Storm Kristin Credit Moratorium Lapses 28 April — BdP's Five-Business-Day Rule, the PARI Default-Prevention Framework, and Where 7,400 Borrowers Stand on €930 Million of Suspended Credit

The emergency credit moratorium opened in late January for households and companies in the municipalities placed under a state of calamity after Storm Kristin — and extended to cover the subsequent storms Leonardo and Marta — runs out at midnight on Tuesday, 28 April 2026. Banco de Portugal data, presented to MPs at the COFAP commission on 21 April and re-published this week, puts the take-up at 7,400 borrowers on roughly €930 million of outstanding credit. From Wednesday morning every one of those contracts is back on the regular instalment schedule, and the May payment will hit the account on the contractually agreed date.

The instalment that lands will, in many cases, be slightly larger than the one that was suspended in late January. Where banks capitalised the interest that accrued during the 90-day pause — the standard mechanic for moratorium products — the principal has grown and the contract has been automatically lengthened by the suspension period. The supervisor was direct in its 27 April statement: where interest was capitalised, “o montante em dívida pode, agora, ser superior”.

The Five-Business-Day Rule

The first thing borrowers under the moratorium need to know is that the supervisor's expectation of banks runs in the opposite direction from the customer's instinct. Banco de Portugal's recommendation is that lenders should have already contacted any client who looked at risk of falling behind “até cinco dias úteis antes do seu termo” — within five business days of the moratorium expiry — with a concrete proposal designed to avoid default. That window closed on Friday 24 April. If a borrower with payment difficulties has not heard from the bank by 28 April, the obligation flips: the customer must call.

The proposal regulators expect to see, where it has not already arrived, falls inside the PARI framework — the Plano de Acção para o Risco de Incumprimento that has governed Portuguese mortgage default-prevention since 2012. PARI is not a programme the borrower opts in to. It is a process the bank is legally required to run for every client whose credit file shows a forward-looking risk of non-payment. The bank reviews the household's income and debt profile, presents a proposal, and the customer has 15 days to accept, counter-propose or reject.

What the Bank Can Offer

The supervisor lists four standard restructuring instruments the bank can put on the table without raising the contracted interest rate:

• A capital grace period — the borrower pays interest only for an agreed window, usually six to twelve months, and resumes full instalment service afterwards.
• A capital and interest grace period, which is effectively a fresh moratorium negotiated bilaterally between borrower and bank rather than legislated by the State.
• A partial deferral of capital to the end of the contract, so the monthly instalment shrinks for the remaining term and a balloon payment sits at maturity.
• An extension of the contract term — the most common lever, and the one that most reduces the immediate monthly bill at the cost of total interest paid.

Banco de Portugal flags a point that gets buried in the conversation: every one of these levers reduces the monthly instalment, and every one of them increases the total cost of the credit over its life. The supervisor uses the wording “estas soluções podem ajudar a evitar o incumprimento, mas é importante ter em conta que (...) o custo total do crédito aumentará.”

A Possible Extension

Two layers of policy uncertainty remain in play. First, the Government has not gazetted an extension of the moratorium itself. Lusa reported on 27 April that the Council of Ministers is preparing a moratorium extension to be announced “at the end of this week or the start of next week”, with the perimeter — households only, businesses only, or both — still being negotiated. Until that diploma is published, the legal regime in force is the one expiring Tuesday.

Second, the supervisor has stressed throughout the moratorium that its end is not an automatic trigger for non-performing classification. A client who renegotiates inside PARI does not have the loan flagged as default, and the supervisor has been telling banks to absorb the operational load of the case-by-case review rather than push borrowers into the more punitive PERSI regime — the Procedimento Extrajudicial de Regularização de Situações de Incumprimento — which only applies once a payment has actually been missed.

The Numbers in Context

The €930 million headline is large in absolute terms but contained in proportion. Banco de Portugal vice-governor Clara Raposo told COFAP last week the moratorium covers under 1.5% of housing credit and roughly 4% of business credit in the affected regions. Sixty per cent of the 7,400 applications came from companies — overwhelmingly small and medium-sized exporters whose plants, fields or logistics chains were disrupted. The household share, at 40%, is concentrated in the centre and north-west municipalities that took the worst storm damage.

The credit-quality readings on the moratorium portfolio are “slightly worse” than the average outside it, Raposo said — a flag that some share of those 7,400 contracts will not survive the May payment without restructuring. The cleanest indicator the supervisor will watch is the proportion of moratorium clients who, by the end of June, are either current on the new instalment, inside a PARI proposal, or already in PERSI.

Where Borrowers Can Get Help

For households without a bank-side proposal in hand, the RACE network — the Rede de Apoio ao Cliente Bancário — operates a free national counselling service on banking-credit difficulties, with a list of accredited entities maintained on the Direção-Geral do Consumidor's Portal do Consumidor. RACE staff cannot renegotiate a contract on the borrower's behalf, but they walk the client through the PARI process, prepare the supporting income and expense documentation, and identify which of the four restructuring instruments fits a given household's profile. Banco de Portugal's Portal do Cliente Bancário hosts the standard FINE / FIN documentation and the model letters PARI requires.

The wider Storm Recovery Plan, signed off by the Council of Ministers earlier this month and tracked through Paulo Fernandes' weekly disbursement readouts, is the longer-term backstop. As of last week, €2 billion of the €3.5 billion envelope had reached households and firms, but only 3,000 of 36,000 housing-aid files had been paid. For the moratorium-using households whose homes were physically damaged in January, the timing of those housing payouts will largely determine whether May's instalment is a one-off bump or the start of a deeper conversation with the bank.