Regulatory Framework: ČNB and European Directives
The main supervisory authority in the field of financial services in the Czech Republic is Česká národní banka (ČNB) — the Czech National Bank. It is ČNB that carries out licensing, supervision and oversight of the activities of payment institutions, electronic money institutions, investment firms, banks and other supervised entities.
The key Czech legislative acts are based on European directives:
- Act No. 370/2017 Coll. on Payment Services implements Directive PSD2 (2015/2366/EU) and regulates payment institutions (PI) and electronic money institutions (EMI). Minimum capital requirements for PI range from EUR 20,000 (money remittance) to EUR 125,000 (full range of services), and for EMI — EUR 350,000 in accordance with Directive EMD2 (2009/110/EC).
- Act No. 256/2004 Coll. on Capital Market Undertakings (ZPKT) implements Directive MiFID II (2014/65/EU) and regulates the activities of investment firms, securities dealers and asset managers. Act No. 240/2013 Coll. on Investment Companies and Investment Funds (ZISIF) regulates alternative investment funds, including funds established under §15 — so-called “small” funds.
- Act No. 257/2016 Coll. on Consumer Credit transposes Directive 2008/48/EC and regulates the activities of credit institutions providing consumer loans.
Advantages of Obtaining a Financial Licence in the Czech Republic
Access to the European passport.
PI and EMI licences obtained in the Czech Republic grant the right to passporting — a notification procedure allowing the provision of services across all 30 European Economic Area (EEA) states without the need to obtain an additional licence in each country. Legal basis: Art. 28 PSD2 (for PI) and Art. 3 EMD2 in conjunction with PSD2 (for EMI).
Stable legal system.
Czech legislation is transparent and predictable. ČNB is one of the most authoritative regulators in Central Europe, recognised by partners throughout the EEA.
Wide range of licence types.
The Czech Republic offers a unique set of financial permissions: from a simple physical currency exchange for EUR 6,500 to a full-scale EMI with passporting rights. This makes the jurisdiction attractive for businesses of varying scale.
Low operational costs.
The cost of office sublease, qualified specialists and administrative services in Prague is significantly lower than in Western Europe, with a comparable level of expertise.
Licence for an indefinite period.
PI, EMI and most other licence types are issued without a time limit and do not require annual renewal fees.
Strategic location.
Prague is an international financial and business centre. Proximity to CEE, EU and CIS markets provides a convenient geography for international financial business.
General Requirements for Obtaining a Financial Licence
Requirements vary depending on the licence type, however there are a number of common conditions imposed by ČNB on most applicants.
Payment Terms
Payment for COREDO’s services on licensing projects is made in three instalments:
For special products (ZISIF §15, currency exchange), terms may differ — please enquire when requesting a consultation.
Procedure for Obtaining a Financial Licence in the Czech Republic
The licensing process takes place in several stages.
Preliminary analysis (2–4 weeks).
Evaluation of the business model, selection of the optimal licence type, preliminary discussion of the structure with COREDO experts. Signing of the agreement and commencement of work.
Company preparation (4–8 weeks).
If necessary — registration of a Czech company. Opening a corporate account, forming the management team, office sublease. Development of AML policy and internal procedures.
Application preparation (4–8 weeks).
Collection and preparation of the complete document package, development of the business plan and financial model, legal support.
Submission to ČNB and review.
Submission of the application to Česká národní banka. The regulator reviews the application within 3–6 months for small institutions and 6–12 months for PI, EMI and investment structures. During the process, ČNB may request additional documents or clarifications.
Licence receipt and launch.
Upon approval of the application, ČNB issues the licence. The company is entered into the regulator’s public register. If desired — passporting notification procedure to other EEA countries.
The total project timeline from the first consultation to licence receipt: from 5 to 12 months depending on the licence type and the client’s readiness.
Passporting: Operating Across the EEA
One of the key advantages of a financial licence obtained in the Czech Republic is the right to passporting within the European Economic Area. After obtaining a PI or EMI licence, the company may submit a notification to ČNB of its intention to provide services in another EEA country. ČNB notifies the host regulator, and upon completion of the notification procedure, the company is entitled to operate in the new market without obtaining a separate licence.
This possibility is based on Art. 28 PSD2 (for payment institutions) and Art. 3 EMD2 in conjunction with PSD2 (for EMI). Passporting extends to all 27 EU countries, as well as Norway, Iceland and Liechtenstein (EEA).
A similar procedure is provided for investment firms licensed under MiFID II (Art. 34–35 MiFID II) and for banks — in accordance with CRD IV (Art. 17–28).
Our Experts
Financial licensing projects in the Czech Republic at COREDO are led by a team of experienced lawyers who have been working with ČNB since 2016. The COREDO team has been supporting clients since 2016 — from initial business model analysis to licence acquisition and post-licensing support.
Frequently Asked Questions
Obtaining a financial licence in the Czech Republic is a complex but well-structured process with the right support. The COREDO team has been helping clients since 2016: we know ČNB’s requirements, can select the optimal licence type and support the project from the first consultation through to launch.