Payments licensing is where the regulatory question and the banking question collide. The authorisation you can obtain, and the authorisation that will actually get you banked, are sometimes the same and sometimes very much not — and the difference is discovered late and expensively if nobody tests it up front.
We lead with the banking constraint. What the sponsor bank or correspondent will accept determines which authorisation is worth having; only then does it make sense to compare regimes on capital, substance and timeline.
The families we work across: EU EMIs and payment institutions, UK and offshore PSP authorisations, money-transmission and MSB registrations, MTO regimes and offshore bank charters.
- You need to hold customer funds and are unsure whether an EMI/PSP authorisation, a registration or a partner model is right.
- A licence application has stalled on a regulator query you cannot resolve.
- You are choosing between an EU authorisation and an offshore one and need the trade-offs made concrete.
- Your current authorisation no longer covers the products you sell or the markets you serve.
Bankability before filing
A licence that no bank will onboard is a filing fee with extra steps. We test the banking outcome before the application is prepared.
Capital and safeguarding designed together
Initial capital, own-funds and safeguarding requirements interact. Structuring them in isolation produces an application that cannot be funded.
Substance matched to the regulator
Local directors, resident officers and a genuine compliance function are a cost in some regimes and a hard requirement in others. We size the substance to the regime you choose.
- Regime comparison against capital, substance, timeline and banking access
- Application strategy and the sequencing of entity, capital and compliance
- Full application pack — business plan, financial model, AML/CFT programme, policies and exhibits
- Regulator engagement, query handling and coordination of local counsel and auditors
- Safeguarding and own-funds structuring where applicable
- Banking introductions and go-live support
- 01
Diagnostic
A structured working session on banking & payments licensing — what you are building, the markets you need, and the constraints that will decide the outcome. You leave with a written read, not a proposal to read later.
- 02
Structure & pathway
We settle entity, ownership and jurisdictional architecture first, because it determines every downstream decision — what can be licensed, what a bank will accept, and what the regulator will ask.
- 03
Build the file
Documentation, policies, financial model and disclosures prepared to the standard the regulator or counterparty actually applies — decision-ready on first submission.
- 04
Execute
Filings, regulator engagement, partner onboarding and integration managed end to end, with local counsel, auditors and providers coordinated where needed.
- 05
Operate & scale
Authorization is the start, not the finish. We stay through go-live — banking, payments, compliance staffing — and through the first expansion market.
They do different jobs. An EU authorisation gives you passporting and a credible answer to European banks and counterparties, at real cost in capital and substance. An offshore authorisation is faster and cheaper and serves non-EU markets, but is frequently declined by tier-1 banks. The honest answer usually depends on where your customers and your banking are, not on the fee.
It depends entirely on the regime and the activities, and it is never just the headline minimum — own-funds and safeguarding obligations usually exceed the initial capital figure. We model the real requirement, including what has to be placed and evidenced, rather than quoting the published minimum.
Often yes, and it is usually sensible, provided the arrangement is documented and the limits are respected. It buys time only if the transition is planned — we treat the partner arrangement as an interim state with an explicit end, not as a permanent answer.
Incomplete first submissions and unresolved banking arrangements. The single biggest lever on total time is filing a file the regulator cannot immediately question, which is why the preparation work in this engagement is front-loaded.