Country _ Name
Trading platforms / social trading platforms / signal following
FinTechs belonging to this category operate trading platforms or online marketplaces for investment opportunities or certain financial contracts – e.g. securities, factoring etc. and sometimes furthermore provide contact to financial experts and tools for the decision-making.

FinTech-signalling and social trading platforms provide users with the opportunity to exchange opinions on financial investments and offer signal providers and traders the possibility to make their securities portfolio publicly visible. This way the portfolios can be linked to and followed by other traders via the platform automatically, so that the trading and investment strategy of the followed traders can be copied.

The platform often cooperates with a financial services provider or a credit institution where both the trader and the follower hold their securities accounts, and which execute the orders both of the trader and the follower and to which the platform passes on the trading decisions.


Attitude of the country towards trading, social trading or signalling platforms

In recent years, the investment banking sector has seen the emergence of white label outsourcing agreements with BaaS international players (e.g. Saxo, CMC, Interactive Brokers, Allfunds, Deposit Solution) for the deployment of platforms offering brokerage services by authorised investment firms (trading platforms, smart order routing, deposit distribution platforms etc.). Social trading and signalling platforms mainly operate in Portugal via cross-border.

Legal affairs

Obligations and requirements to provide trading, social trading or signalling platforms described above

Reception and transmission of orders, portfolio management and financial advice are deemed an investment service under the Portuguese Securities Code. The provision of investment services, either in the internet or by other media, is subject to an authorisation from CMVM. Authorisation requirements rely on the company’s capital structure, information on the shareholders, corporate governance, material/technical and human means, internal control/compliance, and risk management mechanisms, among others. Please refer to our answer to the previous number.

Outsourcing agreements for the externalisations of IT infrastructure, particularly to cloud services providers, by investment firms are also subject to regulation, and in certain cases, to previous disclosure to the CMVM.

Algorithmic trading is subject to operational requirements under MIFID and complementary regulation.

In our view, if the lead trader in social and signalling platforms merely discloses to the public those investment strategies to be followed, he is not providing personalised investment advice (required to be qualified as financial advice) nor receives a mandate for the exercise of discretion in the best interests and on behalf of the asset holders (as required in portfolio management). The CMVM did not issue guidelines on the matter, and a case-by-case analysis is recommended.

Additional comments regarding the legal situation for trading, social trading or signalling platforms or what FinTech’s must be aware of in this business area

The New Regime applicable to investment firms entered into force on 1 February 2022 and new regulation is expected by CMVM. The New Regime simplified the applicable regulation to the investment firms, unified the several investment firms and appointed CMVM as the sole supervisor, which is expected to enhance the investment services market. Albeit this time of change CMVM is accepting authorisation requests and available to assist applicants with queries around the application process.  

Economic conditions

Market size for trading, social trading or signalling platforms and biggest compani

es in this business area All major investment banks or banks performing investment services operate trading platforms, allowing for algorithmic trading. Social and signalling platforms are still at an early stage and are covered mainly by foreign operators acting cross-border. 

Additional comments regarding the economic situation for trading, social trading or signalling platforms or what FinTech’s must be aware of in this business area

Trading, social trading and signalling platforms’ activity is expected to grow in the near future.



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