You log into your Hargreaves Lansdown account on a Tuesday morning to check your ISA and there it is: a polite-sounding email asking you to “transfer or close” your account within 90 days. Welcome to one of the most stressful surprises in modern expat life.

Since Brexit, UK investment platforms have been steadily tightening — and in many cases closing outright — the accounts of British citizens living in the EU. If you’re based in Portugal and you still hold UK-domiciled ISAs, SIPPs or general investment accounts, this affects you. This guide explains why it’s happening, what your real options are, and how to make sure your money keeps working for you when your UK broker pulls the shutters down.

Why UK Investment Platforms Are Closing Expat Accounts

The short answer is regulation. The longer answer is that running a platform for someone living in Portugal is now more expensive and more legally complicated than UK platforms want to deal with — especially when those clients are a tiny percentage of their book.

Before Brexit, the EU’s “passporting” rules meant a UK firm regulated by the Financial Conduct Authority (FCA) could serve clients across the EU without needing local authorisation. That passporting right ended on 31 December 2020. Since then, UK platforms wanting to keep EU-resident clients have needed to either get authorised separately in each EU country (expensive), partner with a local regulated entity (administratively painful), or rely on narrow “reverse solicitation” rules that most compliance teams find too risky to lean on.

The result has been a steady drumbeat of account closures. Interactive Investor, AJ Bell, Hargreaves Lansdown, Fidelity, Vanguard UK and others have all sent versions of the same letter to expat clients over the last few years. The wording varies; the message doesn’t. Find another home for your investments, please.

There’s also a second pressure: the EU’s MiFID II rules, which require UK firms to comply with EU investor-protection standards if they’re soliciting EU clients. Most UK platforms have decided it’s simply not worth the cost. In my experience working with clients across the Algarve, the platforms that are still accepting expat applications today are not the same ones that were accepting them two years ago — and that list keeps shrinking.

What Actually Happens to Your Existing Investments?

This is the question that keeps people awake at the night. The good news is that your money does not disappear. The bad news is that you have to make active choices, and some of those choices have tax consequences.

When a UK platform closes your account, you typically have three options:

1. In-specie transfer to another platform. Your investments move “as-is” to a new provider. No sale, no capital gains event in the UK. This is almost always the best option if you can find a platform that will accept you.
2. Sell down and transfer cash. The platform liquidates your holdings and sends you the proceeds. This triggers a UK capital gains tax event on the gains — and if you’re already Portuguese tax resident, Portuguese CGT rules also apply. Avoid this unless there’s no other choice.
3. Move the assets to a new tax wrapper. For SIPPs, this might mean a transfer to a different SIPP or, in some cases, an overseas pension scheme. For ISAs, the rules are more restrictive (more on that in a moment).

One critical detail people miss: the 90-day window UK platforms typically give you is not always enough time to open a new account elsewhere, complete the KYC checks, and execute a transfer. Start the process the day the letter arrives. Do not wait.

The ISA Problem — And Why It’s Bigger Than You Think

ISAs are a particular headache for UK expats. Once you become non-resident in the UK, HMRC’s rules stop you from contributing to an existing ISA, but you can still hold it. The growth remains UK-tax-free.

Here’s where Portugal comes in. The Portuguese tax authority does not recognise UK ISAs as tax-free. They treat them like any other foreign investment account. Dividends and gains inside an ISA are fully taxable in Portugal under your personal tax rules — usually at 28% for investment income (or your marginal rate if you elect to include it in your main tax return). So even before your platform closes, your “tax-free” wrapper is doing nothing for you in Portuguese hands.

When the platform does close, you face a choice. If you can transfer the ISA in-specie to another UK platform that accepts expats, you preserve the UK tax-free status. If you can’t, you may end up having to crystallise the holdings, at which point the wrapper is gone forever. Once an ISA is collapsed, you cannot rebuild it from outside the UK.

This is one of the areas where I see clients lose the most value through inaction. They wait until the deadline, panic, sell down, and discover six months later they could have done something smarter.

Which UK Platforms Still Accept Portugal-Based Clients?

This list moves frequently — what’s true this quarter may not be true next year — so always check directly before relying on a name. As of 2026, the platforms most likely to accept Portugal-resident clients fall into three categories:

• UK platforms with EU subsidiaries, such as Interactive Brokers and Saxo. These typically transfer your account to their Irish, Luxembourg or German entity, which is authorised under MiFID. Costs and product ranges can differ from the UK version.
• Specialist expat platforms like the offshore arms of certain wealth managers. These are usually designed around offshore investment bonds or international SIPPs and have higher fees but more flexibility.
• Adviser-managed platforms where the platform itself is happy to hold expat assets provided you work with a regulated adviser. This is how many of my clients end up structured — the platform sees an adviser firm in the relationship, which solves their compliance question.

If you go down the DIY path, the most important thing is to read the small print on jurisdiction. Many “international” platforms hold your money in Luxembourg, Ireland or the Isle of Man. The protection sc(eme that applies to your assets is the local one, not the UK’s FSCS. That’s not necessarily worse — but it is different, and you should know what you’re signing up for.

SIPPs and QROPS — A Different Set of Rules

If your SIPP provider closes your account, the consequences are slightly less alarming than with an ISA, because pensions have their own transfer regime. You can usually transfer your SIPP to:

• Another UK SIPP provider that accepts overseas residents (these still exist, but the list is shorter than it used to be).
• An international SIPP, which is typically held in the UK but designed for non-UK residents — often with multi-currency capability.
• A QROPS (Qualifying Recognised Overseas Pension Scheme), typically based in Malta or Gibraltar.

I’ve written previously about SIPP vs QROPS for UK expats in detail. The short version: a QROPS is not automatically the right answer just because you’re abroad. The 25% Overseas Transfer Charge that was reintroduced in the 2024 Autumn Budget caught a lot of people out, and the case for QROPS is now much narrower than it used to be. For most Portugal-resident clients, an international SIPP is the more sensible option.

How to Choose a New Platform — A Practical Checklist

When you’re shopping for a new home for your investments, work through these questions before you commit:

1. Will they accept you? Some platforms say they take “European clients” but then quietly exclude Portugal. Confirm in writing before transferring.
2. What currencies do they support? If you’re going to be spending in euros, a platform that only deals in sterling adds an FX drag to every transaction.
3. What’s the total cost of ownership? Look at platform fees, dealing charges, FX spreads and fund charges combined. Cheap headline fees can hide expensive trading costs.
4. What protection applies? Compare the local investor compensation scheme to the UK’s FSCS limit. Most EU schemes cap at €20,000 — significantly less than the FSCS’s £85,000.
5. What tax reporting do they provide? Portuguese tax returns require detail on every disposal. A platform that can produce a transactions report in a format your accountant accepts is worth its weight in gold.
6. Are the funds tax-efficient for Portugal? EU-domiciled UCITS funds are usually fine. UK-domiciled funds and US ETFs can create reporting headaches and higher tax rates under Portuguese rules.

That last point matters more than people realise. Holding US-domiciled ETFs as a Portuguese tax resident exposes you to US withholding tax on dividends (typically 15% under the Portugal–US treaty, but it can be 30% if you haven’t filed a W-8BEN). Switching to UCITS equivalents is often the right move and most EU platforms make this easy.

The Hidden Risk: Doing Nothing

The worst outcome I see is when a client receives the closure letter, feels overwhelmed, and parks the decision. A few months later their account is force-closed, holdings are sold at whatever price the platform achieves, and a cheque (or bank transfer) lands for the proceeds. The capital gains tax bill — UK and Portuguese — arrives later. The ISA wrapper is gone. The pension transfer they could have planned carefully turns into a rushed scramble.

Acting early gives you choice. Waiting takes it away.

Frequently Asked Questions

Can a UK platform really close my account just because I live abroad?

Yes. Their terms and conditions almost universally allow them to terminate the relationship at notice if you move to a jurisdiction they’re not authorised to serve. You’re not being singled out — you’re being moved off a list that compliance teams want to shrink.

Will I have to pay capital gains tax if I’m forced to sell?

Potentially in both the UK and Portugal. As a Portuguese tax resident, you’ll usually report disposals on your Portuguese tax return, and the UK may also apply CGT depending on how long you’ve been non-resident. The Portugal–UK double taxation treaty typically resolves this by giving primary taxing rights to Portugal, but the calculations are not straightforward. Speak to a cross-border accountant before any disposal.

Can I keep my UK ISA after I move to Portugal?

You can keep an existing ISA open as long as your provider still allows it, but you cannot make new contributions while you’re a UK non-resident. Note that Portugal does not treat the ISA as tax-free — gains and dividends inside it are taxable in Portugal regardless of the UK wrapper.

Are international SIPPs safer than QROPS?

Safer isn’t quite the right word — they’re different. An international SIPP remains under UK pension law and FCA oversight, which suits most expats. A QROPS sits under the rules of the jurisdiction it’s based in (typically Malta or Gibraltar). For most Portugal-resident clients, an international SIPP is currently the simpler and lower-risk choice, especially given the 25% Overseas Transfer Charge now applying to many QROPS transfers.

How long does a platform-to-platform transfer take?

An in-specie transfer between UK platforms typically takes four to eight weeks. International transfers can take longer, particularly if KYC documentation is queried. Always start the process the moment you receive a closure notice — don’t wait until you’ve finished your research.

What to Do Next

If you’ve received a closure letter, don’t panic — but don’t park it either. The earlier you start working through your options, the more choice you’ll have. Look at your wrappers, look at your holdings, and get clear on what an in-specie move would look like before any deadline forces a sale.

If you’d like to discuss how this affects your personal situation, get in touch with our team. We specialise in helping UK expats in Portugal navigate exactly these cross-border platform and pension issues — and we work with several international platforms that still actively welcome Portugal-based clients.

Matthew Renier is a Chartered Financial Adviser at Arthur Browns Wealth Management, based in the Algarve, Portugal. He has over 25 years of experience helping British expats manage their pensions, investments and financial planning across borders.

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