Two neighboring markets with opposite approaches to sovereignty
Spain and Portugal are two payment markets that sit side by side on the map but differ in their domestic architecture. Both belong to the euro area, the EEA, and SEPA, so the same EU legislation governs them. Their national setups diverge on one question: how to keep control of retail payments. Each country answered it the opposite way. The usual label for southern Europe, a card market where some cash lingers, lumps the two models together without telling them apart.
Spain left acceptance to the international schemes and built its sovereignty on top of that layer. Its three domestic card networks merged in 2018 into a single national clearing house, and innovation moved to a credit transfer rail, Bizum, which runs on the SNCE. Portugal went the other way. As early as 1985, it built a single interbank network, Multibanco, operated by SIBS. The network handles cash withdrawals, in-store payments, bill payments, and a messaging service for payment claims. Visa and Mastercard offer nothing equivalent to that combination. The model is now tied up in litigation with Portugal's competition authority and with the central bank.
This difference in architecture determines what a merchant has to integrate in each country. In Spain, accepting international cards and Bizum covers most payments in the market. In Portugal, a merchant can integrate Visa, Mastercard, and the international wallets and still not accept Multibanco references or MB WAY. Portuguese consumers treat these two instruments as the normal way to pay, and no foreign payment method replaces them.
| Function | Spain | Portugal |
|---|---|---|
| Central bank and supervisor | Banco de España: licensing and supervision of PSPs, payment systems oversight, ICT authority under RDL 8/2023 | Banco de Portugal: PSP supervisor and operator of the SICOI retail clearing system |
| Retail clearing | SNCE, run by Iberpay (Sociedad Española de Sistemas de Pago), which is owned by its participants | SICOI, operated directly by the central bank, in separate subsystems |
| Domestic card clearing | SNCT (formerly STMP), run by Sistema de Tarjetas y Medios de Pago S.A., with technical support from Redsys and Cecabank | SICOI's “card-based payment transactions” subsystem, fed by the Multibanco network |
| Domestic scheme or network | Sistema de Tarjetas, created by the 2018 merger of ServiRed, Sistema 4B, and Euro 6000; it provides a rulebook, not acceptance of its own | Multibanco (SIBS, 1985): a single network of ATMs and POS terminals, plus payment references |
| Mobile / A2A solution | Bizum (Sociedad de Procedimientos de Pago S.L., 2016), overseen by Banco de España under the PISA framework | MB WAY (SIBS, 2015), Multibanco's mobile extension, with MB NET for virtual cards |
| Processor and gateway | Redsys (2011), owned by Spanish banks; Cecabank | SIBS (processor and gateway), plus local PSPs ifthenpay, Easypay, and Eupago |
| Acquiring | Comercia Global Payments (CaixaBank/Global Payments), BBVA, Banco Sabadell, Getnet (Santander), Adyen, Stripe | Unicre (Redunicre), SIBS Pay, local banks, Adyen, Stripe |
| Local cash collection | ATM network and SDA (Sistema de Distribución de Efectivo, Iberpay) for cash logistics | Payshop (SIBS, 2001): cash payments collected at neighborhood stores |
How Bizum won pay-by-bank and moved into e-commerce
Bizum is a Spanish account-to-account payment service that lets users send money to a phone number, which serves as the payee's identifier. Spanish banks created it jointly in 2016, and Sociedad de Procedimientos de Pago S.L., a company they own, operates it. The principle has not changed since. The interbank infrastructure resolves the phone alias to an IBAN, and the funds move by credit transfer, cleared and settled through Iberpay's SNCE. So there is no prefunded balance, no PAN, and no card chargeback.
Building on the customer's existing bank account explains how fast the service caught on. Bizum required no third-party app and no new account: it appeared inside the banking app the user already had. The verb bizumear and the phrase “hazme un bizum” (“send me a bizum”) have entered everyday Spanish. That happened before the service became a way to pay merchants.
The notable development of 2025 was merchant use. P2P growth was already a given. This shift to merchant payments amounted to 105.6 million online purchases, an average of 289,000 a day, and 28,600 new merchants and platforms connected. Bizum has become the second-largest payment method in Spanish e-commerce, with a share that merchants and banks put between 20% and 30% (Bizum, January 2026). A Spanish checkout without Bizum leaves out the country's second most-used online payment method.
| Parameter | Value | What it means for merchants |
|---|---|---|
| Minimum per transaction | 0,50 € | Not usable for single micropayments; aggregate before billing |
| Maximum per transaction | 1 000 € | High-ticket carts (appliances, travel, furniture) are out of scope: plan a card fallback |
| Cumulative daily limit | 2 000 € | A customer who has already sent bizums that day can be declined, and the merchant won't know why |
| Monthly limit | 5 000 € | A real constraint on high-value subscriptions and installment payments |
| Payments received per month | 60 | Designed for individuals: a business needs the merchant service, not P2P |
| Recipients per group payment | 30 | Sets the bounds for group pots and fundraisers |
Bizum is subject to public oversight. Banco de España monitors it under the Eurosystem's PISA framework, which covers payment instruments, schemes, and arrangements. Oversight includes statistical monitoring of activity, regular meetings with the operating company, and incident tracking (Banco de España, Memoria de Supervisión 2025). It applies to the arrangement itself and to its operator, separately from the prudential supervision of the banks that offer the service.
From ServiRed, 4B, and Euro 6000 to STMP, now SNCT
Spain long had three domestic card networks, mirroring the structure of its banking sector. Sistema 4B (1974) served the large commercial banks, ServiRed (1990) was the largest network, and Euro 6000 (1988) brought together the cajas de ahorros (savings banks). When the savings banks disappeared after the financial crisis, that segmentation lost its rationale. In 2018, the three entities transferred their domestic payment system business to a single company, Sistema de Tarjetas y Medios de Pago S.A. (STMP).
STMP is the interbank clearing system for a large share of domestic card transactions. It has no acceptance brand: it does not appear on cards or at checkout. It processes instruments issued under the brands and rules of Visa and Mastercard, plus a few specialized Spanish schemes: VIA-T for electronic toll collection and Gasóleo Bonificado for tax-discounted commercial diesel. Banco de España classifies it as a prominently important retail payment system (PIRPS).
The two cash withdrawal series move in opposite directions. The number of ATM withdrawals fell 3.7% in 2025, while the total amount withdrawn rose 2%. So the average withdrawal got bigger. In Spain, people use ATMs for occasional large withdrawals rather than for a daily supply of banknotes. An ATM network operator whose revenue depends on transaction counts sees its billing base shrink even as the amounts dispensed grow.
| Case | Limit | Notes |
|---|---|---|
| Debit card, transaction > €20 | 0,2 % | With an absolute cap of €0.07, which in practice applies to any payment above €35 |
| Debit card, transaction < €20 | 0,1 % | A lower tier specific to Spanish law, stricter than Regulation (EU) 2015/751 |
| Credit card, transaction > €20 | 0,3 % | Aligned with the EU cap |
| Credit card, transaction < €20 | 0,2 % | Specific lower tier |
| Commercial cards | Out of scope | Article 11 does not apply, so B2B acceptance costs are much higher |
| ATM withdrawals | Out of scope | Withdrawals follow separate economics, negotiated between institutions |
These caps apply only to transactions on card terminals located in Spain when the payer's PSP and the payee's PSP are both established in Spain. As soon as either leg of the transaction leaves the country, the EU regime applies. Through its Circular 1/2015, Banco de España requires PSPs to report the merchant discount rates (tasas de descuento) and interchange fees they charge. Pricing transparency in Spain thus rests on a reporting obligation set in the supervisor's own rules.
Redsys, the unavoidable gateway to Spanish acceptance
Redsys Servicios de Procesamiento S.L., owned by the Spanish banks and operating under that name since 2011, combines two roles that few European markets give to a single provider. It processes for a large share of the market, and it publishes the payment gateway that acquiring banks resell under their own brands. A merchant signs up for a virtual terminal with BBVA, CaixaBank, Santander, or a rural savings bank. In almost every case, it ends up integrating the same gateway under its bank's brand.
This concentration has two separate effects. Documentation, e-commerce plugins, and integration parameters are the same from one bank to the next. Multi-acquiring in Spain is therefore cheaper than it looks: a merchant that adds an acquiring bank reuses the integration it already built. The second effect is that most of the market depends on a very small number of platforms. For that reason, Banco de España monitors Redsys and Cecabank as critical providers to the retail payments ecosystem, under the ICT risk provisions of Article 4 of Real Decreto-ley 8/2023.
| Mode | Where the card is entered | What to watch for |
|---|---|---|
| Redirect | On a page hosted by the gateway | Easiest for PCI DSS, but it breaks the checkout flow and causes measurable drop-off on mobile |
| Modal window | In an overlay on top of the merchant's page | A common compromise; test rendering and accidental closing on mobile browsers |
| InSite | Fields embedded in the merchant's page | Better conversion, broader PCI scope, careful control of script loading |
| E-commerce plugin | Depends on the mode chosen | Official plugins for the common platforms; Bizum is built into the same plugin, with nothing extra to install. The bank only has to activate it |
Ds_Merchant_MerchantCode merchant code (FUC) assigned by the acquirer
Ds_Merchant_Terminal virtual terminal number under the contract
Ds_Merchant_Order order ID - RECONCILIATION KEY
Ds_Merchant_Amount amount in minor units (EUR 12.50 -> 1250)
Ds_Merchant_Currency 978 = euro (ISO 4217)
Ds_Merchant_TransactionType 0 = authorization, 1 = preauthorization, 3 = refund
Ds_Merchant_PayMethods payment method selection (card, Bizum...)
Ds_Merchant_MerchantURL server-to-server notification URL
Ds_Merchant_EMV3DS EMV 3-D Secure authentication data
GOLDEN RULE: reconcile on Ds_Merchant_Order, never on the bank
statement description. An order ID that is not unique, or is reused
after a failure, creates duplicates you cannot untangle at month-end.Spanish acquiring is concentrated among a handful of institutions and is being reshaped. Comercia Global Payments, a joint venture owned 80% by Global Payments and 20% by CaixaBank, is described as the market leader in merchant payment services, with a 31.2% share by billings. In physical POS terminals, CaixaBank, BBVA, and Banco Sabadell each hold around 20%, or roughly 60% of installed terminals between them (ON Economia, June 2025). A merger among these institutions would therefore shift a large share of the country's terminal base.
Multibanco and MB WAY, Portugal's single network
Multibanco is Portugal's interbank network of ATMs and payment terminals, launched in 1985. Most countries ran several ATM networks side by side and later linked them. Portugal built a single network, shared by the country's banks and operated by SIBS, a company owned by those same banks. A Multibanco machine works as a universal interbank service point. It dispenses cash, pays bills and taxes, tops up phones, buys transit tickets, and sends credit transfers, whatever the cardholder's bank.
MB WAY, launched in 2015, is the network's mobile offshoot. It covers P2P payments by phone number, in-store QR payments, single-use virtual cards through MB NET, and online payments. The service is shared by Portuguese banks, whose apps plug into it instead of each offering their own solution. The single-network logic still holds.
SIBS now operates well beyond its home market. The group says it reaches more than 220 million users at more than one million points of sale and serves more than 90 financial institutions (SIBS, 2025). It also exports its model. Timor-Leste's P24 interbank switch, launched nationwide in 2024 (including for taxes and customs duties), runs on a platform supplied by SIBS.
Portuguese law also restricts charging for the use of a payment method. Decreto-Lei n.º 3/2010 bars payees from charging payers a fee for using a given payment instrument. It also bars fees on transactions at ATMs. Surcharging, common elsewhere as a way to offset the cost of accepting credit cards or alternative methods, is not available in Portugal as a margin lever.
Portuguese payment references, the rail no one has managed to copy
A referência Multibanco is a payment claim identifier that the creditor gives to the payer, who then initiates the payment. It takes the form of a triplet, entidade / referência / valor (entity / reference / amount), sent when the order is placed or the invoice issued. The creditor never asks the payer for bank details or a card number. The payer enters the triplet at a Multibanco machine, in a banking app, or in MB WAY. The payment reaches the creditor already reconciled.
Entidade 12345 5 digits, greater than 10000, assigned by SIBS
identifies the CREDITOR in the network
Referencia 987 654 321 9 digits, built by the creditor
the last 2 are a check digit computed
from the entity, reference, and amount
Valor 47,90 EUR expected amount
WHAT THIS MEANS
- the check ALSO covers the amount: a reference generated for
EUR 47.90 is rejected if the payer enters a different amount
- the reconciliation key is the reference, never the description
- payment is ASYNCHRONOUS: the order is placed, the reference is
issued, and payment arrives later... or neverTwo access models coexist, and the choice between them sets the project timeline. The first is to obtain an entity code of your own from SIBS. Large billers in energy, telecoms, insurance, and government take this route. It gives full control over the reference range but requires a direct contract and lead time. The second is to go through a Portuguese PSP that holds an entity code and shares it among its merchant clients as sub-entities. Almost all e-commerce works this way. The connection goes live in a few days, at the cost of a reference range managed by the provider.
| Payment method | List price | Takeaway |
|---|---|---|
| MB WAY | 0,07 € + 0,7 % | The cheapest option in the catalog: a clear economic incentive to push the domestic wallet |
| Multibanco references | 0,20 € + 1,5 % | Priced like cards, but with no card chargeback risk and no authentication cost |
| Visa/Mastercard EEA consumer cards | 0,20 € + 1,5 % | The benchmark online card price; Apple Pay and Google Pay are billed at the same rate |
| Payshop | €0.57 per transaction | Flat fee, consistent with cash collected at the counter |
| SEPA direct debit | €0.45 per transaction | No percentage fee: the go-to instrument for high-value subscriptions |
| Physical POS terminal | 0.7% + €12 monthly rental | Ballpark for in-person acceptance of an EEA consumer card |
These are one provider's list prices, not a market average. Use them as a ballpark and a starting point for negotiation. MB WAY is priced at €0.07 plus 0.7%, versus €0.20 plus 1.5% for cards. In Portugal, the cost gap between the domestic wallet and cards is wide enough to justify steering customers at checkout. Because Decreto-Lei n.º 3/2010 bans surcharging, passing that gap on to the customer is not an option.
SNCE and SICOI, two clearing houses with different governance
A retail clearing house calculates net positions between participating institutions and prepares their settlement. Spain and Portugal each run one, under different governance. In Spain, the SNCE (Sistema Nacional de Compensación Electrónica) is run by Iberpay, a company owned by the participating institutions. Banco de España supervises it under Article 17 of Ley 41/1999. In Portugal, Banco de Portugal itself operates SICOI. The central bank is both operator and regulator, an arrangement it shares with the Banca d'Italia and one that partly explains its dispute with SIBS.
| SNCE (Spain) | SICOI (Portugal) | |
|---|---|---|
| Operator | Iberpay (Sociedad Española de Sistemas de Pago), owned by its participants | Banco de Portugal, directly |
| Volume, 2025 | 3,261 million transactions (+8.2%) | 5.2 billion transactions (+10.7%) |
| 2025 value | €3,052B (+10.1%) | €875.9B (+12.8%) |
| Leading instrument by number | Credit transfers: 1,850M transactions (+14.3%) | Cards: 4.4B transactions, or 85.2% of the total |
| Instant | 1,194M instant payments worth €416B; the first year standard transfers declined as instant took over | 323.8M instant payments worth €140.9B; 70% of credit transfers in Q4 2025 |
| Checks | 14M transactions, but still €137B | Marginal: electronic instruments account for 99.9% of the total number |
| Oversight framework | Eurosystem framework for “other retail payment systems” (ORPS); PFMI and cyber resilience assessments completed in 2025 | Central bank oversight of its own subsystems, governed by the SICOI rulebook |
Sources: Banco de España, Memoria de Supervisión 2025 (Iberpay data) for Spain; Banco de Portugal, Relatório dos Sistemas de Pagamentos 2025 for Portugal. The two series show the same underlying shift, on slightly different timelines. Instant payments are no longer an add-on; they have become the default way to send a credit transfer. Spain saw standard transfers decline for the first time, and in Portugal instant payments made up 70% of credit transfers in Q4 2025. Regulation (EU) 2024/886 has required PSPs to receive instant payments since January 9, 2025, and to send them since October 9, 2025, at the same price as a standard credit transfer.
- Spain's SNCE for instant payments: the service opened in November 2017, runs 24/7, and caps exchange time at 20 seconds; 147 institutions are connected, representing more than 99% of the retail payments market in Spain (Iberpay, checked in August 2026).
- Pan-European reach: the SNCE is connected to TIPS (access to more than 1,450 European institutions) and to EBA Clearing's RT1 (more than 2,200 institutions), so cross-border reachability does not depend on which CSM the payee's bank uses.
- Verification of Payee (VoP): Iberpay and the Spanish banking community launched the European service on October 17, 2025, as required by Regulation (EU) 2024/886.
- Portuguese subsystems: SICOI clears checks, bills of exchange, direct debits, credit transfers, instant payments, and card-based transactions separately. The first five subsystems settle on a deferred basis; instant payments settle in real time. Joining one subsystem does not require joining the others. The SICOI rules are set by Banco de Portugal's Instrução n.º 11/2025, which replaces Instrução n.º 8/2018.
- SNCT folded in on the settlement side: Spanish institutions have agreed that interbank settlement of domestic card activity will take place in the SNCE, concentrating Spain's clearing arrangements even further around Iberpay.
E-invoicing, cash, and tax traceability
Both countries impose document-level tax traceability that goes well beyond the payment itself. The rules cover invoicing software, invoice formats, and transmission to the tax authority. The two regimes are at different stages. Portugal has built its system in successive layers over 15 years and is nearing the end of the cycle. Spain is rolling out two separate obligations at once, with different scopes and timetables.
Spain: two regimes, neither replacing the other
| Veri*factu | B2B e-invoice | |
|---|---|---|
| What it governs | Invoicing software: tamper-proof records, traceability, submission of records to the tax authority | The format and exchange of invoices between businesses and self-employed professionals |
| Legal basis | Real Decreto 1007/2023 of December 5, 2023, amended by Real Decreto 254/2025 of April 1, 2025 | Ley 18/2022 (“Crea y Crece”), Article 12, implemented by Real Decreto 238/2026 of March 25, 2026 |
| Timeline | January 1, 2026 for corporate income taxpayers; July 1, 2026 for all other obligated parties | The decree is in force, but actual application awaits the ministerial order defining the public solution |
| Deadlines after that order | Not applicable | 12 months for companies with revenue above €8 million, 24 months for the rest |
| Exclusions | Taxpayers under SII (Immediate Supply of Information) are exempt | Applies to transactions between businesses and professionals |
| Formats | Standardized invoicing records | Facturae, UBL, CII, and EDIFACT, through the public solution of the AEAT (Spain's tax agency) or private platforms |
Portugal: ATCUD, QR code, SAF-T, and the end of the plain PDF
- ATCUD and QR code: the unique document code and the QR code are mandatory on invoices and other tax-relevant documents; the QR code applies to paper invoices and signed PDFs.
- SAF-T (PT) for invoicing: the file must be sent to the Autoridade Tributária (Portugal's tax authority) every month, by the 5th of the following month. The annual accounting SAF-T has been postponed: the first mandatory filing, covering fiscal year 2026, is due in 2028 (2026 budget law).
- Plain PDFs remain valid until December 31, 2026: the 2026 budget law extends their treatment as e-invoices. From January 1, 2027, invoices must carry a qualified electronic signature or seal, and the structured CIUS-PT format becomes the rule.
- B2G: the requirement to send structured e-invoices to public bodies has been postponed again for micro, small, and medium-sized enterprises until end-2026 (Decreto-Lei n.º 13-A/2025).
| Spain | Portugal | |
|---|---|---|
| General cap | €1,000 whenever one of the parties acts as a business or professional | €3,000 for any person, natural or legal |
| Non-resident individual payer | €10,000, with proof of tax residence outside Spain and when not acting in a business capacity | €10,000 for non-resident individuals not acting as a business |
| Traceability requirement | – | IRC/IRS (corporate and personal income tax) filers required to keep formal accounts must make and receive payments of €1,000 or more by a method that identifies the recipient; taxes above €500 cannot be paid in cash |
| Legal basis | Ley 11/2021, Article 18 | Lei 92/2017, Articles 63-C and 63-E of the Lei Geral Tributária |
| Penalty | 25% of the amount paid in cash above the threshold, owed jointly by payer and payee | Fines of €180 to €4,500 |
What breaks, what it costs, and what's next
On April 28, 2025, a nationwide blackout cut power to most of the Iberian Peninsula for several hours. The episode offered a real-world test of how both countries' payment methods behave when the power goes out. Both central banks measured the impact instrument by instrument. The infrastructure held up; the points of acceptance went down.
The drop measured in Spain varied widely by type of business. Large retailers lost only 35% of their card payments, while small shops saw declines of more than 80% at the worst points, and many chose to close. Rail transport fell 73% and restaurants 63%. The rebound was immediate and pushed spending above normal levels. On Tuesday, April 29, card spending was 14% higher than on non-holiday Tuesdays in April 2024, and on Wednesday, April 30, it was 37% higher (Banco de España, Revista de Estabilidad Financiera No. 49). In Portugal, withdrawals fell 34% by number and 24% by value, returning to normal the very next day.
| Instrument | Fraud cases per million transactions (H1 2025) | Loss allocation (2025) |
|---|---|---|
| Payment cards | 66 | Institutions absorb 54.5% of losses |
| Credit transfers | 10 | Customers bear 84% of losses |
| Direct debits | 4 | – |
Source: Banco de Portugal, Relatório dos Sistemas de Pagamentos 2025. Credit transfer fraud is ten times less frequent than card fraud, yet customers bear 84% of the losses it causes, while institutions absorb 54.5% of card fraud losses. The gap comes from the liability regime. A transfer executed after the account holder has authenticated is an authorized transaction, with no automatic right to a refund, whereas a disputed card transaction opens a chargeback process. That regime covers Bizum and MB WAY account-to-account payments, and it is the flip side of their success. This is why Regulation (EU) 2024/886 requires Verification of Payee, which went live in Spain on October 17, 2025.