Regulatory Framework
Payment institutions in the European Union are regulated by PSD2 (Directive (EU) 2015/2366 on payment services), which entered into force on 13 January 2016 and was transposed into the national legislation of all EU Member States by 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 EU’s Sixth Anti-Money Laundering Directive (AMLD6) and the succeeding AMLR Regulation (Regulation (EU) 2024/1624), which comes into full force in 2027, 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. After official publication, Member States will have 18 months to transpose it, meaning the new requirements will become mandatory approximately by the end of 2027. 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 RPAA. Payment services are regulated under the Retail Payment Activities Act (RPAA, 2024) and supervised by FINTRAC. MSB companies must register with FINTRAC and comply with AML/CFT requirements, as well as obtain provincial licences. Capital requirements: CAD 25,000 – 250,000 depending on the province. Licensing timeline: 3–6 months.
Singapore — Monetary Authority of Singapore (MAS). Regulation is governed by the Payment Services Act 2019 (PS Act). MAS issues two licence classes: MPI (large operators) and SPI (smaller operators), covering e-money, money transfers, digital asset tokenisation, and merchant payments. Minimum capital: from SGD 1 million (SPI). Review period: 4–6 months. One of the most advanced regulatory regimes in the Asia-Pacific region.
Switzerland — FINMA FinTech Licence. There is no dedicated PSP licence. Payment intermediaries operate under Art. 1b of the Banking Act (FinTech licence), provided they do not meet the threshold for a full banking licence. Oversight is carried out by self-regulatory organisations (SROs). PSD2 does not apply. Capital and operational requirements are lighter than for a banking licence. Timeline: 2–4 months.
United Arab Emirates and Dubai. Regulation depends on the emirate: DFSA covers operators in the DIFC; CBUAE regulates at the national level; ADGM offers an alternative regime in Abu Dhabi; VARA oversees crypto and digital payment services in Dubai. Minimum capital: AED 5–20 million (approx. EUR 1.3–5.3 million). Timeline: 4–8 months. The sector is growing rapidly, particularly in international transfers.
PSP Licence Acquisition Process
The payment institution licensing process at COREDO consists of six sequential stages.
Preliminary screening and jurisdiction selection (1–2 weeks).
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 (2–4 weeks).
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 (3–6 weeks).
Preparation of a complete set of licensing documents: a business plan with 3-year financial projections, AML/CFT policy and procedures, IT infrastructure and security systems description, client fund protection mechanisms, internal risk management policies. The quality of documentation directly affects the regulator’s processing speed.
Application submission (1–3 business days).
COREDO prepares and submits the complete set of documents to the national regulatory authority. The official review period begins from the date of submission.
Regulator review (2–12 months).
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. Review timelines vary: from 3 months in Estonia and Lithuania to 12 months in Spain and the United Kingdom.
Licence receipt and launch of activities (1–2 weeks after approval).
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 more than 23 jurisdictions 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.
The consultation is free. We work with clients worldwide since 2016.