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Fintech & Payments

EMI and payment institution licensing, safeguarding, partnerships and ongoing compliance for businesses that move, hold or issue money.

Topics: EMI & PI licensingSafeguardingOpen bankingEmbedded finance

Payment cards with contact chips leaning against a stone block on a deep teal ground.

Who we advise

  • Electronic money and payment institutions
  • PSPs, gateways and payment orchestrators
  • Banking-as-a-service and card programme providers
  • Open banking (AIS / PIS) providers
  • Platforms embedding payments or accounts
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Specialisations

Business models we advise

Payment Institutions
Authorisation, safeguarding and conduct of business for payment institutions, including agent networks.
Electronic Money Institutions
E-money licensing, safeguarding, distribution through agents and distributors, and card programmes.
PSPs & Acquirers
Acquiring, gateway and payment service provider models, scheme rules and merchant onboarding obligations.
Payment Facilitators
Sub-merchant onboarding, card scheme registration and the regulatory position of the flow of funds.
Merchant Services
Merchant onboarding, underwriting and monitoring, and the contracts between providers and merchants.
Embedded Finance
Allocating regulatory responsibility between licensed providers and the brands that distribute their products.
Payment Platforms
Platforms that collect and pay out funds for others, and the licences and exemptions that apply to them.

Context

The regulatory landscape

The authorisation route and the bank accounts behind it decide what a payments or e-money business can offer and when it can go live. Regulators expect robust safeguarding, operational resilience and governance from the first day of authorisation, and banks expect the same before they provide the accounts that make the model work.

We advise payment and e-money institutions, PSPs, BaaS providers and companies embedding financial services into their products — from choosing the licence and preparing the application to safeguarding, partnerships, outsourcing and supervisory engagement after authorisation.

Typical matters

Where businesses need support

  • Selecting the regime

    Payment institution, e-money institution or an agent model — and in which jurisdiction — for a given product.

  • Safeguarding

    Designing and evidencing safeguarding that satisfies regulators, auditors and partner banks.

  • Operational resilience

    ICT risk management, outsourcing and third-party oversight requirements under frameworks such as DORA.

  • Partner bank relationships

    Securing and keeping safeguarding and operational accounts with credit institutions.

  • Passporting and expansion

    Using EU passporting rights and planning for markets where passporting is not available.

  • Embedded finance allocation

    Contracts and controls that set out which tasks the distributing brand performs and how the licensed provider oversees them.

Services

How we help

  • Regulatory & Licensing

    Licence strategy, applications and regulator engagement for gaming, payments, e-money, investment and crypto-asset businesses.

  • Banking & Payments

    Bank account opening, merchant accounts, acquiring, payment flows and safeguarding for international businesses, including gaming, crypto, forex and other high-risk models.

  • AML & Financial Crime Compliance

    AML/CFT programmes, MLRO-as-a-Service, independent AML/CFT audits, risk assessments, monitoring, sanctions and inspection support.

  • Information Security & Cybersecurity

    Fractional CISO support, ISMS and security programmes, certification and audit readiness, DORA, NIS2 and customer assurance for enterprise sales.

  • Privacy & Data Protection

    External DPO services and working privacy programmes: GDPR and global privacy laws, DPIAs, data mapping, transfers and ISO/IEC 27701.

  • Commercial & Technology Contracts

    Platform, white-label, B2B supply, SaaS, affiliate and outsourcing agreements, drafted and negotiated to close deals in regulated markets.

Jurisdictions

Relevant frameworks

Cartography by ROZSUD from Natural Earth data (public domain).

Insights

Related analysis

Practice note

DORA in practice for payment and e-money institutions

The Digital Operational Resilience Act (DORA) has applied since January 2025. For smaller payment and e-money institutions, most of the practical work lies in ICT third-party arrangements.

5 min read

Questions

Frequently asked

Do we need our own licence to offer payments in our product?

Not always. Depending on the flow of funds, an agent or distributor model with a licensed partner, or a specific exemption, may be available. We map the flow and tell you which route fits before you invest in an application.

Launching a payments or e-money product?

Show us how funds will flow and where you plan to operate. We weigh the licence, partner and banking options with you, then set out the work in a written proposal with scope, timetable and fee.

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