It is the second change to the complaints submission regime carried out by Banco de Portugal (BdP) in a short time. The first, recently announced, makes financial institutions more responsible, both in relation to response deadlines and in relation to its content, as it must state, “expressly, whether they consider there to have been non-compliance”, and, when applicable, the measures adopted to correct the situation. The second, communicated this Monday, aims to direct electronic complaints submitted digitally to the Electronic Complaints Book, discontinuing the presentation form previously existing on the Bank Customer Portal.
“The Electronic Complaints Book allows for faster handling of complaints, because it automatically forwards complaints to the entities complained against and provides for shorter response times (15 days)”, says the banking supervisor in a statement. Adding that this channel “already received the majority of complaints submitted by bank customers”.
The change now introduced only applies to complaints made by digital means, maintaining, however, the possibility for customers to continue “to submit complaints directly to Banco de Portugal by post or at the respective service points”, as well as through the paper complaints book.
“Regardless of the channel used and as already happened, the complaint is always received and analyzed by Banco de Portugal”, guarantees the supervisor.
The first change, announced on May 22nd, and which also covers complaints addressed directly to Banco de Portugal, has greater relevance for consumers and is included in the Circular Letter No. CC/2026/00000018which gives it greater strength in terms of compliance.
That instrument establishes that, “after registration and preliminary analysis, the BdP sends complaints addressed directly to it (by post or through its branch network) to the complained entity through the BPnet service, the complained entity analyzes the complaint within a maximum period of 15 working days from its receipt, and communicates, within that period, to the complainant the result of the analysis carried out”.
And in the response addressed to the complainant, “the complained entity expressly indicates whether or not it considers there to have been non-compliance on its part, presenting the respective reasons and, when upholding the complaint, the measures adopted to remedy the identified situation”.
Also within the same period of 15 working days, “the complained entity sends to Banco de Portugal a copy of the response sent to the complainant, as well as any additional elements considered relevant for the assessment of the complaint, in accordance, when applicable, with the models previously made available by Banco de Portugal”
The circular letter, which revokes two previous letters, establishes new rules for possible requests for additional information: “After analyzing the response to complaints (either those addressed directly to Banco de Portugal or those presented through the Electronic Complaints Book), and if it considers that the information and elements made available do not allow it to be assessed whether the action of the complained entity is in compliance with the applicable regulatory framework, Banco de Portugal requests the necessary clarifications, submitting an additional request through the service BPnet”.
In this case, “the requested entity responds to the additional request, providing clarifications and making the requested elements available, within a maximum period of 5 working days or another longer period defined by Banco de Portugal”, establishes the normative document.
The greater speed of response and the express indication of the existence or not of non-compliance on the part of the institution are relevant for customers who wish to activate other means of defense, namely through alternative means of defense, such as arbitration courts, or through the courts.
According to data from the Behavioral Supervision Report, referring to 2025, the BdP received 33,375 complaints, 2.3% less compared to 2024, but of this universe, only 22,542 related to matters within the supervisor’s scope of action, a monthly average of 1879 complaints. And the amount that banking institutions were forced to return, the majority relating to undue commissions, amounted to at 8.91 million euros to customers.
Also in 2025, the Complaints Book, in paper and online format, received 485,203 complaints (of all sectors), 9.1% more than in 2024, and the highest number ever.
