On April 9th, 2025, Bank of Portugal published the Behavioral Supervision Report. This report is published annually and is a fundamental instrument for transparency, accountability, and strategic guidance for behavioral supervision in the banking and retail markets.
This report consists of the following considerations:
- Assessment of the regulatory, inspection, and educational activities carried out by the Bank of Portugal for the year in question;
- Reflections on the priorities and challenges identified in the previous year, with a view to setting the goals for subsequent years;
- Assessment of compliance with the rules by financial institutions and financial intermediaries;
- Promotion of consumer trust and financial system stability;
- Strengthening of the preventive and collaborative role of the Bank of Portugal for the purpose of consumer protection and defense.
The 2024 Behavioral Supervision Report placed special emphasis on credit intermediation, due to its exponential growth, which in 2024 resulted in 9436 authorized credit intermediaries at the end of the year, in which:
- 86,8% are collective entities and 13.2% are individuals;
- 99,9% act on behalf of financial institutions;
- The most prominent sectors are car sales and repairs (43,1%), real estate (21,5%) and retail trade (10,5%).
Regarding the types of credit intermediation, in 2024 the intermediaries were distributed as follows:
- Tied – 38,5%;
- Accessory title – 61,4%;
- Non-tied – 0,1%.
It should be noted that Bank of Portugal found a clear predominance of consumer credit in the Credit Intermediation universe, with an estimated 63,6% operating exclusively in this segment. This growth is associated with the intensification of commercial activity in the automotive and retail sectors, as well as increased demand for financing solutions from consumers.
In view of the clear growth in credit intermediation activity, the Bank of Portugal had already highlighted the urgent need to review the Legal Regime for Credit Intermediaries. Therefore, in its Behavioral Supervision Report, it considered a review to be essential and urgent, which should result in:
- Simplifying the process of registering and monitoring activity;
- Strengthening the technical capacity of credit intermediaries with a focus on legal compliance;
- Improving the transparency of their activities, providing consumers with greater clarity on costs, risks, and responsibilities;
- Optimizing supervision by the Bank of Portugal.
It should also be noted that the Bank of Portugal proposes to standardize interpretations of the legal framework in force, as some discrepancies have been identified in the application of existing rules among different Credit Intermediaries. The aim is therefore to achieve the following in 2025:
- Transmission of clarifying understandings, ensuring fair conditions in the market;
- Promotion of good practices across all credit intermediaries;
Finally, and most importantly, Bank of Portugal seeks the proper implementation of the new advertising regime that will enter into force on July 1st, 2025 (Notice No. 5/2024). The implementation of Notice No. 5/2024 is an operational and communication challenge for credit intermediaries, as they must:
- Review all their commercial communications;
- Ensure that commercial communications comply with the new criteria of legibility and clarity;
- Document and justify advertising approvals with the lending institutions
Overall, the Bank of Portugal emphasizes the growing importance of credit intermediation in consumers’ access to financial products, requiring, to that extent, greater attentive, preventive, and educational supervision.
The year 2024 was marked by a strengthening of measures for credit intermediaries, namely through the standardization of information practices, interpretative clarifications, and preparation for the new advertising regime provided for in Notice No. 5/2024.
Nevertheless, significant challenges remain for 2025, including the need to review and modernize the Legal Framework for Credit Intermediaries, harmonize market practices, effectively implement the new advertising framework, and strengthen responsible conduct in the marketing of financial products.
To this end, the future actions of Bank of Portugal will seek to combine rigorous supervision with close guidance to the sector, promoting a more transparent, inclusive, and balanced market for banking consumers.
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