ECB s New Rules A Nightmare for NB PSPs - read in the blog of the company COREDO

Nikita Veremeev

31.07.2025 | 6 min read

Updated: 31.07.2025

In 2025, the European payment services market found itself at the center of seismic shifts: according to the European Central Bank, in just the last year, the share of non-bank payment service providers (NB-PSPs) in cross-border transactions grew by 27%, and the volume of funds placed in safeguarding accounts exceeded €100 billion for the first time. But behind this growth lies a new reality: the enactment of Regulation (EU) 2024/886 and accompanying ECB rules, already described as the most stringent regulatory challenge for the fintech industry in recent years.

Why such ambitious reforms? The regulator aims not only to enhance financial stability and transparency of Eurosystem payment systems but also to level the playing field between banks and NB-PSPs, tightening requirements for access, fund storage, and AML compliance. However, for most non-bank players, these changes do not just present new tasks but a real stress test for business models and operational processes.

Are you ready for NB-PSP fund storage limits at central banks to be monitored in real time, and new compliance requirements violations to lead to instant financial sanctions and even expulsion from payment system? How to avoid the traps of Regulation (EU) 2024/886 and turn new challenges into strategic opportunities?

In this article, I, Nikita Veremeev, founder of COREDO, share practical case studies, adaptation strategies, and expert analysis of new ECB rules — so you not only survive but strengthen your position in the new competitive environment. Read to the end: here you will find not only risk analysis but also step-by-step recommendations, proven in practice by our team.

Regulation (EU) 2024/886 for NB-PSPs

Illustration for the section "Regulation (EU) 2024/886 for NB-PSPs" in the article "ECB’s New Rules- A Nightmare for NB-PSPs"

Regulation (EU) 2024/886 for NB-PSPs fundamentally changes the rules of participation for non-credit payment organizations in the EU payment infrastructure. Now NB-PSPs can gain direct access to the TARGET system, creating new opportunities for competition and innovation in the payment market. Below are the key access criteria for NB-PSP to TARGET under this regulation.

NB-PSP Access Criteria to TARGET

Regulation (EU) 2024/886 introduces unified access standards for non-bank payment organizations to key Eurosystem infrastructures, including TARGET and related settlement systems. Now NB-PSPs, electronic money institutions (EMIs), and payment institutions (PIs) can apply for direct TARGET system access if they meet objective admission criteria: having a license in one of the EU countries, demonstrating robust IT infrastructure, and a transparent ownership structure.

Implementation of non-discriminatory access means that banks and NB-PSPs are formally equal in rights, but in practice, non-bank players must undergo a more complex due diligence procedure, including an assessment of operational risks, AML/KYC requirements, and compliance monitoring. Our experience at COREDO shows that successfully gaining access to central bank accounts requires not only legal preparation but also a deep understanding of the specifics of the Settlement Finality Directive (SFD) and integration with Eurosystem payment systems.

Fund Storage Restrictions and Safeguarded Accounts

One of the most sensitive innovations: strict restrictions on client fund storage in central bank accounts. Regulation (EU) 2024/886 establishes limits, the excess of which is automatically recorded in real time. For NB-PSPs, this means the need for constant monitoring of volumes in safeguarding accounts and the implementation of automated monitoring systems.

COREDO has repeatedly encountered cases where international NB-PSPs, entering the EU market, underestimated requirements for safeguarding client funds. A solution developed by our team includes the integration of compliance monitoring modules and regular audits, allowing risks of limit violations to be timely identified and the likelihood of sanctions minimized.

Therefore, implementing an effective client fund storage control system becomes critically important, especially in the context of potential access restrictions or exclusion of NB-PSPs from payment systems, which are detailed further.

Exclusion from Payment Systems: Conditions and Sanctions

The new ECB rules provide clearly defined financial sanctions for NB-PSPs for violations of fund storage limits and other compliance requirements. In some cases, expulsion from the payment system is possible — exclusion from TARGET or other key infrastructures, effectively meaning loss of access to the EU market.

COREDO’s practice confirms: to minimize the risk of fines and exclusion, it is crucial not only to comply with the limits but also to document all actions concerning safeguarding funds, maintain transparent reporting, and regularly interact with national regulators. Otherwise, even a single violation can lead to multimillion financial penalties and operational blockage.

Risks for Non-Bank Payment Organizations

Illustration for the section "Risks for Non-Bank Payment Organizations" in the article "ECB’s New Rules- A Nightmare for NB-PSPs"
Risks for non-bank payment organizations are becoming an increasingly relevant topic amidst their growing role in the financial system. Regulatory peculiarities, technological, and operational challenges form a complex of factors that can affect the stability of such companies: let’s examine key risks and their consequences in more detail.

Consequences of Fund Storage Limit Violations

Violations of central bank account fund storage limits are now automatically recorded, and sanctions can be applied without prior notification. For NB-PSPs, this means not only financial losses but also reputational risks and the threat of expulsion from the payment system. In one COREDO case, a client faced operational blockage after exceeding the limit by just 2%, necessitating the urgent implementation of an automatic monitoring system and a review of internal procedures.

AML/KYC Risks for NB-PSP After 2025

Regulation (EU) 2024/886 and new ECB standards tighten AML compliance requirements for payment organizations. Now NB-PSPs are obliged not only to implement a risk-based approach to client identification but also to ensure continuous compliance monitoring, integrating processes with national and European registries. Special attention is given to crypto-asset service providers (CASPs), for whom AML/KYC requirements become even stricter.

The COREDO team implemented a comprehensive strategy for a major NB-PSP, including regular internal audits, staff training, and process automation for client verification. This approach not only meets new requirements but also reduces operational risks.

IT Risks and Infrastructure Requirements

The implementation of new ECB rules requires NB-PSPs to modernize their IT infrastructure, integrate fraud prevention technologies, and ensure the uninterrupted operation of safeguarding accounts. Special attention is given to cybersecurity, data protection, and compatibility with instant payments infrastructure.

In COREDO’s practice, cases were reported where insufficient IT system readiness led to settlement delays and even temporary suspension of TARGET access. Therefore, we recommend regular infrastructure testing and investing in modern compliance monitoring solutions.

NB-PSP Adaptation to Regulation (EU) 2024/886

Illustration for the section "NB-PSP Adaptation to Regulation (EU) 2024/886" in the article "ECB’s New Rules- A Nightmare for NB-PSPs"
Adapting NB-PSP to Regulation (EU) 2024/886 requires implementing new procedures and revising existing practices to comply with European standards for payment services provision. Special attention is paid to risk management and ensuring effective client fund protection, which becomes a central element amidst the tightening regulation and responsibility of payment service providers.

Risk Management and Client Fund Protection

Effective safeguarding account management is a key element of the adaptation strategy. The COREDO team recommends implementing automated limit control systems integrated with internal and external registries, as well as conducting regular stress tests of operational processes. This approach allows timely identification of potential violations and risk minimization of sanctions.

In one of COREDO’s projects for a European NB-PSP, an automatic notification system about approaching the fund storage limit was implemented, allowing the client to avoid fines and maintain regulator trust.

Moving on to legal support issues for NB-PSP in Europe, it is important to consider the specifics of local regulation and compliance requirements.

Legal Support for NB-PSP in Europe

Legal support becomes a critical success factor for NB-PSPs entering the EU market or expanding their activities. Licensing NB-PSPs in the EU requires a deep understanding not only of Regulation (EU) 2024/886 and PSD2 but also of the specifics of interacting with national regulators.

COREDO’s experience shows that regular legal audits, preparation for inspections, and support during the licensing process help not only minimize compliance risks but also expedite entry into new markets.

Instant Payments: Integration and Innovation

Instant payment infrastructure is becoming the standard for the European market, and integration with instant payments regulation opens new opportunities for fintech companies. For NB-PSPs, this means the need to modernize IT systems, implement new security protocols, and train staff.

COREDO developed a phased integration strategy for instant payments for one of its clients, considering ECB and national regulator requirements, which not only increased transaction speed but also strengthened competitive market positions.

New ECB Rules and EU Fintech

Illustration for the section "New ECB Rules and EU Fintech" in the article "ECB’s New Rules- A Nightmare for NB-PSPs"
New ECB rules and EU fintech initiatives fundamentally change the financial services landscape, setting stricter requirements for innovations, security, and regulation of digital payments. In this context, understanding how the new standards affect the operations of traditional banks and non-bank fintech companies, as well as their differences, becomes particularly important.

Banks and NB-PSP: What’s the Difference?

Regulation (EU) 2024/886 formally equalizes the rights of banks and NB-PSPs to payment system access, but in practice, differences in capital adequacy requirements, operational reserves, and compliance monitoring remain. This creates new barriers for non-bank players, but also stimulates innovation and the development of open banking.

COREDO notes that NB-PSPs investing in process digitalization and digital euro integration gain a competitive edge through speed and flexibility in client servicing.

NB-PSP Prospects in Asia and Africa

The influence of new ECB rules extends beyond the EU: NB-PSPs planning expansion into Asian and African countries face the need to adapt business processes to varying compliance and fund safeguarding standards. COREDO’s experience in supporting cross-border payments shows that a successful market entry strategy requires not only legal support but also a deep understanding of local regulatory requirements.

In a recent case, COREDO’s team provided comprehensive support to an NB-PSP launching operations in Singapore and Dubai, integrating European AML/KYC and safeguarding accounts standards with local requirements.

This approach allows companies to minimize regulatory risks and ensure sustainable development when entering new markets.

Practical Advice for NB-PSP and Business

Risk/Requirement	Practical Solution	Responsible Department
Fund Storage Limits	Implementation of Automatic Monitoring	Financial/IT
AML/KYC Compliance	Audit and Staff Training	Legal/Compliance
Instant Payment Integration	IT Infrastructure Modernization	IT/Operational
Interaction with Regulators	Regular Consultations with Lawyers	Management/Legal

COREDO’s practice shows that effective adaptation to Regulation (EU) 2024/886 requires a systematic approach:

Analyze new compliance requirements and integrate them into business processes.
Implement automated compliance monitoring and limit control systems.
Organize regular internal and external audits, including preparation for inspections by national and European regulators.
Invest in employee training on AML/KYC requirements and risk-based approach.
Modernize IT infrastructure for integration with instant payment infrastructure and fraud prevention.
Maintain constant dialogue with regulators and participate in industry initiatives for developing unified access standards.

Conclusions and Recommendations for Business

Illustration for the section "Conclusions and Recommendations for Business" in the article "ECB’s New Rules- A Nightmare for NB-PSPs"
The implementation of Regulation (EU) 2024/886 and new ECB rules: is not just another wave of regulation, but a fundamental transformation of the competitive environment for NB-PSPs. The tightening of requirements for safeguarding accounts, fund storage limits, and AML compliance calls for strategic re-evaluation of business models, investments in IT, and legal expertise by entrepreneurs and top managers.

COREDO’s experience confirms: those who perceive new rules as an opportunity for development rather than a threat gain access to new markets, strengthen customer and partner trust, and minimize risks of financial sanctions and expulsion from the payment system.

I recommend using this period of change for comprehensive process diagnostics, implementing modern compliance monitoring tools, and building partnerships with regulators. Only then can NB-PSPs not only comply with Regulation (EU) 2024/886 but also become leaders in the new fintech ecosystem of Europe and the world.