The Bank of Portugal Puts a Minimum Font Size on Bank Adverts, and Rules That the Cost of Credit Cannot Hide Behind a Swipe
Nine points in the written press, ninety on a street mupi, measured on the capital letters. In digital, the TAEG has to sit in the same field of view as the offer it belongs to.
If a Portuguese bank advertises a credit card on Instagram, the annual cost of that card may not sit on the second slide of the carousel. The Bank of Portugal said so on Tuesday, in a practical guide that takes the advertising rules already binding on banks and works them through, example by example, into the places people actually see them.
The supervisor described the document as an effort to "support institutions and promote a more consistent application of the rules governing advertising in retail banking markets, contributing to clear, rigorous and transparent information for banking customers". The underlying rules are not new: the size table reproduced in the guide is Part I.A of the Annex to Aviso n.º 5/2024, already binding. What is new is the level of detail about how the regulator will read it. The guide runs to 45 pages and covers credit institutions, financial companies, payment institutions and electronic money institutions.
A minimum font size, measured in capital letters
The guide sets out how small the mandatory small print is allowed to be, and the answer depends on where the advertisement appears. In the press, leaflets and brochures, the floor is nine points. On websites, banners, apps, social media and email it rises to twelve. An indoor poster meant to be read inside the branch needs thirty points; one placed indoors but intended to be read from the street needs forty. An outdoor poster of up to 1.2 by 1.8 metres, which is the standard street mupi, needs ninety, and anything larger scales up in proportion.
Arial is the reference, but only as a yardstick. The guide is explicit that Arial is "merely indicative" and that an institution may use any other typeface, including one it owns, provided the text still reads properly and the characters match Arial's height at the size given. Worked examples show the comparison: Arial at 30 is equivalent to Calibri at 34, while Times New Roman at 30 does not qualify.
The measurement itself is defined narrowly. It should be taken from "the capital letters, without accents or cedillas, of the mandatory information", which closes off the argument that a descender or an accent could be counted towards the height.
Digital media get a further yardstick. Font size is to be judged at 100 percent zoom on the screen where the advertisement is being viewed, and the guide suggests institutions check their own work with a screenshot taken at that zoom level. In audiovisual advertising, characters must reach 3.5 percent of the screen height, which the guide puts at 38 pixels on a Full HD 1920 by 1080 screen.
The rule that bites hardest is about scrolling
A whole section of the guide deals with digital channels, and the principle running through it is that the cost of a product and the benefit being advertised have to appear in the same field of view.
The TAEG, the all-in annual charge figure that Portuguese law requires alongside any credit offer, is the usual test case. If a reader has to "click a button, turn the page, scroll down or perform any other action" to reach it, the Bank of Portugal says the advertisement does not meet the requirement. That is why a credit-card carousel cannot park the TAEG on the second image if getting there needs a swipe.
There is one carve-out, and it is a narrow one. Where the content advances on its own, as with an auto-playing carousel or a video, the requirement counts as met so long as the information follows immediately and the viewer has to do nothing to bring it up.
Why it matters to anyone banking here
Advertising rules of this kind are written for compliance departments, but they decide what a customer can see before signing. The pattern the regulator is trying to break is a familiar one: a headline rate or a cashback promise in large type, and the figure that tells you what the product really costs pushed somewhere that requires an extra gesture to find.
For newer residents, the TAEG is the number worth learning. It folds interest, commissions, insurance and other charges into a single annual percentage, which makes it the only figure that allows two credit offers to be compared honestly. Under the guidance published on Tuesday, a bank advertising in Portugal now has considerably less room to keep it out of sight.
