The legislation, approved by parliament at the end of 2025, is designed to reinforce oversight of the crypto sector, improve market transparency and combat money laundering, terrorist financing and other illicit activities linked to digital assets.

Under the new framework, the Bank of Portugal and the CMVM are responsible for authorising and supervising crypto-asset service providers operating in the country, as both regulators will also publish and regularly update lists of firms authorised to offer crypto-related services, detailing the activities each company is permitted to undertake.

This legislation introduces a tougher enforcement regime, with significant financial penalties for breaches: individuals found guilty of the most serious offences face fines of up to €2.5 million, while companies can be fined up to €5 million.

Among the offences classified as particularly serious are operating crypto-asset services without regulatory approval, manipulating markets and providing false or misleading information to regulators, clients or the public.

The legislation was signed into law by former President Marcelo Rebelo de Sousa on 13 December 2025, despite reservations over the risks associated with crypto-assets.

At the time, he acknowledged concerns about the sector but argued that implementing the legislation was necessary to ensure that Portugal complied with the European Union's Markets in Crypto-Assets (MiCA) Regulation, adding that imperfect regulation was preferable to having no regulatory framework at all.

However, concerns remain within the financial services industry over how the transition is being managed.

The Portuguese Association of Payment Institutions and Electronic Money (ANIPE) has warned that the conclusion of MiCA's transitional period could leave parts of the domestic crypto market unable to operate if outstanding authorisation applications are not processed in time.

In a statement, the association said that only a small number of firms have so far received full authorisation under the new regime, arguing that delays in adapting Portugal's national legislation, combined with lengthy approval procedures, have left many businesses with insufficient time to complete the authorisation process before the new rules came into force.

The ANIPE believes the situation could disrupt operators whose applications are still under review, despite having already begun the licensing process.

The association is now calling on both the Bank of Portugal and the CMVM to provide greater transparency on pending applications, including expected decision timelines, and to clarify what transitional or mitigating measures, if any, will apply to firms whose applications remain unresolved after the new regime takes effect.