The new credit assignment and management regime

The Credit Assignment and Management Regime (RCGCB), approved by Decree-Law No. 103/2025 of 11 September, and Banco de Portugal Notice No. 6/2025 entered into force yesterday.

This new legal framework implements Directive (EU) 2021/2167 and establishes the rules governing the assignment and management of banking credits in Portugal.

The regime aims to stimulate the secondary credit market, particularly in the non-performing loanssegment, and to ensure that debtors’ rights remain safeguarded even after credits are transferred by lending institutions.

Notice No. 6/2025 sets out the operational aspects of the regime, namely:

• The procedures and criteria for the authorisation of credit servicers;
• The elements that must accompany the authorisation request;
• The rules on registration and updates; and
• The communications relating to activity in other Member States and to subcontracting.

As of yesterday, authorisation requests must be submitted through SIRES, using the electronic form made available by Banco de Portugal.

The entry into force of this regime represents a significant development for the sector, reinforcing governance, transparency and debtor-protection requirements applicable to credit servicers.

Credit securitisation funds, their management companies and credit securitisation companies, as potential purchasers and holders of portfolios of banking credits, will need to assess and adapt their contractual frameworks, governance structures and compliance models to this new framework, ensuring alignment with the RCGCB and with Directive (EU) 2021/2167.

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