Practical tips for navigating modern banking licenses
Image by Mohamed Hassan from Pixabay
Navigating a banking or payments license today can feel complex, but it becomes manageable with a clear plan. Scope what services you truly need, build your application around controls, customer outcomes, and the tech you can actually operate.
Map your license to the exact services you offer
List the concrete services you plan to provide in the first 12 months. Trim anything nice-to-have that complicates your scope without adding revenue. Regulators look for clarity: a focused plan with clear customer journeys and money flows gets fewer questions.
If you need to gather balances and transactions from customer accounts, that is a different regulatory footprint than initiating payments. Separating these early helps you choose the right track and avoid over-licensing.
Understand AIS, PIS, and the lighter RAISP option
Account information services let you read financial data with user permission. Payment initiation services let you start payments from a user’s account. Each triggers different prudential and operational expectations.
Many firms discover that they only need AIS at launch. The Account Information Service Provider route can be less demanding than a full payment institution, as it keeps capital needs and ongoing complexity down while you validate product-market fit. You can expand your permissions later once the data shows where to invest.
The regulator explains that firms offering only AIS can register under a lighter regime compared with fully authorised entities. This sharper fit reduces initial friction while still holding you to conduct and data standards.
Consent and customer trust 101
Customers must give explicit consent before you access their accounts, and they should understand what data you will read, for how long, and how to revoke access. A regulator explainer to consumers stresses that AIS and payment initiation services operate only with clear consent and that customers can withdraw it at any time, so your interfaces need to make this easy and visible.
Transparent flows reduce friction and increase conversion. Build consent prompts that are specific, time-bound, and auditable. Treat revocation like a first-class path, with a one-click off switch and instant confirmation.
Built to the open banking standard
Use mature standards to shrink integration risk. The Open Banking specifications set expectations for AIS flows and require you to capture explicit PSU consent with a clear scope. Aligning with these specs helps you interact with banks, document technical controls, and speed up security reviews.
Operationally, standard APIs make your vendor audits easier. They reduce the chance of brittle one-offs that break when a bank changes its stack. Start with token lifecycles, data minimisation, and event logging that match the spec so your compliance narrative mirrors your code.
Watch the new EBA compliance pieces
EU supervisors keep tightening operational resilience. Recent guidelines introduce shared expectations on policies, procedures, and controls to comply with restrictive measures and other cross-cutting obligations. Translate this into living documents, playbooks, and training, not just static PDFs.
Use a gap analysis to map what you already do versus what the guidance expects. Embed controls into tickets and runbooks so evidence appears automatically during daily work. This avoids scramble mode when auditors ask for proof.
Assemble a complete application pack
Photo by Anna Shvets
Your application tells a story about fitness and readiness. Make that story easy to follow with crisp structure, consistent definitions, and mapped controls.
- Business plan with realistic unit economics
- Governance chart, role descriptions, and independence of control functions
- Policies for risk, AML, sanctions screening, and incident handling
- Third-party register with contracts and exit plans
- Information security framework, including access control and key management
- Operational resilience playbooks and testing evidence
- Financial projections and funding letters that match your growth plan
Keep versions under control. Tag every policy to its owner, review cadence, and the board committee that approves changes.
Plan your project timeline and governance
Work backward from the point where you can safely onboard customers. Create a weekly plan that covers documentation, control testing, and vendor due diligence. Assign a single accountable owner for the application dossier and a separate owner for live operational readiness, and have them meet every week to reconcile gaps.
Run a pre-submission mock interview with an external advisor. Use it to stress test your risk narrative, decision logs, and how your tech enforces policy. Document the changes you make from that session so you can demonstrate a feedback loop to supervisors.
Regulatory change never stops, but a focused plan keeps you moving. By narrowing your scope, building on standards, and proving controls in day-to-day operations, you can turn licensing from a blocker into a milestone. Keep your documents living, your metrics visible, and your customer consent crystal clear so you are always ready for the next step.