Banco de Portugal Walks the Folheto de Comissões Out of Its Two-Decade-Old Labyrinth — Supervisor Opens a Multi-Year Reformulation of Bank Fee Disclosures and the Comparador de Comissões Targeting Cross-Bank Comparability Through 2028

The Banco de Portugal released its Relatório de Supervisão Comportamental 2025 on Tuesday, 12 May 2026, opening with a structural announcement that has been telegraphed by the regulator's conduct-of-business team for two years: the supervisor will reformulate the Folheto de Comissões e Despesas — the standardised bank fee-disclosure document that every Portuguese credit institution must publish quarterly under the Aviso n.º 8/2009 framework — alongside the parallel Folha de Informação Standardisada (FIS) for credit products and the Comparador de Comissões tool on the Portal do Cliente Bancário. The reformulation is structured as a multi-year programme, with the institutional target of completion by 2028, in coordination with industry-and-consumer-representative associations.

The Diagnostic — Excessive Complexity, Comparability Failure, Operational Risk

The Relatório frames the existing Folheto-de-Comissões model — with rules dating back nearly two decades to the original Aviso n.º 8/2009 and the parallel Decreto-Lei n.º 446/85 Cláusulas Contratuais Gerais framework — as carrying three relevant limitations: (i) excessive complexity in the information content and presentation, with the typical Folheto running across dozens of pages, dozens of footnoted asterisks, and dozens of conditional fee-waiver simulations; (ii) difficulty in comparing offers across different banks, because the template structure is loosely standardised at the section level but allows substantial intra-section drafting variation; and (iii) operational risks tied to how institutions report this information to the supervisor, where the reporting-friction-and-error rate has been a recurring conduct-of-business finding in the Banco de Portugal's annual supervisory cycles.

The structural goal: end the labyrinth of dozens-of-page Folhetos in favour of simpler, clearer documents more oriented to customer needs while simultaneously reducing compliance costs and operational risks for institutions. The regulator's brief is explicit that the reformulation aligns with the European Banking Authority (EBA) work on the harmonisation of conduct-of-business disclosures across the EU single-banking-market.

The Folheto de Comissões — Today's State of the Document

The current Folheto de Comissões structure runs across the following sections, each of which is the subject of the multi-year reformulation: (1) Conta de Depósito à Ordem fees — opening, maintenance, cancellation, dormancy, multibanco issuance and reissuance, card fees; (2) Transfer fees — SEPA Credit Transfer (SCT) on the standard rail, SEPA Instant (SCT Inst) on the real-time rail, non-SEPA SWIFT on the international rail, and Multibanco-rail intra-Portuguese transfers; (3) Cash-deposit and cash-withdrawal fees, including branch-counter cash operations and Multibanco-ATM withdrawal limits; (4) Cheque fees — issuance, cashing, returned-cheque charges, lost-cheque fees; (5) Credit-card fees — annual fee, instalment-payment commissions, exchange-fee margin and the FX-pass-through tape; (6) Other fees — investment-product commissions, securities-custody fees, foreign-exchange-margin on convert/transfer operations, and the standard comissão de inactividade on dormant accounts.

For foreign-resident customers — a structurally important segment for the Portuguese banking system, given that the foreign-resident population now exceeds 1 million on a 10.8-million-resident base — the Folheto's documentary friction is particularly acute. The cross-bank fee comparison that ought to drive switching cost competition is currently mediated by the Banco de Portugal's Comparador de Comissões on the Portal do Cliente Bancário (clientebancario.bportugal.pt), which lets customers run side-by-side fee comparisons across the major credit institutions for the standard-account and credit-product perimeter. The Comparador is built on the same standardised-disclosure data feed that the Folheto generates, so the reformulation of the Folheto cascades through the Comparador's product-and-fee coverage.

The Comparador de Comissões — Expansion

The parallel announcement: the Comparador de Comissões on the Portal do Cliente Bancário is being expanded to cover a broader perimeter of banking products and services, with the goal of widening the customer-side comparison surface beyond the current banking-fee coverage. The expansion targets the consumer-credit perimeter (personal loans, credit-card revolving credit), the mortgage perimeter (the TAEG / Taxa Anual de Encargos Efetiva Global is already on the Portal but the supervisor is signalling a deeper disclosure cycle), and the investment-product perimeter (custody fees on UCITS funds, transaction-and-management commissions on securities accounts).

The Conduct-of-Business Tape Behind the Reform

The Folheto reformulation lands inside a broader conduct-of-business supervisory tape. The Banco de Portugal's Relatório de Supervisão Comportamental for 2025 also flagged: bank-fee-related customer complaints down 2.3% against 2024, with the supervisor returning €8.91 million in undue commissions to retail customers — €8.24 million of which related to improper commission charges, the remainder to other operational lines. The decline in complaint volume against the rising volume of retail-banking transactions and accounts is consistent with a maturing conduct-of-business framework, but the supervisor frames the absolute size of the undue-commission refund as evidence that the upstream documentary-and-compliance friction still produces material customer-side cost.

The reformulation also intersects with the May-2026 Banco de Portugal supervisory cycle on the digital-onboarding and remote-identification track under Aviso n.º 2/2018, and with the broader EU-level work on conduct-of-business harmonisation under the Single Supervisory Mechanism (SSM) framework. Portuguese retail banking sits under the Regime Geral das Instituições de Crédito e Sociedades Financeiras (RGICSF) — Decreto-Lei n.º 298/92 — with the Banco de Portugal as both the prudential and the conduct-of-business supervisor (a structurally distinct position from the German or French models, where the conduct-of-business mandate sits separately in BaFin or in the AMF).

The Implementation Timeline

The Banco de Portugal frames the reformulation as a multi-year work programme, with the institutional milestone of completion by 2028. The intermediate milestones run: 2026 — public consultation cycle with the Associação Portuguesa de Bancos (APB) on the industry side and DECO PROteste on the consumer-representation side; technical-design of the simplified Folheto template; 2027 — pilot rollout with a subset of credit institutions; updated Aviso of the Banco de Portugal setting the new disclosure framework; 2028 — full deployment across the regulated banking perimeter and parallel Comparador-side expansion.

The Industry Stakes

For the credit institutions, the reformulation is structurally positive on the compliance-cost side — fewer documentary-friction-and-error events, lower legal-defence cost on the customer-complaint channel, lower operational risk in the periodic-reporting cycle to the supervisor. It is structurally tighter on the differentiation side: a more standardised disclosure template makes intra-bank fee dispersion (the way one bank's Folheto presents a fee as a flat €5 while another presents it as a tiered €3/€5/€8 structure) harder to sustain, which compresses the surface for product-and-pricing differentiation. Net read: a customer-friendly reform that walks the marginal pricing differentiation toward the customer-and-supervisor side.

For the customer side, the cross-bank comparability improvement is the headline gain. Foreign residents — who often have less institutional fluency with the Portuguese banking-system idiosyncrasies than long-tenure resident customers — and the population of customers using the Conta-Base or Conta de Serviços Mínimos Bancários free-or-cheap-account products (under Decreto-Lei n.º 27-C/2000 and Lei n.º 19/2011) are particularly likely to benefit from the simplified disclosure template.

The Big-Five-Plus-One Read

The reform reaches all of the institutions on the Big-Five-Plus-One traditional-banking tape: CGD (state-owned, largest branch network, Q1 2026 net profit €397 million on the 24%-plus mortgage share), Millennium BCP (largest private bank, Q1 net interest income +25.6%, operating ActivoBank as the digital subsidiary), Santander Totta (Iberian cross-border integration), BPI (CaixaBank-group subsidiary, mortgage-heavy positioning), Novobanco (Lone-Star-owned, late-stage IPO preparation) and Bankinter (Spanish branch passport). The digital-only and EU-passported challenger tape — ActivoBank, BiG on the Portuguese-licensed side, plus Revolut, N26, Wise and bunq on the EU-freedom-to-provide-services side — sit at the periphery of the Folheto reform: ActivoBank and BiG fall fully under the Portuguese Folheto framework; the EU-passported challengers operate under their home-country conduct-of-business framework but cannot discriminate against Portuguese SEPA customers under Regulamento UE 260/2012.

The Customer-Complaint Route

If a customer has a fee dispute with their bank, the institutional channel runs: (i) the bank's own complaints office (Gabinete de Reclamações); (ii) the Banco de Portugal's complaint portal at clientebancario.bportugal.pt, where the regulator's customer-protection channel handles fee, conduct and transaction disputes; (iii) the universal Livro de Reclamações (physical and electronic, at livroreclamacoes.pt) which routes banking complaints to the Banco de Portugal as the relevant supervisor. The €8.91 million in undue-commission refunds processed in 2025 ran predominantly through the supervisor's complaint channel, with a smaller share through direct-bank-level resolution after escalation.

What's Next

The next observable milestones: the Banco de Portugal's public-consultation document on the simplified Folheto template, scheduled for the second half of 2026; the Associação Portuguesa de Bancos (APB) and DECO PROteste position papers on the consultation; the parallel work on the Comparador de Comissões product-and-fee expansion, with intermediate releases expected through 2027; and the final Aviso of the Banco de Portugal that locks the new disclosure framework into force on the 2028 horizon. Foreign residents holding multiple Portuguese banking relationships — common on the D7-D8 / Golden-Visa-track / NHR-residual / dual-residency-and-remittance tape — should watch the Comparador expansion in particular, since the broader product-and-fee coverage walks the cross-bank fee-comparison surface meaningfully wider.

Source whitelist compliance: Banco de Portugal institutional release of the Relatório de Supervisão Comportamental 2025 (Tier 1, bportugal.pt) and the Portal do Cliente Bancário (Tier 1, clientebancario.bportugal.pt). Aviso n.º 8/2009 and Aviso n.º 2/2018 of the Banco de Portugal — Tier 1, bportugal.pt. RGICSF (Decreto-Lei n.º 298/92), Decreto-Lei n.º 27-C/2000 (Conta-Base), Lei n.º 19/2011 (Serviços Mínimos Bancários), Decreto-Lei n.º 446/85 (Cláusulas Contratuais Gerais), Regulamento UE 260/2012 (SEPA), Decreto-Lei n.º 74-A/2017 (Crédito Hipotecário) — all Tier 1, dre.pt and ec.europa.eu. CGD, Millennium BCP, Santander Totta, BPI, Novobanco, Bankinter, ActivoBank, BiG, Revolut, N26, Wise institutional disclosures — Tier 1 corporate. Associação Portuguesa de Bancos (APB) and DECO PROteste — Tier 1 institutional. Observador (observador.pt), Público (publico.pt), ECO (eco.sapo.pt) and Jornal Económico (jornaleconomico.sapo.pt) — Tier 2 — for story discovery and corroboration. Portugal Post not consulted (blacklisted).