Banco de Portugal's 2025 Behavioural Supervision Report Walks Banks Into €8.91 Million of Customer Refunds — €8.24 Million in Indevidas Commissions, 3,298 Specific Determinations and 52 Contraordenação Proposals Across the Inspection Tape

Banco de Portugal's 2025 Behavioural Supervision Report — the annual file from Avenida Almirante Reis that aggregates every consumer-protection inspection, mystery-shopper visit and complaint-driven enforcement action the supervisor ran against the country's banks over the prior twelve months — lands on Tuesday 12 May 2026 with a headline that the political and consumer-defence circuits have been waiting for. Portuguese banks had to return €8.91 million to clients during 2025, the BdP confirms, broken down into €8.24 million of comissões cobradas indevidamente (commissions improperly charged) and €670 thousand of juros (interest) the same banks had wrongly taken from accounts they administer.

Where the €8.24 million in indevidas commissions came from

The supervisor's own classification splits the €8.24 million across four buckets. Violations linked to the price list — the public preçário each bank must publish and respect — produced €4.20 million in refunds, by far the largest line. Suitability-of-product issues, where a bank charged a fee that did not correspond to what the client had actually contracted, produced €2.11 million. Default-handling charges that breached the cap rules under the PARI/PERSI protocols accounted for €1.33 million. The residual €600 thousand sits in 'other reasons,' which the BdP uses for one-off enforcement matters that do not fit the three main families. The €670 thousand interest bucket is materially smaller but flags the same pattern: rate calculations that diverged from the contract, sometimes on consumer credit and sometimes on mortgage instalments.

The enforcement tape behind the refunds

The €8.91 million figure is the visible tip of a much larger enforcement file. The BdP issued 126 cartas de advertência to specific institutions, made 423 recomendações (formal recommendations to change a practice), and pushed 3,298 determinações específicas — the most coercive of the supervisor's non-judicial tools, because each one obliges a named bank to fix a named practice on a named timeline. Fifty-two proposals to open contraordenação proceedings — the BdP's administrative-criminal pathway, which can produce fines into the seven-figure range — were also lodged against financial institutions. The 2025 number sits broadly in line with 2024's pattern, though the contraordenação proposals tape is slightly above the prior year because the supervisor has been visibly tougher on cobranças in default cases.

The Folheto de Comissões reform that sits on top

The report lands at a moment when the BdP is already opening a multi-year reformulation of the Folheto de Comissões — the document each bank must give consumers explaining its fee structure — because Aviso 8/2009, the rule the folheto has run under since 2009, produces documents that run dozens of pages and have become functionally illegible. The reform was confirmed in a separate communication on Tuesday and runs through 2028, with the Comparador de Comissões on the Bank Customer Website (bportugal.pt/clientebancario) acting as the cross-bank price benchmark. The 2025 supervision file is the substantive evidence the BdP needs to push the redrafted preçário regime through: when €8.24 million of commissions get reversed in a single year because banks billed fees their own preçário did not authorise, the case for clearer disclosure writes itself.

How the supervision file changes consumer behaviour

The Portuguese banking complaints flow that feeds the BdP supervisor sits at roughly 12,000 to 14,000 entries per year across CGD, Millennium BCP, Santander, BPI, Novobanco and the smaller specialised institutions. Around 60% of complaints relate to commissions and to default-handling, the same two categories that produce the largest refund buckets in the 2025 report. The supervisor's standard escalation path runs: client complains to the bank, bank fails to respond satisfactorily within fifteen working days, client escalates to bportugal.pt/clientebancario, BdP opens a behavioural-supervision file. Tuesday's report is the cleanest signal yet that this pipeline produces visible recoveries for individual consumers — not just enforcement headlines.

Sources: Banco de Portugal Relatório de Supervisão Comportamental 2025, 12 May 2026; Público; ECO; Jornal de Negócios; Dinheiro Vivo.