Banco de Portugal Tightens Bank-Complaint Response Window to 15 Working Days Across Every Channel — Carta Circular Closes the Old 15-vs-20-Day Asymmetry

The Banco de Portugal has unified the maximum response time for retail bank complaints at 15 working days, regardless of whether the complaint enters via the Livro de Reclamações (paper or electronic version) or directly through the supervisor's own channel. A carta circular released by the regulator on Friday 22 May 2026 — and picked up the same evening by ECO, Observador and RTP — overwrites the previous regime, which let banks take up to 20 working days when consumers complained directly to the supervisor and only 15 working days when the same complaint travelled the complaints-book path.

What the Carta Circular Changes

The new instrument levels every channel. Banks now have a single statutory clock — 15 working days — to respond to any complaint, whether it lands via the Livro de Reclamações Eletrónico, the paper version still maintained at branches, the Portal do Cliente Bancário, or a direct submission to the Banco de Portugal. The response itself must do two things the carta circular makes explicit: state whether the bank considers there was a breach of obligations, and, if it acknowledges one, identify the corrective measures taken or scheduled. A second clock applies upstream: if the Banco de Portugal asks the bank for additional data to analyse a complaint, the institution has five working days to supply it. The supervisor framed the move as a behavioural-supervision tightening that closes a gap consumers had been routinely arbitraging — filing through the slower channel without recourse — and as part of the convergence with EU-level retail-investor protection standards.

The Volume the New Window Has To Clear

The compliance load is not trivial. In 2025, the Banco de Portugal logged 33,375 complaints against banks, payment-services providers and intermediaries — a 2.3% decrease on 2024 but still the second-highest annual reading on the supervisor's series. Of those, 22,795 fell inside the BdP's direct competency. The mix concentrates around the consumer-banking core: deposits carried 32% of the file, consumer credit another 27%, credit transfers 11%, payment cards 11%, and mortgage and housing credit 10%. Together those five categories absorb more than 90% of the complaint book and define where the 15-day clock will bite hardest. Banks that have run the complaints-book path on the older 20-day track now have to absorb a five-day acceleration on the heaviest file in their consumer-conduct queue.

Why the Asymmetry Existed and Why It Goes Now

The old split was an accident of layered regulation. The Livro de Reclamações regime, run jointly by DGC and the sectoral supervisors, ran on the 15-day rule that applies across regulated sectors. The direct-BdP complaint route was governed by the supervisor's own internal procedural rules, which carried the longer 20-day deadline as a residual from the pre-Livro Eletrónico era. With the Portal do Cliente Bancário now routing the bulk of digital complaints inside a single workflow, and with the EU Retail Investment Strategy revisions tabled through 2025 pushing supervisors toward harmonised consumer-conduct timeframes, the BdP framed the carta circular as the natural unification of two windows that had outlived the rationale that produced them.

What This Means for Expats

One clock now, whichever channel you use. Whether you file through the Livro de Reclamações Eletrónico at livroreclamacoes.pt or directly through clientebancario.bportugal.pt, the bank has the same 15 working days to respond. Routing choice no longer affects the deadline.
The response has to be substantive. Look for the carta circular's two-part test: did the bank acknowledge or deny a breach, and, if it acknowledged one, what remedial step has it logged? A response that ducks either limb is non-compliant.
Top complaint category. With deposits, consumer credit, credit transfers, payment cards and mortgage credit accounting for 90%+ of the supervisor's file, expats opening a Portuguese current account should know the system the regulator is now policing tightly: rejected SEPA transfers, undisclosed card fees and frozen-deposit disputes are exactly the file the 15-day window is designed to flush.
Escalation path. If the bank misses the 15-day window or returns a non-substantive response, the next step is a direct filing with the Banco de Portugal at clientebancario.bportugal.pt. The supervisor can fine non-compliant institutions; the consumer's path is the same regardless of the original complaint route.