Mortgage Pre-Approved? Your Deposit Could Still Be at Risk

Grab a meia de leite, because we need to talk about one of the most misunderstood parts of buying property in Portugal: the mortgage pre-approval. 

Not the final mortgage approval. The pre-approval. That little word matters more than people think.

The one-sentence version

A mortgage pre-approval in Portugal does not always mean the bank will definitely lend you the full amount when it is time to sign the deed. And if you have already signed the CPCV and paid the sinal (deposit), that gap between "pre-approved" and "finally approved" can become very expensive.

And there is a new wrinkle on the way. From 1 August 2026, Portuguese banks are expected to tighten how much they will lend (more on that below), which means the gap between what you think you can borrow and what the bank actually hands over could get wider.

Technically, this is a Banco de Portugal recommendation, not a new law passed in parliament. In real life, though, banks are expected to follow it, so for buyers and sellers it will feel very much like a rule.

Pre-approved does not mean approved

This is the part that catches people out.

A pre-approval usually means the bank has looked at the buyer's income and said, broadly, "yes, this could work." It does not mean the bank has made a final, binding decision on the property, the valuation, the paperwork, and the amount.After the CPCV is signed, the real process still has to happen. The bank still needs to:

• value the property
• check the property documents
• check the buyer's final paperwork
• apply its final risk rules
• confirm the exact amount it is willing to lend
• complete all of this before the CPCV deadline

That is where things can start to wobble.

A buyer may think they can borrow €250,000, sign a CPCV based on that assumption, pay the sinal, and then discover the bank will only lend €220,000. Or the bank approves the buyer but not the property. Or the valuation comes in too low. Or the approval arrives after the CPCV deadline has passed.

The buyer did not necessarily do anything reckless. They may have had a pre-approval. They may have spoken to a broker. They may have genuinely believed the mortgage was fine. But a pre-approval is not money in the bank. 

Literally.

The sinal is not a casual reservation fee

This is where the stress really starts.

The sinal is the deposit paid when the CPCV is signed. In Portugal, this is often 10% of the purchase price, although the amount can vary.A friend in the industry recently told me about a buyer who had been pre-approved, signed the CPCV, paid the sinal, and then did not get the final mortgage approval they needed in time.

That is the quiet trap in this story. The bank did not have to say no. The clock just ran out. 

A CPCV sets a deadline for signing the deed, and if your financing does not arrive inside that window, even if it would have landed a couple of weeks later, you can be treated as the one who broke the contract. And whoever breaks it usually loses the sinal.

It is not a one-off. Spend ten minutes in the expat groups or the Portuguese property forums and you will find people asking the same anxious question: can I lose my deposit if the bank says no at the last minute?

Here is the part that surprises people. In Portugal, a CPCV does not automatically protect you if the mortgage falls through. That protection, a clause making the sale conditional on final mortgage approval, is something you often have to ask for, and some sellers or agents will push back on it. If nobody wrote it in, the default is not on your side. Whether you get the sinal back depends on the wording of the CPCV and the facts of the situation. 

But without that clause, the seller may not be legally obliged to return a cent.So this is not just a paperwork detail. This is a "could I lose my deposit?" detail.

Why the new mortgage rule matters

Now add the new Banco de Portugal rule into the mix.From 1 August 2026, banks are expected to use a stricter affordability calculation. All your monthly loan payments together should fit inside 45% of your take-home pay. It used to be 50%.

Five percent. Sounds like nothing, right? Wrong.Say you and your partner bring home €3,000 a month between you.

• Old rule: the bank could let your loan payments go up to €1,500/month
• New rule: the ceiling drops to €1,350/month

That missing €150 a month sounds like a nice dinner out. But stretched over a 30-year mortgage, it can chop tens of thousands of euros off what the bank will lend you.

Suddenly the house you fell in love with is €30,000 out of reach, and you did not do anything wrong. The rules just moved.And it gets worse. The bank does not run this test at today's interest rate. It adds a stress cushion, pretends rates jumped, then checks if you still fit. So your real ceiling can sit below 45%. Plan for less, not more.

This new rule does not create the pre-approval problem from scratch. That problem already existed. It just makes the weak point more obvious, especially for buyers who were already close to the limit. And it is not always a clean rejection. Sometimes the bank still says yes, just not to the number the buyer needs.

Existing debts now hurt more

Banks have always counted your other loans in this calculation. That part is not new.  But with a smaller ceiling, your existing debts suddenly hurt more. 

That shiny car on credit? Every €100 of monthly car payment can eat roughly €25,000 to €30,000 of house-buying power, and now there is less power to spare. 

Your car just got more expensive without moving an inch.If you are applying for a mortgage, it may be worth looking at whether small debts can be paid off before the bank does the final assessment. Not because it makes you richer, sadly, but because it can make the bank's maths look better.

The good-ish news for some younger buyers

There is one small cushion hidden inside all this tightening.

For buyers aged 35 or under, the maximum mortgage term is now 40 years. Before, the 40-year term only applied up to age 30, and buyers aged 31 to 35 were generally capped at 37 years.

So if you are 32, 33, 34, or 35, this change may give you a little more breathing room. A longer mortgage term can lower the monthly payment, which helps the bank's affordability calculation.

It does not magically cancel out the stricter 45% rule, but it can soften the hit for some younger buyers.Two important details:

• Couple buying together? The bank uses the age of the oldest borrower. So if one of you is 34 and the other is 39, do not expect the 40-year term.
• 35 or under? The state guarantee scheme, where the government backs your deposit so you can borrow up to 100%, is still alive and kicking, and young first-time buyers still skip the nasty IMT purchase tax

Before signing the CPCV, ask better questions

Buyers should not be afraid to ask boring, uncomfortable questions before signing anything. Especially these:

• Is this a real mortgage approval, or only a pre-approval?
• Has the property valuation already been done?
• Has the bank approved this exact property, or only looked at my income?
• Does the CPCV say the sinal is refundable if the bank does not approve the mortgage?
• Does that protection apply if the bank approves a lower amount than expected?
• Does the protection last until the deed date, or only for a short window?
• What happens if the bank approval arrives after the CPCV deadline?

These are not small-print questions. They are deposit-saving questions.

And please, do not rely only on what an agent, friend, Facebook group, or friendly stranger on the internet tells you. Get the CPCV checked properly before signing, ideally by a lawyer who understands Portuguese property contracts.

^{Buying property in Portugal can feel a bit like its cobbled streets: beautiful, full of character, and steeper than it first looks. A mortgage pre-approval is only part of the climb.}

Selling? Expect twitchier deals

This is not just a buyer story. 

If you are the one with the "Vende-se" sign, you should care too. A buyer can arrive with a pre-approval and still fail to complete if the bank later says no, says not enough, values the property lower than expected, or misses the timeline.

So before accepting an offer, ask what kind of financing position the buyer actually has. 

There is a big difference between:

• a buyer with cash already available (a pronto pagamento)
• a buyer with a large deposit and strong documents
• a buyer with a formal bank approval (the carta de aprovação, given for this property after the bank's valuation)
• a buyer with a pre-approval (pré-aprovação)
• a buyer with a broker estimate
• a buyer who says, "it should be fine"

Those are not the same buyer.

A slightly lower offer that actually completes can be better than a higher offer that dies at the bank stage. Heartbreaking, avoidable, and extremely annoying if you have already taken the property off the market.

And now for the plot twist

Who wins from all this? Cash buyers.

A huge share of Portuguese property sales still depends on bank financing. When banks tighten up, some buyers drop out, some need to shrink their budget, and some deals wobble after the CPCV.A seller then looks at two offers. One depends on a bank saying yes in time. The other says, "I have the money, we can sign in three weeks."Suddenly the cash offer looks gorgeous, even if it is a chunk lower.

So if you have been squirrelling away savings: congratulations, you just became the most popular person at the estate agency. Negotiate accordingly. 😏

The fridge-magnet summary

• A mortgage pre-approval is not the same as final mortgage approval
• The sinal is not just a reservation fee, it is tied to the CPCV terms
• If the CPCV does not protect you, failed financing may put your deposit at risk
• From 1 August 2026, banks are expected to use a stricter 45% affordability rule, down from 50%
• They stress-test it too, so your real limit can land below 45%
• Buyers close to the limit may still be approved, but for less than they need
• Existing debts now hurt your borrowing power more
• Buyers aged 31 to 35 get a small improvement: the maximum term can now go up to 40 years, instead of 37
• Before signing the CPCV, ask whether the buyer has final approval, pre-approval, or just a hopeful estimate
• Got cash? You are holding the best hand at the table

Planning a move or a purchase in Portugal and want to catch the next trap before it catches you? Stay in the loop and I'll send the next one your way.

Not legal or financial advice, just me translating property stress into human. Every bank, buyer, CPCV, and wallet is different, so do check your own situation properly before signing anything expensive.

I'm Moira. 

I moved from South Africa to Portugal in 2020 and have been buying and selling property here since 2017. I've signed enough CPCVs and paid enough sinais to have watched deals wobble at the very stage this post is about. I write Portugal Horizon to help people move and buy here without the expensive mistakes, from Sesimbra, where I live with my husband and two dogs.