Banco de Portugal Authorises Just Five Loan-Management Firms Five Months Into the Lei 70/2024 Regime — 321 Crédito's €28 Million Projeto Boavista 3 Sets the First Secondary-NPL Test

The Banco de Portugal has approved only five gestores de créditos in the five months since the Lei 70/2024 regime governing the secondary non-performing-loan (NPL) market entered into force on 10 December 2025. ECO carried the count on Wednesday: Servedebt, Duo Capital, Solicigest, the German-owned Global Loan Agency Services, and Finsolutia as the most recent approval.

The slow build-up matters because the new regime is the transposition of EU Directive 2021/2167, which requires every entity acting on a transferred non-performing loan portfolio to hold a Bank of Portugal licence — a sharper compliance bar than the previous regime, where most servicers operated under a notification rather than an authorisation framework. The directive's stated objective is to widen Europe's secondary NPL market by giving cross-border buyers a single passport, but the bottleneck is now the national supervisor's processing capacity.

The five authorised firms

Servedebt is the local servicer that handled the post-2014 wave of bank-led NPL transfers for Novo Banco and Santander Totta and is by far the largest of the five by managed book. Duo Capital and Solicigest are mid-sized Portuguese-owned operators with concentrations in unsecured consumer credit and real-estate-backed loans, respectively. Global Loan Agency Services — owned by a German parent — is the only cross-border entrant and arrives with a Frankfurt-based operating model. Finsolutia, the most recent approval, is the regional player owned by KKR Credit and active across Portugal, Spain, and Italy.

The first transaction the new rules will be tested against

The first NPL transaction launched into the post-Lei-70/2024 market is 321 Crédito's Projeto Boavista 3 — an unsecured consumer-credit portfolio valued at €28 million that the auto-finance subsidiary of Banco CTT put out to non-binding bids in early May. Closing is targeted for September. The portfolio is small relative to the €1.5-to-€2.5 billion bank-led transactions that closed in 2017-19, but it is the first issuance where bidders, sellers, and the eventual servicer will all need a Lei 70/2024 authorisation, making it the regulatory test bed for the new pipeline.

The macro backdrop

Portugal's banking-system NPL ratio has compressed from a 2015 peak of 17.5% to just over 2% at end-2025, the steepest improvement in any peripheral euro-zone banking system over the cycle. That decline means the live NPL stock available for secondary-market activity has shrunk substantially, with most transactions now in the unsecured-consumer or specialised-mortgage segments rather than the large corporate-loan blocks that dominated the post-crisis wave.

The flow side is moving the other way. The Banco de Portugal's first-quarter banking-stability data showed a marginal pick-up in mortgage NPLs after the central bank tightened the DSTI cap to 45% from 1 July, with stage-2 forborne exposures rising as well. If the next cycle materialises, the question for the secondary market will be whether the BdP's processing rhythm — five authorisations in five months — can keep up with the demand the regime is supposed to enable.

What the licence actually requires

The Lei 70/2024 file demands evidence of idoneity, professional experience, and minimum financial capacity for the legal representative and at least one director, plus an internal-control framework that the BdP signs off on. The regime also prohibits any "prática de assédio ou coação" toward borrowers — a clause the Banco de Portugal lifted directly from the directive and that exposes authorised firms to licence revocation if collection practices breach the standard. The first revocation will be the next informal datapoint on how seriously the supervisor intends to enforce the regime.