Banco de Portugal Forces Lenders to Refund €8.91 Million to Clients in 2025 as Cobranças Indevidas Drop From the €22 Million 2024 Outlier — Commissions Carry €8.24 Million of the Restitution
BdP's 2025 Behavioural Supervision Report shows banks returned €8.91M to clients — €8.24M in commissions and €670k in interest — after pricing, suitability and late-payment breaches surfaced. Complaints over account closures jumped 55% and fraud disputes 45%.
Portugal's banks returned €8.91 million to clients in 2025 after the central bank's behavioural-supervision teams identified improperly charged fees and interest, according to the Banco de Portugal (BdP) 'Relatório de Supervisão Comportamental' published this month. The figure marks a sharp drop from €22.26 million in 2024 — a year inflated by a single institutional case worth roughly €15.5 million tied to an unlawful contractual clause that stripped credit clients of their spread bonuses when payments slipped late. Excluding that 2024 outlier, the 2025 print sits modestly above a normalised baseline rather than below it.
The €8.91 million breaks down as €8.24 million in commissions and approximately €670,000 in interest. Within the commissions bucket, pricing-rule failures accounted for €4.20 million, suitability and product-selling breaches drove €2.11 million, and late-payment penalty mis-application returned €1.33 million to clients. Roughly €600,000 came from other categories.
How the mechanism actually works
Refunds do not depend on individual customers filing complaints. The BdP's behavioural-supervision team conducts on-site inspections, off-site monitoring and complaints triage; when a systemic breach surfaces at one institution, the regulator orders restitution to every affected client — not just the ones who flagged the problem. The reclamation window extends up to five years back from the date of the determination, which means a single ruling can sweep up tens of thousands of historical transactions at once.
On the complaints side, the BdP received 33,375 complaints against financial institutions in 2025, a 2.3% year-on-year decline. Of those, 22,542 fell within the regulator's jurisdiction. Bank deposits remained the most reclaimed product at 32% of the in-scope flow, followed by consumer credit at 27%. Two sub-categories stood out for sharp growth: account closures jumped 54.9% year-on-year and fraud-related transfer disputes climbed 45%, reflecting the broader rise in 'Olá pai/Olá mãe' phishing scams and instant-payment fraud.
The regulator's enforcement toolkit produced 3,297 specific determinations, 418 recommendations and 124 warnings across 128 institutions during the year, alongside 51 contra-ordenações filed against 24 entities and €6.3 million in fines (€530,000 suspended).
What This Means for Expats
- Check your statements: If you held a Portuguese current account, a mortgage or a consumer credit line at any point in the past five years, ask your bank in writing whether you fall inside any 2025 restitution determination. The bank does not always notify proactively; an email to the Provedor do Cliente is the fastest route.
- Account closure friction: The 54.9% jump in closure complaints matches a wave of frustration from expats trying to wind down accounts on relocation. Send the closure request in writing, retain proof of receipt, and escalate to the BdP Portal do Cliente Bancário if your bank stalls past the contractual notice window.
- Fraud disputes are rising fast: If you authorise a transfer under social-engineering pressure and only realise afterwards, you have a narrow window to file with both your bank and the PJ's cybercrime unit. The 45% rise in disputes shows the regulator is taking these complaints more seriously than two years ago.
- Five-year look-back: The restitution window covers transactions back to 2020. Old account statements from a bank you've since closed remain relevant — request a historic extract before throwing anything away.
The 2025 report continues a pattern in which the BdP recovers an average of more than €13 million a year for retail clients across the last three years, even before accounting for the 2024 outlier case. Affected clients can check the BdP's Portal do Cliente Bancário for the published determinations and standard complaint templates. The broader supervisory environment also sits alongside this week's Segurança Social Direta two-factor rollout and the BdP's wider authentication push.
