Portugal has officially completed the implementation of the EU Markets in Crypto-Assets Regulation (MiCA). With the publication of Law 69/2025 on 22 December, the country moves from regulatory delay to full alignment, bringing long-awaited clarity for crypto-asset issuers and service providers.
After postponements caused by the May 2025 snap elections, this marks a decisive shift from Portugal’s “crypto-friendly” positioning to a fully regulated MiCA framework.
Who Supervises What? A Highly Structured Model
The new law introduces a detailed split of responsibilities between national regulators.
Banco de Portugal now leads on:
- – Licensing and prudential supervision of CASPs
- – Authorisation of ART and EMT (stablecoin) issuances
- – Governance, outsourcing, wind-down planning, and acquisitions
CMVM takes charge of:
- – Conduct and behavioural supervision of CASPs
- – Oversight of non-stablecoin crypto-asset offerings
- – Market abuse and investor protection rules
Given the overlap in CASP obligations, the law mandates formal cooperation and information sharing between the two authorities, an essential safeguard in such a dual-supervision model.
New Obligations, Higher Expectations
Law 69/2025 goes beyond MiCA’s core framework by introducing:
- – Knowledge and competence requirements for CASP staff and advisors
- – The possibility of class actions by investor and consumer associations
- – Mandatory complaints-handling systems
- – Access to alternative dispute resolution mechanisms for clients and tokenholders
Sanctions and Transition: No Room for Complacency
Administrative fines can reach EUR 5 million, or more where linked to economic benefit or turnover. Meanwhile, CASPs registered under the existing AML/VASP regime may continue operating only until 1 July 2026, unless authorisation is granted or refused earlier.
What This Means for the Market
Portugal now offers regulatory certainty at the cost of significantly higher compliance and governance standards. For crypto firms, early preparation, licensing strategy, and regulator engagement are no longer optional.
At DCGG, we continue to support digital asset businesses navigating MiCA across Europe, helping them turn regulatory change into strategic advantage.