Portugal's Insurance and Pension Funds Supervisory Authority published a consolidated version of its rules on market conduct and complaints, setting out how insurers and pension fund management entities must organise customer treatment and complaint handling and how the authority itself processes complaints about supervised entities in Portugal. The framework expands key conduct and complaints-management requirements to pension fund management activity and, in some cases, to cross-border occupational pension institutions, and applies to activity carried on in Portugal by ASF-supervised entities including insurance intermediaries. It requires board-approved customer treatment and complaints procedures, a designated central complaint-handling function with recordkeeping, and written responses to complainants within 20 business days, with access to an ombudsman where eligibility conditions are met. Within governance arrangements, firms must assign board-level responsibility for market conduct, establish an autonomous market conduct function (which may be combined with the complaints function in proportionate cases), and subject conduct-related policies and controls to periodic internal audit review with reporting to ASF. The rules also introduce structured supervisory reporting, including annual complaints reporting by the end of February, quarterly behavioural reporting (including information on highly automated or digitally dependent processes), and website disclosure via a dedicated customer-facing market conduct section. For complaints submitted to ASF, the rules require prior submission to the supervised entity and prefer submission through ASF’s consumer portal, with the supervised entity generally given 15 business days to respond to ASF requests and ASF aiming to conclude analysis within 90 business days. The text sets phased application provisions, including entry into force 30 days after publication, a six-month period to implement the governance and website requirements, and specified start points for certain reporting obligations (including quarterly behavioural reporting from 30 April 2024).
Portuguese Insurance Regulator (ASF) 2025-07-17
Portugal's Insurance and Pension Funds Supervisory Authority publishes a consolidated market conduct and complaints handling rulebook for insurers and pension fund managers
Portugal's Insurance and Pension Funds Supervisory Authority (ASF) released a framework on market conduct and complaints management for insurers and pension fund managers. The rules extend to cross-border occupational pension institutions and require board-approved procedures, a central complaint-handling function, and structured supervisory reporting. Firms must assign board-level responsibility for market conduct and ensure periodic internal audits, with phased implementation provisions for governance and reporting requirements.