The Portugal Central Bank (Banco de Portugal) has issued a consumer alert about fees charged by loan brokers: most credit intermediaries operating in the country are legally forbidden from demanding any payment whatsoever from borrowers.
Why This Matters
• Most loan brokers cannot legally charge you for arranging, executing, or repaying a credit contract—only one category can.
• Verify the intermediary's registration and category on the Banco de Portugal website before signing anything—or paying a cent.
Three Types of Intermediaries, Three Sets of Rules
The Portugal Central Bank divides credit intermediaries into three distinct categories, and the rules for who pays them differ sharply depending on which type you're dealing with.
Tied intermediaries (vinculados) work under contract with one or more lenders and are compensated exclusively by those institutions. They cannot demand any payment, commission, or expense from consumers—full stop.
Ancillary intermediaries (a título acessório) provide loan brokerage as a side service to their main business. Like tied intermediaries, they are paid solely by the lenders and cannot extract fees from borrowers.
Unaffiliated intermediaries (não vinculados) are the exception. Because they receive no compensation from banks or finance companies, they are entitled to charge consumers directly for their services. However, the law requires them to disclose the price upfront and include it explicitly in the credit intermediation contract. No contract, no payment—period.
The Central Bank emphasizes that all three categories are banned from collecting any funds related to the signing, performance, or early repayment of the actual loan itself. The only permissible charge is the service fee owed to an unaffiliated intermediary, and even that must be transparent and contractually documented.
What This Means for Residents
If you're shopping for a mortgage, car loan, or personal credit and working with an intermediary, your first move should be checking the official registry on the Banco de Portugal website. The database lists every authorized intermediary and clearly labels their category.
Before you agree to any service, confirm whether the broker is tied, ancillary, or unaffiliated. If they fall into the first two categories and ask for money, you're dealing with an illegal demand. If they're unaffiliated, ask for a written quote and verify that the fee appears in the intermediation contract before you sign.
Never hand over cash, bank transfers, or any form of payment beyond the agreed service fee for an unaffiliated intermediary. If a broker requests funds "to process the loan," "to secure the rate," or "to expedite approval," that's a red flag for fraud.
The Central Bank urges consumers to read all documentation carefully before making a decision and to verify that any intermediary you work with is listed on the official registry.
How to File a Complaint
If you suspect an intermediary has charged you illegally or engaged in deceptive practices, the Portugal Central Bank offers several channels for lodging a complaint:
• Electronic Complaints Book (Livro de Reclamações Eletrónico): accessible online via the national complaints platform.
• Direct submission to the Central Bank: use the electronic form on the Portal do Cliente Bancário, mail a printed form to Apartado 2240, 1106-001 Lisboa, or visit the bank's offices in person.
• Telephone hotline: call 213 130 020 (calls are recorded).
Before filing, the Central Bank recommends consulting the virtual assistant on the Portal do Cliente Bancário to clarify the rules that apply to your situation. Once a complaint is submitted, the intermediary has 15 business days (if filed via the electronic complaints book) or 20 business days after notification (if filed directly with the bank) to respond. The regulator will analyze the case and communicate its findings to the complainant.
The Central Bank can order corrections, impose fines, and enforce compliance, but it does not award compensation for damages. If you believe you've been defrauded, you should also file a criminal complaint with the PSP, GNR, Polícia Judiciária, or Public Prosecutor's Office.
The Bottom Line
The regulatory message is unambiguous: most credit intermediaries in Portugal cannot legally demand money from you. Only unaffiliated brokers can charge for their services, and even they must play by strict transparency rules. Before you sign, check the registry, read the contract, and remember—if they ask for money they're not entitled to, it's time to walk away and report them.
