COREDO > Licensing > Financial Licences in the EU > Banking Licences

Banking Licences

Banking Licences: Authorisation for Banking Activities in the EU

Banking Licences — authorization to conduct banking activities in the European Union. It allows a credit institution to accept deposits, issue loans and provide a full range of banking services, as well as operate under the EU passporting regime within the EEA.

Since 2016, COREDO has supported the licensing process and structuring of banking projects across the EU.

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What Is a Banking Licence

A banking licence is the authorisation a credit institution needs to conduct banking activities in the European Union. It is issued under CRD IV (Directive 2013/36/EU), and the application is filed with the national regulator of the licensing country. With the licence, the institution may:

Deposits and loans

Accept deposits from the public and lend for your own account — a combination that neither an EMI nor a PSP licence permits.

Payment services and e-money

Provide payment services and issue electronic money under the same licence.

Full range of banking services

Offer clients a full range of banking services in the EU.

Operation across the EEA

Open branches and provide services in other EEA countries through passporting, without a separate licence in each country.

Who Needs a Banking Licence

A Banking Licence is required for any company that intends to conduct regulated banking activities in the EU. The most common applicants are:

Fintech startups

seeking to offer deposit accounts and lending alongside payment services

Investment firms

expanding into full banking services (asset management, lending, custody)

Payment institutions

that have grown beyond the scope of their existing EMI or PSP licence

Foreign banks

entering the European market via a newly established EU subsidiary

Family offices and private banks

structuring EU-based deposit and wealth management operations

If your model combines taking deposits or other repayable funds from the public with granting credits for your own account, you need authorisation as a credit institution under EU law. Taking deposits from the public without it is prohibited, while lending on its own is governed by national rules.

Regulatory Framework: Banking Licences vs EMI vs PSP

Banking licences are issued under CRD IV (Directive 2013/36/EU), and the application is reviewed by the national regulator of the licensing country. The table shows how the capital and the permitted activities differ from those of EMI and PSP licences.

Criterion	Banking Licences	EMI Licence	PSP Licence
Minimum capital	EUR 5,000,000	EUR 350,000	EUR 20,000–125,000
Deposit taking	✅ Yes	❌ No	❌ No
Lending	✅ Yes	Only credit linked to payments	Only credit linked to payments
Payment services	✅ Yes	✅ Yes	✅ Yes
Electronic money	✅ Yes	✅ Yes	❌ No
Decision period	6 months from a complete application, 12 months at most (CRD IV, Art. 15)	3 months from a complete application (PSD2, Art. 12)	3 months from a complete application (PSD2, Art. 12)

Requirements for Obtaining a Licence

Applicants must meet strict regulatory requirements:

Minimum capital:

initial capital of at least EUR 5,000,000. This requirement is established by Directive 2013/36/EU (CRD IV, Article 12). The capital serves as a guarantee of obligations to clients.

Competent management:

Founders and board members must have relevant education, financial sector experience, and an impeccable reputation. Regulators screen candidates against EU sanctions lists and PEP databases.

AML/CFT procedures:

Mandatory implementation of AML controls under national AML laws based on Directive (EU) 2015/849; from 10 July 2027 the EU AML Regulation (2024/1624) applies directly. This includes client identification (KYC), beneficial owner verification (KYB), transaction monitoring and, where appropriate to the size and nature of the business, an independent audit function.

IT infrastructure and security:

Development of robust data protection systems, operational resilience under DORA, GDPR compliance, and backup procedures.

Business plan:

Description of services, target audience, financial projections for at least three years, risk management strategy, and growth plans. The regulator assesses the viability of the business model.

Physical presence:

A registered office and operational centre in the licensing country.

Jurisdictions and Expansion Opportunities

COREDO provides licensing services in the following jurisdictions:

Jurisdiction	Regulator	Minimum capital	Regulator’s decision period from a complete application	COREDO price	Features	Country page
Czechia	Czech National Bank (ČNB)	Share capital of at least CZK 500,000,000 (Czech Act No. 21/1992 Coll. on Banks)	6 months; no later than 12 months after filing	On request	Proximity to COREDO HQ, experienced regulator ČNB	Learn more
Estonia	Finantsinspektsioon; licence granted by the ECB	At least EUR 5,000,000 (Estonian requirement, Finantsinspektsioon)	6 months; no later than 12 months after filing	On request	Digital-first approach, fintech-friendly environment	Learn more
Lithuania	Bank of Lithuania; licence granted by the ECB	EUR 5,000,000; EUR 1,000,000 for a specialised bank (Bank of Lithuania)	6 months; no later than 12 months after filing	On request	Fintech hub	Learn more
Latvia	Latvijas Banka; licence granted by the ECB	EUR 5,000,000	6 months; no later than 12 months after filing	On request	Competitive conditions	Learn more
Poland	Polish Financial Supervision Authority (KNF)	At least the PLN equivalent of EUR 5,000,000 (Polish Banking Law, Art. 32)	6 months; no later than 12 months after filing	On request	Major EU jurisdiction	Learn more
Cyprus	Central Bank of Cyprus; licence granted by the ECB	At least EUR 5,000,000 (Cypriot Business of Credit Institutions Law 66(I)/1997)	6 months; no later than 12 months after filing	On request	International financial centre	Learn more
Portugal	Banco de Portugal; licence granted by the ECB	Share capital of at least EUR 17,500,000 (Portuguese Portaria No. 95/94, as amended)	6 months; no later than 12 months after filing	On request	Stable regulatory framework	Learn more

COREDO service pricing: available on request. Contact us for an individual quote.

How We Work: Licence Acquisition Process

Obtaining a licence is a multi-stage process:

Stage 1: Document Preparation

Collecting and preparing all required documents: articles of association, financial statements, management qualification records, business plan, IT infrastructure description, AML/CFT policies, and office documentation.

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Stage 2: Application Filing

Official submission of the application to the national regulator. The review timeline begins.

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Stage 3: Application Review

The regulator conducts a comprehensive analysis: evaluating management qualifications, reviewing the business plan, and verifying IT infrastructure and security. Additional information requests are common at this stage.

Under CRD IV (Article 15), the decision comes within six months of a complete application and no later than 12 months after the application is received.

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Stage 4: Licence Issuance

Upon a positive decision, the licence is published in the regulator’s register, and the institution may commence operations.

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Banking Regulation Beyond the EU

COREDO also assists financial institutions based outside the EU seeking authorisation for European banking operations. The regulatory landscape varies significantly across key jurisdictions:

United Kingdom (PRA/FCA):

Banking in the UK is regulated by the PRA and FCA. After Brexit, UK banks lost EU passporting rights and must obtain separate licenses to operate in the EU. Market access in the EU requires subsidiaries or locally licensed entities.

Switzerland (FINMA):

Banking licenses are issued by FINMA under the BankA (Banking Act). Switzerland is not part of the EEA, so EU passporting is not available. EU operations require a separate licensed entity within the EU, typically structured through cross-border regulatory planning and licensing processes.

Dubai and UAE (CBUAE/DFSA):

Banking is regulated by the Central Bank of the UAE (CBUAE) on the mainland and the DFSA in the DIFC. Expansion into the EU requires establishing an EU-licensed subsidiary. International structures are built through separate regulated jurisdictions and localized compliance frameworks.

For entities based in these and other non-EU jurisdictions, COREDO offers cross-border structuring advice and full-cycle EU licensing services. Contact us to discuss your specific situation.

Passporting: Expansion Across the EEA

A key advantage is the ability to expand operations to other EEA countries without obtaining additional licences. This is achieved through the passporting mechanism established by Directive 2013/36/EU (CRD IV). Once licensed in one jurisdiction, you may:

Open branches

in other EEA countries by notifying the local regulator

Provide services

in other jurisdictions without additional authorisation

Scale geographically

without additional licensing costs

The passporting mechanism is particularly valuable for companies planning growth across European markets. After obtaining a licence in one country (e.g. Czechia), you can rapidly enter other markets, saving time and resources.

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Required Documents

Applicants typically need to submit the following documentation package:

Corporate documents:

Articles of association, shareholder register, ownership structure diagram, proof of registered office

Financial documentation:

Audited financial statements (if existing entity), source of funds evidence, capital deposit confirmation

Management documentation:

CVs and qualifications of all board members and key function holders, criminal background checks, PEP declarations

Business plan:

Detailed description of services, target markets, financial projections for at least three years, governance model

AML/CFT framework:

Written AML/CFT policies and procedures, KYC/KYB methodology, transaction monitoring system description

IT and security documentation:

IT infrastructure description, DORA compliance overview, cybersecurity and business continuity plan

Office confirmation:

Lease agreement or ownership documentation for the operational premises

COREDO assists in preparing, verifying, and translating all required documents to meet the specific regulator’s format and language requirements.

Why Choose COREDO

COREDO is a Prague-based advisory firm specialising in financial licensing in the EU.

Experience:

Since 2016, COREDO has supported financial licensing projects for clients across EU jurisdictions. This represents deep expertise and thorough knowledge of regulatory nuances in each country.

Dedicated manager:

Each client is assigned a personal manager who oversees the entire process from start to finish. The manager ensures deadlines are met, document quality is maintained, and communication with the regulator is effective.

Full-cycle service:

COREDO handles the entire workflow: document preparation, application filing, negotiations with the regulator, and licence issuance. You only need to provide initial data and approve key decisions.

Geography:

We operate in all 27 EU member states and other key jurisdictions (Canada, Singapore), enabling you to select the optimal option for your goals.

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Our Experts

Pavel Kos

Head of Legal. Has been with COREDO since June 2017 and has headed the legal team since July 2020. Possesses extensive experience in supporting financial licensing projects in the Czech Republic and other EU jurisdictions.

Alena Mach

Executive Director

Nikita Veremeev

Founder & NED

Gregory Lutsenko

Head of Compliance

Case Studies

Case 01Fintech Startup in Czech Republic.

A Czech fintech firm with EUR 6,000,000 capital sought Banking Licence for deposit-taking and lending operations. COREDO prepared comprehensive licensing documentation including business plan, governance structure, IT infrastructure specification, and AML/CFT compliance framework. ČNB application filed and approved in 5 months; bank commenced deposits and lending operations immediately.

Case 02Investment Firm in Estonia.

An Estonian investment company with strong institutional backing applied for Banking Licence to offer full investment and advisory services. COREDO coordinated application including detailed risk management procedures, capital calculation documentation, and regulatory reporting infrastructure. Licence granted in 4 months; bank launched investment services across EEA within 2 weeks of authorisation.

Case 03Pan-European Payment Bank in Lithuania.

A Lithuanian payment processor sought Banking Licence to expand beyond payment services into transaction financing and corporate lending. COREDO managed multi-phase application including compliance infrastructure upgrades and capital adequacy calculations. Bank licensed in 6 months; obtained passporting rights to 22 additional EU/EEA markets within 3 months of licence issuance.

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Frequently Asked Questions

What happens if the regulator requests additional information during the review process?

Requests for additional information (RFI) are common and extend the review. COREDO project managers track all incoming regulatory queries and respond within prescribed deadlines. Proactive preparation of complete, well-structured documentation at the outset significantly reduces RFI frequency and delays.

Can an existing company apply for a banking licence, or must it be a new entity?

An existing company may apply for a banking licence, provided it meets capital, governance, and operational requirements. However, regulators often favour purpose-built applicant entities with clean and transparent ownership structures. COREDO advises on whether corporate restructuring before the application would improve approval prospects.

Is it permitted to conduct banking activities before the licence is officially issued?

No. Taking deposits or other repayable funds from the public is prohibited without a banking licence, and other regulated banking activities may not start before authorisation either. A breach is sanctioned under national law and may also lead to supervisory measures. Applicants may use parallel structures (e.g., EMI or PSP licence) for pre-licensing operations if needed.

On what grounds is an application rejected, and how does COREDO help prevent them?

Under CRD IV a regulator refuses authorisation when initial capital is below the required minimum (as a rule EUR 5,000,000), shareholders with qualifying holdings are not suitable, management does not meet fit-and-proper requirements, or governance and risk management are not sound. COREDO conducts a comprehensive internal pre-submission review to identify and resolve such issues before the application is filed.

How does a banking licence differ from an EMI or PSP licence?

Only a banking licence allows a company to accept deposits from the public and lend for its own account; EMIs and PSPs may grant only credit linked to payments. An EMI may provide payment services and issue electronic money, while a PSP provides payment services only. The capital differs as well: EUR 5,000,000 for a bank, EUR 350,000 for an EMI and EUR 20,000–125,000 for a PSP.

Contact COREDO

Ready to obtain a licence? Contact the COREDO team for a consultation.

Tel.: +420 228 886 867 | Email: info@coredo.eu Office: K Cervenemu dvoru 3269/25a, Prague, 130 00

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