Reporting Obligation: Investment Advice

The CMVM has put forward a draft regulation for public consultation that establishes a regular reporting obligation regarding investment advisory activities. The aim is to provide the regulator with comprehensive and comparable information to support market conduct supervision, strengthen investor protection and monitor the market.

The consultation documents can be found on the CMVM website.

Who is covered

Investment firms; credit institutions; management companies of collective investment undertakings; venture capital firms authorised to provide investment advice; self-employed investment advisers; and branches carrying out this activity in Portugal.

What must now be reported

The information is submitted in aggregate form, based on six elements that characterise the activity for the quarter:

• The type of service provided must be specified, distinguishing between ongoing advice (with periodic suitability assessment) and one-off advice.
• Advisory model: independent or non-independent.
• Client categories: retail, professional or eligible counterparty.
• Number of clients who received investment proposals during the period.
• Number of investment proposals submitted during the period. Each advisory report counts as one proposal, regardless of whether it is executed.
• Amount reported according to the type of service. If the consultancy is ongoing, the total amount under advisory at the end of the quarter is reported. If the consultancy is one-off, the total amount of investments advised during the quarter is reported.

Reporting frequency and deadlines

Reports must be submitted quarterly. Submissions must be made by the tenth working day of the month following the end of the quarter to which the information relates. If there has been no activity in a given quarter, a 'nil' report must be submitted so that the regulator can distinguish between inactivity and failure to report.

Technical aspects

Submissions must be made in a standardised XML file identified as 'CST...XML'. The CMVM provides technical schemas for automatic validation and integration with internal systems.

Entry into force and transitional arrangements

The regulation is proposed to come into effect on 1 July 2026. The first report under the new obligation must be submitted by 15 July 2026 and cover the first two quarters of 2026, with reference to 30 June 2026. From then on, the normal quarterly cycle applies.

Consultation process

The consultation period is open until 17 April 2026. Contributions can be submitted by email (editable PDF format) to consultapublica1_2026@cmvm.pt or by post.

The CMVM intends to publish the contributions received, unless the respondent expressly indicates otherwise.