COREDO – EU Legal & Compliance Services Expert legal consulting, financial licensing (EMI, PSP, CASP under MiCA), and AML/CFT compliance across the European Union. Headquartered in Prague, we provide seamless regulatory solutions in Germany, Poland, Lithuania, and all 27 EU member states.
Nikita Veremeev
07.03.2026 | 6 min read
Updated: 07.03.2026
I often begin strategic sessions with clients by saying: a good bank business plan is both a document for the regulator and a practical operational map for the team. Over years of work in the EU, Singapore, the UK, Estonia, Cyprus, the Czech Republic, Slovakia and Dubai the team COREDO has implemented dozens of projects where the quality of the business plan determined licensing timelines, the design of AML/CFT processes and the bank’s real economics over a 3–5 year horizon. Our experience at COREDO has shown: when a bank business plan is based on a correct financial model, a clear operational architecture and mature risk management, the license is a consequence, not a goal.
In this article I will break down how to prepare a bank business plan that will withstand the close scrutiny of regulators and investors and at the same time become a tool for day-to-day management. I will also share practical frameworks, case studies and common mistakes that we at COREDO have learned to anticipate. The text is aimed at entrepreneurs and executives who are building a digital bank or strengthening a universal model and are looking for a partner for comprehensive support.
Structure of a bank business plan
I structure the bank business plan so that each section answers a specific question from the regulator and the investor. The first chapters cover positioning and the bank’s go-to-market strategy: segments (SME, corporate, retail), target markets in the EU and Asia, competitive landscape, the bank’s revenue sources and monetization model. Here we also set down the unit economics (CAC, LTV, payback period) and key financial KPIs (ROE, ROA, NIM, CIR), so that from the first pages the reader sees the connection between strategy and numbers.
The second part is the bank’s operating model: front-, middle- and back-office processes, a plan for implementing a core banking system, target architecture (microservice architecture and API strategy), integrations with the payment infrastructure (SEPA and euro payments, SWIFT gpi and payment optimization, integration with payment gateways and card schemes, acquiring and merchant acquiring). The solution developed at COREDO for neo-banks includes a digital onboarding and e-KYC model, biometrics, as well as the use of cloud services and SaaS in the bank for flexibility and speed of deployment.
The third part – risk management: a risk management plan for the bank, capital assessment and the bank’s capitalization, stress tests and scenario analysis, liquidity (Liquidity Coverage Ratio: LCR, Net Stable Funding Ratio, NSFR), market, interest rate and operational risks. COREDO’s practice confirms: it is precisely the combination of the financial model and ILAAP/ICAAP that makes the business plan a living document that helps make decisions daily.
Regulatory requirements for licensing
In the EU and Asia, bank licensing requirements are similar in spirit and differ in details. Regulators expect not only a well-thought-out strategy but also the “equipment” for execution: corporate governance (board, fit & proper), conflicts of interest and director independence, internal audit, control and GRC procedures, as well as a full compliance and AML framework. In recent projects we supported bank registration and licensing procedures for banks in the EU/Asia using a hybrid model: part of the interaction through sandboxes (sandbox and pilot projects with the regulator), and part in the standard process with a detailed roadmap.
The bank business plan template for submission to the regulator, which we developed at COREDO, includes separate chapters on regulatory reporting and the bank’s key KPIs: reporting to the central bank and the EBA, a breakdown of data assembly processes and the audit trail. We show in detail how the business plan demonstrates compliance to the regulator: from model governance policy to validation procedures and backtesting.
A separate section — Basel III and capital requirements: minimum capital and CET1 capital requirements, the capital adequacy ratio (CAR), CET1 and capital adequacy ratios over time. In every business plan I include ICAAP and an assessment of internal capital needs, as well as ILAAP and liquidity management. We quantify the liquidity buffer and liquidity stress, and describe the contingency funding plan (CFP) step by step: emergency funding sources, activation triggers, communications with the regulator.
Recovery and resolution planning (RRP) and BRRD are not a formality. The COREDO team builds RRP as a technical and managerial scenario: how to preserve critical functions, how to launch the recovery and resolution plan without stopping payments, and how to ensure continuity of core banking during force majeure. This approach increases the regulator’s and investor’s confidence.
Bank financial model
Bank financial model: the central part of the business plan. I start with a projection of profit and loss for the bank (P&L), the balance sheet and cash flows, substantiating forecasts for deposits, net interest margin (NIM) and the loan-to-deposit ratio (LDR). For funding sources we show the funding mix: retail deposits vs wholesale funding, costs and maturities, as well as the impact on NSFR/LCR in base and stress scenarios.
Next I break down the income and expense structure: revenue structuring: interest income vs fees, pricing models by product, operating expenses and the Cost-to-Income ratio. The bank’s capital expenditure plan (CapEx) and operating expenses (OpEx) are supported by an IT project roadmap so that the CIR looks realistic over the implementation horizon. In COREDO projects we always add an assessment of a bank project’s profitability (ROI), NPV and IRR for bank investment projects and sensitivity to key drivers (funding cost, CAC, delinquency rate).
Treasury operations and liquidity management I reflect in a separate tab: the bank’s liquidity plan, liquidity management plan and monthly LCR/NSFR parameters, the treasury’s trading and market activities, mechanisms for hedging interest rate and currency risk (interest rate hedging: swaps and derivatives; currency risk and currency hedge). This level of detail addresses regulator questions at the Due Diligence stage.
Collections and model in the credit portfolio
I build the loan portfolio analysis in the business plan around PD, LGD, EAD: the parameters of the credit model, as well as IFRS 9 and the expected credit loss (ECL) model. Scoring models and scoring procedures are documented through the full cycle: data sources, model validation and backtesting, cut-off calibration, drift monitoring. For the SME portfolio the credit risk assessment takes into account turnover seasonality and industry limit policies.
The credit underwriting process and limit policies set the discipline for growth. We integrate provisioning schemes and collection strategies, debt restructuring and workout processes with recovery metrics. In large cases COREDO deployed instruments such as syndicated loans and securitization when a client moved to a more aggressive risk transfer strategy and needed to free up capital without sacrificing yield.
Scenario analysis and stress testing: a support for ICAAP/ILAAP. I recommend including stress-scenario modeling for the portfolio (rising PD/LGD, decline in collateral values, rate spikes), liquidity stress and a CFP check. Such a section demonstrates the maturity of the risk culture and reduces requirements for additional information at the licensing stage.
Operating model: core banking and API
The bank’s operating model should explain how products turn into processes and IT components. I link the core banking implementation plan to the target architecture: microservice architecture and API strategy, an integration bus, open banking. Integration of PSD2 and open banking in the EU is a separate stream: PSD2, APIs and open banking form a partner ecosystem and accelerate the launch of niche services.
Correspondent relationships and the correspondent network are a critical part of payment capability. We document relationships with correspondent banks and SWIFT, connection to SWIFT gpi, as well as routing for SEPA and euro payments. Integration with payment gateways and card schemes supports acquiring and merchant acquiring, as well as the issuance of foreign-currency and multi-currency cards.
Data migration and data lineage when launching a bank are an area of increased regulatory scrutiny. I include core banking migration and integration risks in the overall risk register, specifying testing checkpoints, reversibility of changes and cut-over plans. Cyber resilience, penetration testing and SOC form the protection framework: plus an information security and cyber defense plan, incident response and a disaster recovery plan.
GDPR and protection of customers’ personal data are present as a common thread: data classification, minimization, encryption, subject rights. Outsourcing and supplier risk management, vendor due diligence and SLAs we capture in the contractual framework and the responsibility matrix, and we base business continuity on the business continuity plan (BCP) and fault tolerance. Internal and external audit, audit trail and GRC close the control loop and provide investor confidence.
Compliance and AML: automation
Compliance and AML in a bank business plan are not “a section for the sake of a section”, but a set of daily procedures. KYC and client identification processes, beneficial owner checks (UBO), CDD, Enhanced Due Diligence and client risk classes I describe in terms of triggers, timelines, SLAs and the responsibilities of process owners. I supplement the sanctions and AML compliance plan with sanctions scoring and sanctions lists, transaction monitoring and SAR/STR rules, as well as fraud detection and anti-fraud mechanisms.
I base the digital onboarding and e-KYC plan on biometrics, OCR/IDV, behavioral analytics and document verification from trusted sources. The solution developed at COREDO for one of the projects in the EU reduced the share of false-positive sanctions hits by 27% thanks to contextual name deduplication and a high-quality scenario monitoring tree. The regulator noted the transparency of logs and the training materials for the second line of defense.
Corporate governance is a separate compliance block. We detail the board, fit & proper, committees (audit, risk, compliance), conflicts of interest and directors’ independence. The regulatory gap-analysis and compliance roadmap close the “tails” between the current state and the target by the time of licensing, with measurable milestones and KPIs.
Commercial strategy and product growth
The go-to-market strategy for the bank in my projects relies on clear segmentation and a sequential product launch. The plan for developing the product lineup: SME, corporate, retail is built iteratively, starting with deposits, payment services and acquiring, then adding lending products and trade finance (letters of credit and supply chain finance), and, if necessary, custodial services, trust and private banking. This approach staggers capital and IT project requirements over time.
Marketing strategy and customer acquisition for the bank must be aligned with unit economics: CAC, LTV, payback period and channel capacity. The COREDO team implemented a hybrid approach with partnerships and referral programs, where a partnership strategy with fintech companies accelerated access to niche segments without inflating the performance marketing budget. Metrics to monitor scaling and portfolio growth: activation rates, cohort retention, share of active users, cross-sell rate: help avoid losing profitability during growth.
The hiring plan and organizational structure of the bank are tied to the timeline and key milestones of the bank’s launch: start of regulatory assessment, UAT for core banking, pilot payments, start of operations, expansion of the product offering. Assessing the impact of scaling on operational risks is mandatory: add checkpoints for SLA, load testing, and second-line staffing risks.
Investment memorandum and capital
The preparation of an investment memorandum and an investor pitch is based on the same model as the licensing sections. I clearly show the ROI assessment and project payback scenarios, the methodology for calculating NPV/IRR and sensitivity, as well as the key financial KPIs: ROE, ROA, NIM, CIR over time. For banking investment projects investors expect clarity on the capital plan: sources of capital, capital assessment and bank capitalization, the CET1/CAR trajectory, and dividend policy after the break-even point.
We discuss the long-term effects of digital transformation on the bank’s balance sheet openly: growth of intangible assets, the impact on OpEx, the scalability effect of SaaS, and margin compression due to competition in payment services and merchant acquiring. In some cases COREDO implemented a hybrid IT model: critical infrastructure on dedicated resources, and service components in the cloud with clear vendor due diligence and SLA.
Cases and lessons from COREDO
In a project to launch a digital bank in one of the EU countries, COREDO adapted a banking business-plan template for submission to the regulator to meet local requirements for the recovery and resolution plan. We strengthened CFP and funding routes, added a stress liquidity run-off for 30 and 90 days, and also expanded interaction with correspondent banks and SWIFT. Licensing proceeded on schedule, and the regulator specifically noted the maturity of the ILAAP and the transparency of LCR/NSFR metrics.
A client from Southeast Asia sought reinforcement of the credit unit and IFRS 9 ECL. The COREDO team deployed PD, LGD and EAD models with per-exposure segmentation, implemented model validation and quarterly backtesting, and synchronized scoring procedures with the limit policy. This reduced reserve volatility and improved NIM/ROE forecasting, which immediately reflected in the dialogue with investors.
In the case of migrating the core banking system at one of the European neo-banks we combined core banking migration and integration risks with an information security and cyber protection plan. COREDO’s practice confirms: without a detailed data migration plan and data lineage you will lose weeks resolving incidents. We built a phased cut-over, included load tests and incident response with clear escalation. The release went through without downtime of client services.
I would like to separately note AML/sanctions practices. For a clearing project in Europe COREDO strengthened compliance and AML in the bank business plan through multi-layered sanctions scoring, contextual lists and manual second review for elevated risks. This setup reduced the share of SAR/STR not supported by facts, while at the same time preserving service speed for SME clients.
Regulatory reporting and transparency
I always dedicate a chapter to regulatory reporting and the bank’s key KPIs: formats, deadlines, contact points, data quality controls. Regulators care not only about the numbers, but also about traceability: how data flows through systems, who owns the process, and where the audit trail is stored. For reporting to the central bank and the EBA we design a pipeline that allows quick changes when there are regulatory updates.
Interaction with the regulator benefits from openness. The COREDO team holds regular Q&A sessions and demonstrations of progress on the compliance roadmap. This approach reduces the risk of unexpected requests at the final stage and increases confidence in the project from the supervisory authority and investors.
What sets a bank business plan apart?
A strong plan does not hide complexities and directly answers the questions “how” and “by what means.” It shows how you will pass licensing stages in the EU/Asia, how the bank’s operating model is structured, how you calculate NIM and CIR, by what means you keep ROE within the target range, and why your monetization strategy is realistic. It discloses the recovery and resolution plan, explains CFP, demonstrates the maturity of ICAAP/ILAAP, and links each ambition to a measurable KPI.
The solution developed by COREDO for such tasks is not just a document, but a management system: a financial model, a risk policy, a technology roadmap, a compliance framework and regulatory logic. Such a package gives entrepreneurs and directors confidence in the timing and cost of launch, and gives the regulator grounds for trust.
COREDO’s approach to comprehensive support
I take on projects where COREDO’s value is maximal: Legal entity registration abroad, obtaining financial licenses (including a digital bank: neo-bank business plan), AML consulting, building an operating model and regulatory reporting. For each jurisdiction the COREDO team prepares a regulatory gap-analysis, creates a roadmap, collects directors’ dossiers for fit & proper and builds a hiring plan for critical roles.
Next we design the financial model: profit and loss projection for the bank, the bank’s liquidity plan, NPV/IRR, ROI, funding mix and LDR. In parallel we describe credit models PD LGD EAD, IFRS 9 ECL, build scenario analysis and stress testing, and prepare the ICAAP/ILAAP package. On the technology track we incorporate core banking, API, PSD2, SWIFT gpi, SEPA, acquiring and open banking.
In compliance we set up KYC/e-KYC, UBO, CDD/EDD, sanctions scoring, transaction monitoring and anti-fraud, with clear SLAs and performance metrics. In corporate governance we establish the board, committees, director independence, internal and external audit, GRC. At every stage the client sees a transparent timeline and the main milestones of the bank’s launch, as well as an assessment of the impact of scaling on operational risks with metrics for control.
Conclusions
A bank business plan is not a ‘thick folder’ for a license, but a living mechanism that turns strategy into numbers, processes and accountability. When it brings together the financial model, liquidity management plan, operating architecture, compliance and AML, as well as a mature risk management system, licensing in the EU or Asia becomes a manageable task. The COREDO team has gone through this process with clients more than once and has seen how a quality plan reduces launch times, increases regulator confidence and disciplines the business.
If you are preparing to launch a bank, building a digital bank, or strengthening an existing model, start with the right structure and honest math. Then: technology, processes and a risk management culture. COREDO’s practice confirms: consistency and transparency win even in complex jurisdictions, and a well-crafted business plan becomes your best argument before the regulator, investors and your own team.