167 words Key regulatory facts for Portugal Regulatory Dimension Portugal Standing Position Jurisdiction Portugal (PT) Regulatory Scope Crypto & Digital Asset Regulation (8 modules, 38 sourced findings) Crypto Licensing MiCA (Regulation (EU) 2023/1114), implemented nationally via Lei n.º 69/2025, applies directly and is fully in force. Token Classification MiCA taxonomy (ART/EMT/other/security token/NFT) applies directly with clear national authority allocation between CMVM and Banco de Portugal, leaving limited national interpretive discretion. On-Chain Activity Regime No Portugal-specific rules identified for staking, DeFi lending, mining or node operation; coverage depends entirely on whether an intermediary CASP is involved, which is not yet clarified in Portuguese supervisory... Stablecoin Regime ART/EMT issuance, reserve and redemption rules apply directly under MiCA Titles III/IV with Banco de Portugal as national authority. Primary Instruments Cited Crypto-asset service providers (CASPs) operating in Portugal, Lei n.º 69/2025 (Portugal's national MiCA implementing law), MiCA Article 143(3) grandfathering clause (Portugal), Portugal (MiCA-authorised CASP count), Portugal MiCA transitional regime Last Confirmed / Updated 2026-10-25 (39 sources in cumulative register) 8 of 8 categories Signal Moved Judgment Gap Density Comfortable Compact Expand all sources Reset all Selections OR within a group, AND across groups. Press / to search. ### Portugal: C1 Crypto LicensingAmberEnacted in forceModule confidence: Probable▾ MiCA (Regulation (EU) 2023/1114), implemented nationally via Lei n.º 69/2025, applies directly and is fully in force. Supervisory responsibility splits between CMVM (CASP authorisation/conduct, Titles II & VI) and Banco de Portugal (ART/EMT issuer authorisation and prudential supervision, Titles III & IV), confirmed via ESMA's Article 93 competent-authority list. Despite the regime being fully in force and the Article 143(3) grandfathering window having closed on 1 July 2026 per ESMA's public statement, Portugal's ESMA interim register showed zero authorised CASPs as of mid-2026, versus 57 in Germany and 26 each in France and the Netherlands. Open gap — crypto-int-1 Exact PT contraordenação fine schedule under Lei 69/2025 for unauthorised CASP activity not independently located this cycle. DeFi/validator-level activity is a flagged under-indexed vector fleet-wide. Open gap — crypto-int-2 MiCA Art 67/Annex IV own-funds figures as applied via the PT authorisation process not retrieved this cycle. no under-indexing note recorded Horizon · 2026-07-01 (± a quarter) MiCA transitional regime expiry for pre-existing PT VASPs Adopted, not yet in force · Tier 1 source Horizon · 2026-Q4 (± a quarter) Further PT full CASP authorisations expected beyond Bison Bank In force · Tier 3 source #### Crypto Licensing Portugal's crypto-licensing perimeter runs on the directly applicable EU framework of Regulation (EU) 2023/1114 (MiCA), given domestic effect through Lei n.º 69/2025, the December 2025 national implementing statute. Supervisory responsibility is split rather than unified: the Comissão do Mercado de Valores Mobiliários (CMVM) is designated competent authority for crypto-asset service provider (CASP) authorisation and conduct supervision under MiCA Titles II and VI, while Banco de Portugal holds authorisation and prudential supervisory competence over asset-referenced token (ART) and e-money token (EMT) issuers under Titles III and IV. This allocation is confirmed via ESMA's Article 93 competent-authority list, a T1 primary source, and is reinforced by Lei n.º 69/2025's grant of Article 94 supervisory and sanctioning powers, including a market-abuse sanctions regime, to both bodies. The regime's practical bite, however, diverges sharply from its formal completeness. As of mid-2026, Portugal's entry in ESMA's interim MiCA register showed zero authorised CASPs, against 57 in Germany and 26 each in France and the Netherlands. This finding rests on a single T4 news source (The Block), corroborated by two further T4 outlets (Incrypted, Cointelegraph) reporting the same cross-EU register figures; absent a directly cited T1/T2 primary source, the crypto guardrail Confidence Floor caps this claim at Probable rather than Confirmed, and that downgrade has been applied and carried through composition unchanged. Compounding the authorisation gap, MiCA's Article 143(3) transitional (grandfathering) provision — which had permitted pre-existing Portuguese virtual-asset service providers to continue operating pending authorisation or its refusal — formally closed on 1 July 2026, per ESMA's 23 June 2026 public statement. Any legacy entity that has not by now secured MiCA authorisation is required to have wound down crypto-asset services in Portugal. Given the mid-2026 zero-authorisation count, this creates a live supervisory and market-access uncertainty: it is not established from current sourcing whether any legacy entities continued operating past the deadline, nor what enforcement posture CMVM or Banco de Portugal has taken toward them. That question remains open in the gaps register rather than resolved here. #### Outlook The immediate forward marker is enforcement follow-through: whether CMVM and Banco de Portugal move visibly against any unauthorised legacy operators now that the transitional window has closed, and whether Portugal's authorisation count moves off zero as pending applications (if any) clear. The current record also flags, but does not resolve, whether Portugal's Banco de Portugal/CMVM dual-authority model should eventually be treated as a JID-split candidate analogous to the Netherlands' DNB/AFM structure — a pipeline-wiring question for a later cycle, not a judgment this composition makes. Confidence on the authorisation-throughput figure should be expected to firm toward Confirmed only once a T1/T2 primary citation to the live ESMA register is obtained. Read full sub-brief · 445 words Periodic update · new data 2026-10-25 #### Crypto Licensing The defining fact for crypto licensing in Portugal is the expiry of the transitional regime created by article 6 of Lei n.º 69/2025, the statute implementing the Markets in Crypto-Assets Regulation domestically. That provision allowed entities registered with Banco de Portugal before 30 December 2024, and that had already commenced duly-notified virtual-asset activity, to continue operating until 1 July 2026 or the date of a final Markets in Crypto-Assets authorisation decision, whichever occurred first. That deadline has now passed, and the transitional carve-out is closed as a matter of law. The practical consequence of that closure is now visible in supervisory data. The European Securities and Markets Authority maintains an interim register of authorised crypto-asset service providers across the Union, and the version of that register dated 7 October 2026 shows only a single Portugal-supervised entity holding completed authorisation. This is a strikingly small number set against the hundreds of authorisations recorded bloc-wide, and it is the clearest available evidence of how the Portuguese authorisation pipeline has handled the population of firms that relied on the now-closed transitional cover. The regime's substantive legal architecture is otherwise settled and not in question: Banco de Portugal and the Comissão do Mercado de Valores Mobiliários have clearly delineated supervisory competence, and the licensing requirement itself, as a matter of law, is neither new nor ambiguous. What is ambiguous is enforcement and compliance behaviour among the population of firms that no longer benefit from transitional cover but have not yet secured full authorisation. Portuguese commentary describes operating as a crypto-asset service provider without authorisation, once the transitional window has closed, as a contraordenação muito grave, a very serious administrative offence under the domestic regulatory-offence taxonomy. That characterisation is sourced to commentary rather than to a primary statement of the applicable fine schedule, and the precise monetary range attaching to that offence category for unauthorised post-deadline activity has not been independently located. Similarly, the own-funds and prudential-capital figures that apply to firms going through the Portuguese authorisation process under Markets in Crypto-Assets article 67 and Annex IV have not been confirmed from a primary source; the transitional-deadline finding itself, by contrast, is corroborated between a Tier 3 legal-commentary source and the Tier 1 designation of competent authorities under the same statute, which supports treating it as a confirmed rather than merely probable fact. The analytical question this authorisation gap raises is not one of misconduct but of supervisory capacity and pacing. A jurisdiction can have an entirely clear and legally settled licensing requirement while still facing a bottleneck in the administrative machinery that turns applications into grants. Whether the single-authorisation count reflects genuinely modest applicant volume in Portugal specifically, or a backlog at one or both of the two competent authorities, cannot be determined from the evidence available. Either reading has implications for any firm relying on, or seeking to rely on, a Portugal-granted Markets in Crypto-Assets authorisation and its associated passporting rights across the Union. #### Outlook The single metric worth tracking forward is movement in the Portugal-supervised authorisation count on the ESMA interim register. A rise toward a figure more proportionate to the market that previously operated under transitional registration would suggest the October snapshot reflected a processing lag rather than a durable constraint; a count that remains flat across further register updates would strengthen the case that this is a structural capacity issue at Banco de Portugal and the Comissão do Mercado de Valores Mobiliários. Two specific evidentiary gaps remain open for a future cycle: the precise contraordenação fine schedule applicable to unauthorised post-deadline crypto-asset-service activity, and the own-funds figures actually applied through the Portuguese authorisation process under Markets in Crypto-Assets article 67 and Annex IV. Neither gap affects the confirmed status of the transitional-deadline finding itself, which rests on corroborated evidence. 3 earlier distinct update(s) Periodic update · new data 2026-10-18 #### Crypto Licensing Portugal's crypto-asset licensing regime is governed by Lei n.º 69/2025, which implements the Markets in Crypto-Assets Regulation domestically and designates Banco de Portugal as the authorising authority for crypto-asset service providers. Banco de Portugal communicates its authorisation, extension, reduction and revocation decisions to the Comissão do Mercado de Valores Mobiliários, and the two authorities are under a joint statutory obligation to publish and keep updated a list of entities authorised or otherwise entitled to provide crypto-asset services in Portugal. This authorisation requirement and the associated publication duty have been in force since 2 July 2026 and represent the settled core of Portugal's licensing architecture. The defining event of this reporting period is the lapse, on 1 July 2026, of the MiCA transitional regime that had permitted continuity of operation for pre-existing virtual-asset service providers. Under that transitional arrangement, entities registered with Banco de Portugal as of 30 December 2024, with activity duly commenced and formally notified, were entitled to continue operating under the prior regime until 1 July 2026 or until Banco de Portugal granted or refused their MiCA authorisation application, whichever occurred first. This transitional permission is corroborated independently by Banco de Portugal's own press release confirming the same cutover date and legal basis, giving this finding a Confirmed confidence rating grounded in primary-source agreement. With the window closed, no further transitional carve-out exists: an entity providing crypto-asset services in Portugal today must either hold a final MiCA authorisation or be in the formal process of a pending application that was lodged while transitional protection still applied. The operative transparency mechanism accompanying this framework, the jointly published Banco de Portugal/Comissão do Mercado de Valores Mobiliários list of authorised and transitionally-permitted entities, is reported to have included eight entities meeting the specified transitional conditions as of one recent check shortly after 10am on a Wednesday. This figure should be read as a single-point-in-time snapshot rather than a stable count, since authorisation decisions continue to be processed and the list is designed to be kept current rather than fixed. Separately, minimum own-funds requirements applicable to crypto-asset service providers in Portugal follow MiCA's tiered structure: €50,000 for advisory and order-reception-and-transmission services, €125,000 for custody and exchange services, and €150,000 for operating a trading platform, with an alternative floor of one quarter of the preceding year's fixed overheads where that figure is higher. These capital tiers are sourced from commentary restating the MiCA Annex IV framework as applied in Portugal rather than from a Banco de Portugal primary document, and should be read as probable rather than confirmed pending a primary-source citation. Penalty exposure under the regime is reported as substantial: very serious infractions, including unauthorised provision of crypto-asset services, market manipulation, and the provision of false or misleading information, carry fines of up to €2.5 million for natural persons and up to €5 million for legal persons. The precise statutory article establishing this penalty tier has not been independently pinpointed this cycle, so this figure likewise carries a probable rather than confirmed confidence rating. The practical reality accompanying this now-fully-operative legal framework is a reported gap between legal force and administrative processing capacity. Industry commentary indicates that firms with MiCA authorisation applications under review have faced processing delays, creating a period of practical uncertainty for entities whose prior transitional protection has lapsed but whose final authorisation status remains pending. This is a capacity observation rather than a legal one: the authorisation requirement itself is settled and enforceable, but the administrative apparatus processing applications against that requirement is, per industry reporting, running behind the volume of applications before it. #### Outlook The central forward-looking question is how quickly the backlog of pending MiCA authorisation applications clears, now that the transitional safe harbour that had covered pre-existing virtual-asset service providers has lapsed. The jointly published Banco de Portugal/Comissão do Mercado de Valores Mobiliários authorised-entities list is the most direct available indicator of that clearance rate, though its update cadence and the stability of the entity count it reports have not been independently tracked across multiple points in time this cycle. No further legal change to the licensing framework itself is indicated; the open variable is administrative throughput against an already-settled legal requirement, a distinction that matters for any entity assessing its own authorisation timeline against the now-closed transitional window. Periodic update · new data 2026-10-11 #### Crypto Licensing Portugal's crypto-asset licensing regime is now structurally settled around Banco de Portugal as the primary authorising and prudential authority, a correction to an earlier interpretive framing that had placed CMVM as primary. The governing instrument is Regulation (EU) 2023/1114 (MiCA) as implemented through Lei n.º 69/2025. The national transitional regime, which had allowed pre-existing virtual-asset service providers registered with Banco de Portugal to continue operating pending full authorisation, closed on 1 July 2026. At that deadline, only Bison Bank held a full Crypto-Asset Service Provider authorisation, meaning the transition produced an authorisation bottleneck: other firms that had relied on the transitional window faced the prospect of lapsing into unauthorised status if they had not secured full authorisation by the deadline. This is a core-authorisation regime that is in force, but the transition has not yet produced a settled multi-firm authorisation base. The open question for the current period is whether Banco de Portugal has issued further full CASP authorisations since the July 2026 deadline; the available record does not establish this either way, leaving the single-authorisation-holder position as the most recent confirmed state. Periodic update · new data 2026-09-05 #### Crypto Licensing CASP authorisation in Portugal is now required under MiCA (Regulation (EU) 2023/1114), administered through coordination between Banco de Portugal and CMVM under the domestic implementation, Law No. 69/2025. CMVM acts as the securities-markets competent authority for CASP conduct and prudential supervision. Entities that were registered with Banco de Portugal for virtual-asset activity as of 30 December 2024, with their activity duly notified, may continue operating under transitional arrangements only until 1 July 2026, or until MiCA authorisation is granted or refused, whichever occurs first. This transitional-deadline finding is sourced directly to Banco de Portugal's own authorisation guidance and is the single most consequential near-term compliance date facing Portugal's crypto sector. #### Outlook The 1 July 2026 cutover is the item to watch: whether previously-registered entities secure full MiCA authorisation, are refused, or exit the Portuguese market before the deadline will be the clearest observable signal of how the transitional regime resolves in practice. Sources and findings (9) - T1 · ESMA[Crypto-asset service providers (CASPs) operating in Portugal](https://www.esma.europa.eu/sites/default/files/2024-12/List_of_Competent_Authorities_notified_to_ESMA_under_MiCA.pdf) — MiCA authorisation, with ongoing supervision split: CMVM (CASPs, Titles II & VI) and Banco de Portugal (ART/EMT issuer authorisation & prudential supervision, Titles III & IV) - T1 · Assembleia da República / Diário da República[Lei n.º 69/2025 (Portugal's national MiCA implementing law)](https://eur-lex.europa.eu/legal-content/PT/TXT/PDF/?uri=NIM:202507294) — Banco de Portugal and CMVM, per MiCA Article 94, including a sanctions regime for crypto-asset market abuse - T1 · ESMA[MiCA Article 143(3) grandfathering clause (Portugal)](https://www.esma.europa.eu/sites/default/files/2026-06/ESMA75-113276571-1710_Public_Statement_MiCA_transitional_period_ends.pdf) — 1 July 2026, or grant/refusal of MiCA authorisation if earlier — this transitional window has now concluded per ESMA's public statement of 23 June 2026; unauthorised legacy entities must wind down crypto-asset services in Portugal - T4 · The Block[Portugal (MiCA-authorised CASP count)](https://www.theblock.co/post/406766/europes-mica-crypto-regime-is-fully-in-force-heres-who-wins-and-loses) — mid-2026, per ESMA's interim MiCA register, versus Germany (57), France and Netherlands (26 each) - T3[Portugal MiCA transitional regime](https://www.mlgts.pt/en/knowledge/legal-alerts/Legal-Alert-Implementation-of-the-Markets-in-Crypto-Assets-Regulation-in-Portugal/26444/) — Entities previously registered with Banco de Portugal under the pre-MiCA virtual-assets AML regime could continue operating under a transitional regime until 1 July 2026, or until a final MiCA authorisation decision, whichever occurred first - T4[Portugal CASP authorisation regime](https://legarithm.io/crypto-license-portugal-2026/) — Operating as a crypto-asset service provider in Portugal without MiCA authorisation after 1 July 2026 is prohibited; firms relying on the old Banco de Portugal registration are treated as trading unlicensed - T3 · Ana Pimenta Advogados[Lei n.º 69/2025, art. 6.º](https://anapimentaadvogados.pt/noticia/portugal-regulamenta-o-mercado-de-criptoativos-com-aplicacao-do-regulamento-mica) — Entities registered with Banco de Portugal before 30 Dec 2024 and that had commenced duly-notified activity could continue virtual-asset activities until 1 July 2026 or final MiCA authorisation decision, whichever occurred first. - T3[Portugal MiCA implementing regime](https://www.noticiasdeaveiro.pt/criptomoedas-em-2026-o-que-um-investidor-portugues-deve-saber-antes-de-comecar/) — Operating as a crypto-asset service provider in Portugal without MiCA authorisation after the end of the transitional period is treated as a contraordenação muito grave (very serious administrative offence). - T2[Lei n.º 69/2025](https://dinheirovivo.dn.pt/mercados/entram-em-vigor-as-novas-regras-sobre-criptoativos-multas-podem-chegar-a-cinco-milhes) — Very serious infractions (including unauthorised provision of crypto-asset services, market manipulation, false/misleading information) carry fines up to €2.5m (natural persons) / €5m (legal persons) ### Portugal: C2 Token ClassificationGreenEnacted in forceModule confidence: Probable▾ MiCA taxonomy (ART/EMT/other/security token/NFT) applies directly with clear national authority allocation between CMVM and Banco de Portugal, leaving limited national interpretive discretion. C2 · Token Classification — Full Module Record 0 sub-modules · 180 words · 6 traced claims · Re-verified 2026-10-25 The decision headline, regulatory posture (Green), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month , or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products) . [Unlock with Free Pass / Sign In](https://a-i.gi/auth/login) [View Pro & Firm Plans (£39 / £199)](https://a-i.gi/licensing/#plans)[View Open Exemplar (Gibraltar)](/jurisdictions/gi/) ### Portugal: C3 On-Chain Activity RegimeAmberEnacted in forceModule confidence: Probable▾ No Portugal-specific rules identified for staking, DeFi lending, mining or node operation; coverage depends entirely on whether an intermediary CASP is involved, which is not yet clarified in Portuguese supervisory practice. This is a genuine sourcing gap rather than a confirmed no-regulation finding. C3 · On-Chain Activity — Full Module Record 0 sub-modules · 180 words · 4 traced claims · Re-verified 2026-10-25 The decision headline, regulatory posture (Amber), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month , or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products) . [Unlock with Free Pass / Sign In](https://a-i.gi/auth/login)[View Pro & Firm Plans (£39 / £199)](https://a-i.gi/licensing/#plans)[View Open Exemplar (Gibraltar)](/jurisdictions/gi/) ### Portugal: C4 Stablecoin RegimeGreenEnacted in forceModule confidence: Probable▾ ART/EMT issuance, reserve and redemption rules apply directly under MiCA Titles III/IV with Banco de Portugal as national authority. Periodic update · new data 2026-09-05 #### Stablecoin Regime Banco de Portugal supervises reserve, redemption-right and disclosure obligations for asset-referenced tokens (ARTs) and e-money tokens (EMTs) under MiCA Titles III and IV, as implemented domestically through Law No. 69/2025. This gives Portugal a stablecoin-supervision framework that is directly derived from the EU-level MiCA regulation, with Banco de Portugal designated as supervisor specifically for reserve-backing, redemption-right and disclosure obligations, distinct from CMVM's role covering other token categories and CASP conduct. #### Outlook No PT-specific stablecoin enforcement or designation track record has yet been observed under the new regime; this is the item most likely to generate observable material next cycle as MiCA supervision matures in practice. C4 · Stablecoins & EMTs — Full Module Record 0 sub-modules · 180 words · 5 traced claims · Re-verified 2026-10-25 The decision headline, regulatory posture (Green), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month , or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products) . [Unlock with Free Pass / Sign In](https://a-i.gi/auth/login)[View Pro & Firm Plans (£39 / £199)](https://a-i.gi/licensing/#plans)[View Open Exemplar (Gibraltar)](/jurisdictions/gi/) ### Portugal: C5 Consumer ProtectionGreenEnacted in forceModule confidence: Probable▾ White-paper, conduct, withdrawal-right and custody-segregation duties apply directly under MiCA Titles II/V with CMVM/Banco de Portugal enforcement under Lei n.º 69/2025. #### Consumer Protection Consumer-facing obligations under MiCA apply comprehensively and directly in Portugal, enforced through CMVM under the Title II and Title V frameworks and reinforced domestically by Lei n.º 69/2025's grant of supervisory and sanctioning powers. Issuers offering crypto-assets to the public or seeking trading admission in Portugal must publish a compliant white paper and accompanying marketing communications, and are liable for damages caused by incomplete, unfair, or unclear white-paper information. Retail purchasers buying crypto-assets directly from an issuer — excluding ART/EMT, which carry their own redemption-right regime under the stablecoin module — are granted a statutory right of withdrawal under MiCA, though this claim is held at Probable confidence pending closer verification of the withdrawal window's exact scope and duration. CASPs providing custody and administration of crypto-assets must safeguard and segregate client crypto-assets from the CASP's own assets under MiCA Title V, also held at Probable confidence. #### Outlook These obligations are binding EU law with clear enforcement teeth in Portugal via CMVM, and are unlikely to weaken; the open question is practical compliance monitoring — whether CMVM has begun active supervision of white-paper quality and custody-segregation practice among the CASPs now operating (or seeking to operate) in Portugal, which the zero-authorisation finding in the licensing module suggests may still be a very small population. Read full sub-brief · 215 words No periodic updates recorded in this cycle Sources and findings (5) - T1 · EUR-Lex[Crypto-asset issuers offering to the public or seeking trading admission in Portugal](https://eur-lex.europa.eu/PT/legal-content/summary/european-crypto-assets-regulation-mica.html) — a crypto-asset white paper and marketing communications; liable for damages caused by incomplete, unfair or unclear white-paper information - T1 · EUR-Lex[Retail purchasers buying crypto-assets directly from an issuer (excl. ART/EMT) in Portugal](https://eur-lex.europa.eu/PT/legal-content/summary/european-crypto-assets-regulation-mica.html) — a statutory right of withdrawal under MiCA - T1 · Official Journal of the European Union / EUR-Lex[CASPs providing custody and administration of crypto-assets in Portugal](https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32023R1114) — client crypto-assets from the CASP's own assets, under MiCA Title V - T3 · NotíciasdeAveiro.pt[Associações de defesa dos detentores de criptoativos](https://www.noticiasdeaveiro.pt/criptomoedas-em-2026-o-que-um-investidor-portugues-deve-saber-antes-de-comecar/) — CMVM-registered crypto-asset holder defence associations may bring collective (ação popular) proceedings on behalf of investors under the PT MiCA-implementing regime. - T3[Portugal CASP custody regime](https://abreuadvogados.com/en/conhecimento/publications/mica-in-portugal-highlights-of-the-new-implementing-law/) — No PT-specific custody/segregation rule beyond MiCA Art 75 was located this cycle ### Portugal: C6 Tax TreatmentAmberEnacted in forceModule confidence: Probable▾ 28% capital gains rate (sub-365-day holdings) and DAC8 cross-border reporting (from 1 Jan 2026) confirmed via T1 sourcing for DAC8; the 28%/365-day capital gains parameters and the VAT exemption still rest on T4 secondary sourcing only. Periodic update · new data 2026-09-05 #### Tax Treatment Individual crypto-asset disposals held under 365 days are taxed at a 28 percent capital-gains rate in Portugal, while holdings of over 365 days remain exempt for individual taxpayers, under the Código do IRS as amended in 2023. This cycle's sourcing rests on a Tier-4 aggregator rather than primary Autoridade Tributária e Aduaneira or Código do IRS text, and the finding should be treated as directionally consistent with the well-documented 2023 reform rather than independently re-verified this cycle. #### Outlook Primary-source verification of the Código do IRS text is the item that would most improve confidence in this module's rate figures; absent that, the finding remains assessed rather than confirmed. C6 · Tax Treatment — Full Module Record 0 sub-modules · 180 words · 8 traced claims · Re-verified 2026-10-25 The decision headline, regulatory posture (Amber), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month , or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products) . [Unlock with Free Pass / Sign In](https://a-i.gi/auth/login)[View Pro & Firm Plans (£39 / £199)](https://a-i.gi/licensing/#plans)[View Open Exemplar (Gibraltar)](/jurisdictions/gi/) ### Portugal: C7 Cross-Border TransferGreenEnacted in forceModule confidence: Probable▾ Travel-rule (Regulation 2023/1113) and Russia-sanctions nexus (Regulation 833/2014) apply directly; no Portugal-specific outbound restriction identified. Periodic update · new data 2026-09-05 #### Cross-Border Transfer Portugal applies the EU Travel Rule to crypto-asset and fund transfers irrespective of value, including self-hosted-address transfers, under Article 71-A of Law No. 83/2017. This zero-threshold application is materially stricter than the phased or de-minimis thresholds many peer EU jurisdictions apply to self-hosted-wallet transfers, placing compliance weight directly on Portuguese crypto-asset service providers and financial institutions to identify and verify counterparties for every self-hosted-address transaction regardless of size. Supervisory responsibility is split by token category between Banco de Portugal (MiCA Titles III/IV) and CMVM (Title II/VI and CASP conduct). #### Outlook The item to watch is how PT-facing CASPs operationalise zero-threshold counterparty identification for self-hosted-wallet transfers in practice, and whether independent verification of the underlying Diário da República legislative text becomes available to corroborate the current single-source finding. C7 · Cross-Border & Travel Rule — Full Module Record 0 sub-modules · 180 words · 5 traced claims · Re-verified 2026-10-25 The decision headline, regulatory posture (Green), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month , or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products) . [Unlock with Free Pass / Sign In](https://a-i.gi/auth/login)[View Pro & Firm Plans (£39 / £199)](https://a-i.gi/licensing/#plans)[View Open Exemplar (Gibraltar)](/jurisdictions/gi/) ### Portugal: C8 AML/CFT RegimeGreenEnacted in forceModule confidence: Probable▾ AML/CFT obligations for Portuguese CASPs are carried via the FIM (financial-integrity monitor) subscription; no independent crypto-specific gap identified requiring escalation at this station, and no original illicit-finance analysis is performed here. C8 · AML/CFT Regime — Full Module Record 0 sub-modules · 180 words · 4 traced claims · Re-verified 2026-10-25 The decision headline, regulatory posture (Green), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month , or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products) . [Unlock with Free Pass / Sign In](https://a-i.gi/auth/login)[View Pro & Firm Plans (£39 / £199)](https://a-i.gi/licensing/#plans)[View Open Exemplar (Gibraltar)](/jurisdictions/gi/)