PSD2 & Payment Institutions Licensing

Providing in-scope payment services in the EU may require authorisation as a payment institution or registration as an account-information service provider

PSD2 & Payment Institutions Licensing covers legal assessment, document preparation and implementation support in Europe. It is typically relevant to businesses, investors and organisations operating or transacting in one or more countries. The precise rules, competent authority and procedure depend on the subject matter, jurisdiction and facts, with EU and national law considered together.

Key points

  • PSD2 remains the applicable framework on the review date.
  • Service classification determines authorisation or registration.
  • Safeguarding and strong customer authentication are assessed separately.
  • Proposed successor rules are not treated as current law.

Jurisdiction and applicable framework

The applicable framework depends on the subject of the service, governing law and countries in which the structure or transaction has effect. EU law and current national legislation are assessed together.

Official sources

Last reviewed: 22 September 2026

Providing in-scope payment services in the EU may require authorisation as a payment institution or registration as an account-information service provider under the PSD2 regime currently applicable on 22 September 2026. We support classification, applications, safeguarding and strong-customer-authentication compliance without presenting proposed successor measures as current law.

We prepare the application dossier: business plan, programme of operations, governance arrangements, initial-capital evidence, and AML/CTF policies. We also advise on passporting notifications for cross-border services and the safeguarding of client funds.

Post-authorisation, we support compliance with SCA requirements, transaction-reporting obligations, incident-notification procedures, and the conduct-of-business rules that govern fee transparency and liability allocation.

What this includes

  • Payment-institution licence application
  • Programme-of-operations drafting
  • SCA & open-banking compliance
  • Client-fund safeguarding arrangements
  • Cross-border passporting notifications

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