COREDO > Licensing > Banking Licences

Banking Licences

Banking Licences: Authorisation for Banking Activities in the EU

Banking Licences — authorization to conduct banking activities in the European Union under CRD IV (Directive 2013/36/EU). It allows a credit institution to accept deposits, issue loans, and provide a full range of banking services with a minimum capital requirement of 5,000,000 EUR, as well as operate under the EU passporting regime within the EEA.

COREDO supports the licensing process and structuring of banking projects across the EU.

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Who Needs a Banking Licence

A Banking Licence is required for any company that intends to conduct regulated banking activities in the EU. The most common applicants are:

Fintech startups

seeking to offer deposit accounts and lending alongside payment services

Investment firms

expanding into full banking services (asset management, lending, custody)

Payment institutions

that have grown beyond the scope of their existing EMI or PSP licence

Foreign banks

entering the European market via a newly established EU subsidiary

Family offices and private banks

structuring EU-based deposit and wealth management operations

A Banking Licence is required for any company that intends to conduct regulated banking activities in the EU. The most common applicants are:

Requirements for Obtaining a Licence

Applicants must meet strict regulatory requirements:

Minimum capital:

EUR 5,000,000, fully paid-up and held in an account at a credit institution within the EEA. This requirement is established by Directive 2013/36/EU (CRD IV, Article 12). The capital serves as a guarantee of obligations to clients.

Competent management:

Founders and board members must have relevant education, financial sector experience, and an impeccable reputation. Regulators screen candidates against sanctions lists (OFAC, EU sanctions) and PEP databases.

AML/CFT procedures:

Mandatory implementation of AML controls under Regulation AMLR (2024/1624). This includes client identification (KYC), beneficial owner verification (KYB), transaction monitoring, and regular audits.

IT infrastructure and security:

Development of robust data protection systems, operational resilience under DORA, GDPR compliance, and backup procedures.

Business plan:

Description of services, target audience, financial projections for 3–5 years, risk management strategy, and growth plans. The regulator assesses the viability of the business model.

Physical presence:

A registered office and operational centre in the licensing country.

How We Work: Licence Acquisition Process

Obtaining a licence is a multi-stage process that takes 3–7 months:

Stage 1: Document Preparation (3–5 weeks)

Collecting and preparing all required documents: articles of association, financial statements, management qualification records, business plan, IT infrastructure description, AML/CFT policies, and office documentation.

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Stage 2: Application Filing (1–2 days)

Official submission of the application to the national regulator. The review timeline begins.

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Stage 3: Application Review (2–6 months)

The regulator conducts a comprehensive analysis: evaluating management qualifications, reviewing the business plan, and verifying IT infrastructure and security. Additional information requests are common at this stage.

Timelines vary depending on the jurisdiction and completeness of documentation.

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Stage 4: Licence Issuance (1 week)

Upon a positive decision, the licence is published in the regulator’s register, and the institution may commence operations.

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Comparison Table: Banking Licences vs EMI vs PSP

Criterion	Banking Licences	EMI Licence	PSP Licence
Minimum capital	EUR 5,000,000	EUR 350,000	EUR 20,000–125,000
Deposit taking	✅ Yes	❌ No	❌ No
Lending	✅ Yes	❌ No	❌ No
Payment services	✅ Yes	✅ Yes	✅ Yes
Electronic money	✅ Yes	✅ Yes	❌ No
Typical timeline	3–7 months	3–6 months	2–4 months

Jurisdictions and Expansion Opportunities

COREDO provides licensing services in the following jurisdictions:

Jurisdiction	Features
Czechia	Proximity to COREDO HQ, experienced regulator ČNB
Estonia	Digital-first approach, fintech-friendly environment
Lithuania	Fast review process, fintech hub
Latvia	Competitive conditions
Poland	Major EU jurisdiction
Cyprus	International financial centre
Portugal	Stable regulatory framework

COREDO service pricing: available on request. Contact us for an individual quote.

Banking Regulation Beyond the EU

COREDO also assists financial institutions based outside the EU seeking authorisation for European banking operations. The regulatory landscape varies significantly across key jurisdictions:

United Kingdom (PRA/FCA):

Banking in the UK is regulated by the PRA and FCA. After Brexit, UK banks lost EU passporting rights and must obtain separate licenses to operate in the EU. The minimum capital requirement for new banks is GBP 1 million. Market access in the EU requires subsidiaries or locally licensed entities.

Switzerland (FINMA):

Banking licenses are issued by FINMA under the BankA (Banking Act). Switzerland is not part of the EEA, so EU passporting is not available. EU operations require a separate licensed entity within the EU, typically structured through cross-border regulatory planning and licensing processes.

Dubai and UAE (CBUAE/DFSA):

Banking is regulated by the Central Bank of the UAE (CBUAE) on the mainland and the DFSA in the DIFC. Expansion into the EU requires establishing an EU-licensed subsidiary. International structures are built through separate regulated jurisdictions and localized compliance frameworks.

For entities based in these and other non-EU jurisdictions, COREDO offers cross-border structuring advice and full-cycle EU licensing services. Contact us to discuss your specific situation.

Passporting: Expansion Across the EEA

A key advantage is the ability to expand operations to other EEA countries without obtaining additional licences. This is achieved through the passporting mechanism established by Directive 2013/36/EU (CRD IV, Articles 17–28). Once licensed in one jurisdiction, you may:

Open branches

in other EEA countries by notifying the local regulator

Provide services

in other jurisdictions without additional authorisation

Scale geographically

without additional licensing costs

The passporting mechanism is particularly valuable for companies planning growth across European markets. After obtaining a licence in one country (e.g. Czechia), you can rapidly enter other markets, saving time and resources.

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Required Documents

Applicants typically need to submit the following documentation package:

Corporate documents:

Articles of association, shareholder register, ownership structure diagram, proof of registered office

Financial documentation:

Audited financial statements (if existing entity), source of funds evidence, capital deposit confirmation

Management documentation:

CVs and qualifications of all board members and key function holders, criminal background checks, PEP declarations

Business plan:

Detailed description of services, target markets, financial projections for 3–5 years, governance model

AML/CFT framework:

Written AML/CFT policies and procedures, KYC/KYB methodology, transaction monitoring system description

IT and security documentation:

IT infrastructure description, DORA compliance overview, cybersecurity and business continuity plan

Office confirmation:

Lease agreement or ownership documentation for the operational premises

COREDO assists in preparing, verifying, and translating all required documents to meet the specific regulator’s format and language requirements.

Why Choose COREDO

COREDO is a leading European advisory firm specialising in financial licensing.

Experience:

COREDO has prepared and obtained over 100 financial licences for clients across all EU jurisdictions. This represents deep expertise and thorough knowledge of regulatory nuances in each country.

Dedicated manager:

Each client is assigned a personal manager who oversees the entire process from start to finish. The manager ensures deadlines are met, document quality is maintained, and communication with the regulator is effective.

Full-cycle service:

COREDO handles the entire workflow: document preparation, application filing, negotiations with the regulator, and licence issuance. You only need to provide initial data and approve key decisions.

Geography:

We operate in all 27 EU member states and other key jurisdictions (Canada, Singapore), enabling you to select the optimal option for your goals.

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Our Experts

Pavel Kos

Head of Legal. Pavel has led COREDO's legal team since June 2017. He specialises in obtaining banking and investment licences across EU countries. Education: University of Finance and Administration, Prague.

Case Studies

Case 01Fintech Startup in Czech Republic.

A Czech fintech firm with EUR 6,000,000 capital sought Banking Licence for deposit-taking and lending operations. COREDO prepared comprehensive licensing documentation including business plan, governance structure, IT infrastructure specification, and AML/CFT compliance framework. ČNB application filed and approved in 5 months; bank commenced deposits and lending operations immediately.

Case 02Investment Firm in Estonia.

An Estonian investment company with strong institutional backing applied for Banking Licence to offer full investment and advisory services. COREDO coordinated application including detailed risk management procedures, capital calculation documentation, and regulatory reporting infrastructure. Licence granted in 4 months; bank launched investment services across EEA within 2 weeks of authorisation.

Case 03Pan-European Payment Bank in Lithuania.

A Lithuanian payment processor sought Banking Licence to expand beyond payment services into transaction financing and corporate lending. COREDO managed multi-phase application including compliance infrastructure upgrades and capital adequacy calculations. Bank licensed in 6 months; obtained passporting rights to 22 additional EU/EEA markets within 3 months of licence issuance.

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Frequently Asked Questions

What happens if the regulator requests additional information during the review process?

Requests for additional information (RFI) are common and typically extend the review by 1–3 months. COREDO project managers track all incoming regulatory queries and respond within prescribed deadlines. Proactive preparation of complete, well-structured documentation at the outset significantly reduces RFI frequency and delays.

Can an existing company apply for a banking licence, or must it be a new entity?

An existing company may apply for a banking licence, provided it meets capital, governance, and operational requirements. However, regulators often favour purpose-built applicant entities with clean and transparent ownership structures. COREDO advises on whether corporate restructuring before the application would improve approval prospects.

Is it permitted to conduct banking activities before the licence is officially issued?

No. Deposit taking, lending, and other regulated banking activities are strictly prohibited prior to licence issuance. Breach constitutes a criminal offence in most EU jurisdictions and may also result in supervisory sanctions. Applicants may use parallel structures (e.g., EMI or PSP licence) for pre-licensing operations if needed.

What are the most common grounds for application rejection, and how does COREDO help prevent them?

Regulators most frequently reject applications due to: insufficient or unverifiable source of funds, fitness and propriety issues of management (sanctions exposure, adverse history), inadequate AML/CFT framework, or an unviable business plan. COREDO conducts a comprehensive internal pre-submission review to identify and resolve such issues before the application is filed.

Contact COREDO

Ready to obtain a licence? Contact the COREDO team for a free consultation.

Tel.: +420 228 886 867 | Email: info@coredo.eu Office: K Cervenemu dvoru 3269/25a, Prague, 130 00