CMVM publishes annual 2025 financial intermediation circular

The Annual Financial Intermediation and Crowdfunding Circular (Circular 003/2025) establishes supervisory priorities and regulatory measures for the sector in 2025.

The document emphasizes enhanced protections for non-professional investors—particularly in the digital context—and stresses the need for transparency in marketing financial products. It ensures intermediation practices align with investors’ interests.

The Portuguese Securities Market Commission (“CMVM”) will increase its supervision of financial instrument marketing to retail investors, focusing on practices that may mislead them.

Key measures:

• Increased supervision of financial product advertising and marketing, ensuring clear and balanced commercial messages that do not create unrealistic expectations.
• Supervision of so-called “finfluencers” and promotional content on social networks, ensuring compliance with legal transparency obligations.
• Monitoring the impact of digital platforms on investor decision-making, analyzing their influence on users’ financial choices.
• CMVM’s Financial Literacy Plan 2025, aimed at helping investors identify fraud, understand crypto-assets, and assess the risks of digitally promoted financial products.
• Enhanced efforts to combat unauthorized financial intermediation through more effective alert mechanisms.

• Crowdfunding and investor protection

The CMVM will strengthen its supervision of crowdfunding service providers (“CFSPs”) to ensure:

1. platforms provide transparent and adequate information to investors;
2. financing projects do not lead investors to take disproportionate risks; and
3. stricter monitoring of reporting obligations and compliance with risk communication duties. 

• Advertising and digital marketing supervision

The CMVM will focus on digital investment platforms to verify:

1. marketing strategies comply with CMVM and ESMA guidelines;
2. entities do not promote unrealistic earnings expectations; and
3. costs and fees are clearly presented to investors.  

• Cybersecurity and operational resilience

The CMVM will monitor the implementation of the new cybersecurity rules for financial intermediaries and CFSPs, assessing their:

1. ability to respond to cyber incidents; and
2. management of technological risks associated with digital service providers.

• Anti-money laundering (“AML”) and counter-terrorism financing (“CTF”)

The CMVM will intensify its supervision of AML and CTF on digital platforms to ensure:

1. entities comply with European Union customer identification and monitoring standards; and
2. transparency in transactions carried out on crowdfunding platforms.

In 2025, the CMVM will continue to strengthen its supervisory model in the financial intermediation sector, focusing on:

• enforcement actions targeting the digital marketing of financial products;
• transparency and clarity in disclosing risks to non-professional investors; and
• compliance with advertising rules and investment recommendations on social networks.