Regulatory Framework
Payment institutions in the European Union are regulated by PSD2 (Directive (EU) 2015/2366 on payment services), which entered into force in January 2016; Member States have had to apply its rules since 13 January 2018.
PSD2 establishes uniform licensing rules, capital requirements, client fund protection standards, and security norms for all payment service providers. The key articles governing PI activity are:
Article 7 of PSD2 defines the minimum initial capital of a payment institution depending on the range of services provided. Article 28 of PSD2 enshrines the passporting mechanism — the right of a licensed PI to provide services across all EEA member states without obtaining separate licences in each country. Article 10 of PSD2 sets out requirements for client fund protection through segregation or insurance.
AML legislation operates in parallel: the national rules transposing Directive (EU) 2015/849 and, from 10 July 2027, the AMLR Regulation (Regulation (EU) 2024/1624) require PIs to implement robust KYC systems, transaction monitoring, and reporting.
On the regulatory horizon is PSD3 (the Directive to replace PSD2): on 27 November 2025, the European Parliament and the Council of the EU reached a provisional agreement on PSD3 and the accompanying PSR Regulation. Under the final compromise text, Member States will have 21 months after the Directive’s entry into force to transpose and apply it. Existing PI licences remain valid during the transitional period.
Regulatory supervision is exercised by national competent authorities: in Lithuania — Lietuvos Bankas (Bank of Lithuania), in Estonia — Finantsinspektsioon (EFSA), in the Czech Republic — Česká národní banka (ČNB), in Poland — Komisja Nadzoru Finansowego (KNF), in the United Kingdom — Financial Conduct Authority (FCA).
Requirements for Obtaining a PSP Licence
General requirements for obtaining a payment institution licence are established by PSD2 and further specified in the national legislation of each jurisdiction.
Payment Services Licensing Beyond the EU
For companies targeting markets outside the European Union, payment services regulation varies significantly by jurisdiction. Key non-EU jurisdictions with active payment services regimes include:
Canada — FINTRAC and the Bank of Canada. A payment service provider must be registered with the Bank of Canada under the Retail Payment Activities Act (RPAA) before it performs retail payment activities; money services businesses also register with FINTRAC and meet AML/CFT requirements. Neither regime sets a minimum capital amount. Instead, a PSP that holds end-user funds must safeguard them — in a dedicated trust account, in an account backed by insurance or a guarantee, or as otherwise prescribed (RPAA, s. 20). COREDO’s package for FINTRAC registration plus the Bank of Canada application takes approximately 4–6 months.
Singapore — Monetary Authority of Singapore (MAS). Regulation is governed by the Payment Services Act 2019 (PS Act). MAS issues three licence classes: money-changing, SPI (standard payment institution) and MPI (major payment institution), covering e-money, money transfers, digital payment token services, and merchant payments. Minimum base capital: SGD 100,000 (SPI) or SGD 250,000 (MPI). One of the most advanced regulatory regimes in the Asia-Pacific region.
Switzerland — SRO membership and FINMA FinTech Licence. There is no dedicated PSP licence. Payment service providers are financial intermediaries under the Anti-Money Laundering Act (AMLA, Art. 2(3)(b)) and must join a self-regulatory organisation (SRO) recognised by FINMA (Art. 14); a FINMA FinTech licence (Banking Act, Art. 1b) is needed to accept public deposits of up to CHF 100 million. PSD2 does not apply. SRO review takes approximately 2–3 months.
United Arab Emirates and Dubai. Regulation depends on the location: CBUAE regulates at the national level; DFSA covers operators in the DIFC; ADGM offers an alternative regime in Abu Dhabi; VARA oversees virtual-asset activities in Dubai. The sector is growing rapidly, particularly in international transfers.
United Kingdom — FCA. Payment institutions and e-money institutions are authorised by the Financial Conduct Authority (FCA). COREDO supports authorisation as an authorised e-money institution (AEMI) under the UK Electronic Money Regulations 2011: initial capital of at least EUR 350,000, COREDO fee from EUR 100,000 + VAT. The FCA usually assesses a complete application within 3 months; an incomplete one can take up to 12 months. The United Kingdom retains FCA authorisation post-Brexit; companies registered in the UK do not have automatic passporting rights to the EU.
PSP Licence Acquisition Process
The payment institution licensing process at COREDO consists of six sequential stages.
Preliminary screening and jurisdiction selection.
COREDO specialists analyse your business model, planned payment services, and target markets. Based on the screening, the optimal jurisdiction, licence type (PI, SPI, or EMI), and a preliminary documentation plan are determined.
Corporate structure preparation.
Registration of a legal entity in the chosen jurisdiction, arrangement of a registered office and physical presence, selection and verification of directors and key staff for Fit & Proper compliance.
Documentation development.
The complete set of licensing documents includes a business plan with 3-year financial projections, AML/CFT policy and procedures, IT infrastructure and security systems description, client fund protection mechanisms and internal risk management policies. COREDO prepares the legal documents and the application. Depending on the jurisdiction and the agreed scope, it drafts the business plan, financial projections and IT infrastructure description or supports you in preparing them. The quality of documentation directly affects the regulator’s processing speed.
Application submission.
COREDO prepares and submits the complete set of documents to the national regulatory authority. When the regulator’s review period starts depends on the jurisdiction; at the FCA, for example, the standard 3-month period runs from receipt of a complete application.
Regulator review.
The regulator conducts a comprehensive review: analyses the business plan, assesses the Fit & Proper status of directors, and reviews AML policies and IT infrastructure. During this period, the regulator may request additional documents or clarifications. COREDO ensures prompt responses to all enquiries. How long the review takes depends on the jurisdiction and on how complete the application is.
Licence receipt and launch of activities.
Following approval, the licence is published in the regulator’s register. The company gains the right to commence operations. COREDO provides support in setting up operational processes, configuring regulatory reporting, and, where necessary, assists with passporting notifications to other EEA countries.
Why COREDO
COREDO is a European law firm specialising in financial licensing since 2016. During this time, we have supported the acquisition of financial licences in the EU and beyond for clients from around the world.
Full-cycle support
From the initial consultation on licence and jurisdiction selection — to the regulator’s decision and post-licensing support. We handle document preparation and submission, communication with the regulator, and responses to queries during the review process.
Personal project manager
Each client is assigned a dedicated manager who oversees the entire process, monitors deadlines, and serves as the single point of communication.
Knowledge of European regulatory practice
The COREDO team knows the preferences and working practices of ČNB, EFSA, Lietuvos Bankas, KNF, and the FCA. This allows us to anticipate regulators’ questions and prepare comprehensive documentation right from the first submission.
Our Experts
Frequently Asked Questions
Ready to begin the PSP licence acquisition process? Contact our specialists for an initial consultation. We will screen your business model, help you select the optimal jurisdiction, and prepare an individual licensing plan.
We work with clients worldwide since 2016.
Related Services
For a complete picture of licensing and compliance, explore our related pages: