Banks Forced to Refund €8.9 Million in Improper Charges — BdP's Behavioural Supervision Logs 33,375 Customer Complaints, 51 Contraventions and a 45% Jump in Illicit Activity Cases

The numbers landed quietly on Friday: in 2025, Banco de Portugal forced the banks to return €8.9 million in improperly charged interest and commissions to their customers, opened 479 investigations into illicit financial activities — a 45% jump on 2024 — and applied €6.3 million in fines across 24 institutions in 51 separate contravention proceedings. The figures, drawn from the central bank's 2025 Behavioural Supervision Report and reported by ECO and the Jornal de Negócios, are the consumer-protection backbone the regulator wields independently of its monetary-policy mandate — and they spell out an active 2025 in which Portuguese banks were repeatedly found wanting.

A Complaint Volume That Keeps Growing

33,375 complaints reached Banco de Portugal against financial institutions over the year, of which 22,795 fell within its supervisory perimeter — the rest were redirected to the CMVM, the ASF or sectoral arbitration. Of those it processed, 6.3% showed indications of infraction. That's not the highest hit-rate the regulator has logged, but it sits on top of a clear upward trend in volume; the comparable 2023 number was 8.3 million euros refunded, and 2024 was inflated to €22 million by “a specific situation with one particular institution”, in the central bank's own euphemism. Setting that one-off aside, the 2025 number is materially above the 2023 baseline.

The Enforcement Toolbox

Banco de Portugal's behavioural arm does not just publish bad reviews. Across the year it issued 3,297 specific determinations, 418 recommendations and 124 warnings at 128 institutions. Where it found systematic breaches, it filed contraventions: 51 proceedings against 24 banks, with €6.3 million in fines imposed (€530,000 of which were suspended). Cumulatively, the regulator has clawed back more than €65 million in improperly charged commissions and interest from Portuguese banks since 2019. For a sector that booked record profits across the same period, the supervisory cost remains modest in absolute terms — but the public message is that the central bank's fiscalização comportamental is no longer a paper tiger.

Illicit Activity Investigations Surge

The most striking rise is in the parallel financial-crime workstream. Banco de Portugal launched 479 investigations into illicit financial activities in 2025, against 330 the year before — an increase of 149 cases, or 45%. Over half of those involved fraud schemes targeting Portuguese consumers: bogus investment platforms, IBAN-mismatch scams, deepfake-driven impersonation of bank executives, and a growing volume of WhatsApp-based social engineering. The supervisor's response includes the new beneficiary verification service introduced for SEPA transfers in early 2025, which the regulator credits with a 21% reduction in payer-manipulation fraud in its first five months compared to the same period of 2024.

Why It Matters for Expats

For foreign residents holding Portuguese bank accounts, the practical takeaway is that the route to redress is not theoretical. Disputed commissions, double-charged transfer fees, mortgage rate calculations that don't match the contract, and unauthorised standing orders are all in scope of the Banco de Portugal complaint book — known to most expats as the Livro de Reclamações. The 2025 numbers show that, in roughly one in sixteen processed complaints, the regulator agrees the bank was in the wrong. The €8.9 million returned to customers is the cumulative footprint of those individual decisions.

The full 2025 Relatório de Supervisão Comportamental will be available on the central bank's portal at bportugal.pt in the coming days.