Press Release 12/2026
July 20, 2026
The Portuguese Competition Authority (AdC) has issued 17 recommendations to the legislator and the Banco de Portugal aimed at reducing search, comparison and switching costs in the Portuguese retail banking sector. The final version of the Study includes a new recommendation inviting the Banco de Portugal to consider publishing a multiannual strategy for open banking and open finance in Portugal, setting out monitoring objectives, public indicators and periodic review mechanisms.
The Study, Consumer Mobility in Retail Banking in Portugal, prepared by the AdC, identifies barriers that may affect consumers' ability to make informed choices and limit banking mobility, and puts forward recommendations designed to remove those barriers, improve competition in the market and strengthen consumer choice.
The ability of consumers to search for information, compare offers and switch providers whenever they wish, in a simple, secure and informed manner, is an important condition for effective competition in retail banking. It increases competitive pressure on financial institutions, promotes efficiency in the sector and helps ensure better outcomes for consumers.
Public consultation
The draft Study was subject to a public consultation between 13 February and 5 March 2026.
As part of the consultation, the AdC received the opinion of the Banco de Portugal, as well as contributions from three representative associations of the financial sector and from two consumers or consumer representative organisations. These contributions reflected different perspectives on the issues examined and were taken into account in the revision and further development of the Study's findings and recommendations, as detailed in the public consultation report.
Following the public consultation, the AdC introduced a new recommendation addressed to the Banco de Portugal, proposing that it consider publishing a multiannual strategy for open banking and open finance in Portugal, covering, in particular, information aggregation services. The strategy should include monitoring objectives, public indicators and periodic review mechanisms, supported by information collected from supervised institutions and other relevant stakeholders.
The AdC also refined two recommendations contained in the draft Study (Recommendations 6 and 15 of the final version), in the light of the contributions received during the consultation.
The draft Study was prepared following a market consultation on retail banking conducted by the AdC between 22 July and 24 September 2025. Overall, the contributions received pointed to the existence of barriers likely to affect consumers' ability to choose and to limit banking mobility.
The Study
The Study focuses on assessing the conditions for searching, comparing and switching payment accounts, as well as savings and credit products, from the perspective of individual consumers. On the basis of this assessment, it sets out 17 recommendations addressed to the legislator and the Banco de Portugal.
The Study identifies difficulties in searching for and comparing banking products. According to a consumer survey commissioned by the AdC, around 69% of respondents had not sought information on current accounts offered by other banks during the previous five years. This finding is particularly relevant, as the Study estimates that searching for alternative offers increases the likelihood of switching banks by around 7.2 percentage points. At the same time, the take-up of the payment account switching service established under the legal and regulatory framework remains very limited.
The barriers identified are particularly significant in the context of the long duration of customer-bank relationships and relatively low levels of financial literacy, both of which tend to increase search and switching costs and reduce consumers' willingness to compare offers and change providers.
Credit intermediaries can play an important role in assisting consumers. However, this potential is constrained by consumers' limited awareness of the nature and scope of the services provided, particularly where intermediaries act on behalf of lending institutions.
To reduce search, comparison and switching costs, the AdC puts forward a set of 17 recommendations addressed to the legislator and the Banco de Portugal.
Recommendations
The AdC recommends that the legislator:

1. Strengthen the harmonisation of terminology by identifying terms that are relevant to consumers and developing standardised definitions.

2. Ensure that Directive (EU) 2023/2225 is transposed into national law as soon as possible.

3. Reform the payment account switching service so that it is centrally managed by an independent entity.

4. In cases of early repayment of credit agreements: for variable-rate loans, abolish the possibility of charging an early repayment fee; for fixed-rate loans, set a maximum fee based on the remaining duration of the agreement.

5. Require credit intermediaries to provide clear information on their remuneration policy and on the credit institutions with which they work.

6. Ensure that the remuneration of tied credit intermediaries and ancillary credit intermediaries is subject to the limits already applicable to staff providing advisory services.

7. Ensure that the pre-contractual terms made available by lenders through credit intermediaries are no less favourable to consumers than those that would be offered if consumers approached lenders directly.
   The AdC recommends that the Banco de Portugal:

8. Strengthen the functionality and information provided by the Fees Comparator.

9. Consider extending the scope of the Fees Comparator to savings products.

10. Consider publishing a multiannual strategy for open banking and open finance in Portugal, covering, in particular, information aggregation services, with monitoring objectives, public indicators and periodic review mechanisms, supported by information collected from supervised institutions and other relevant stakeholders.

11. Require banks to provide consumers with a standardised information sheet setting out the most relevant information on mortgage credit.

12. Define indicators to measure consumer awareness of and satisfaction with the payment account switching service, together with annual targets for credit institutions.

13. Assess the costs and benefits of extending the scope of the payment account switching service to include the temporary redirection of payments and the transfer of fixed-term deposit accounts and savings accounts.

14. Assess the costs and benefits of introducing national bank account identifier portability solutions.

15. Require credit intermediaries to inform consumers of the number of offers obtained the identity of the institutions that submitted them and the criteria used to select the offers presented.

16. Assess the costs and benefits of introducing time limits on requirements linked to the purchase of ancillary banking products or services.

17. Define information requirements applicable to package accounts and bundled offers, including the possible introduction of a standardised indicator of the total cost of bundled offers.