Pragmatic aproach

Licensing through compliance by design

The financial services sector is becoming increasingly diversified and competitive with established and innovative tech companies entering the market, fuelled by business, technological and regulatory developments. For example, PSD2 and Open Banking introduce licensed third parties providing account information and payment initiation services. Another driver for more diverse ecosystems is the introduction of a licensing regime for crypto exchanges and wallet providers under AMLD5. Licence requirements have a broad organisational impact in areas such as governance, risk management, client onboarding, and reporting.

INNOPAY helps FinTechs with preparing for a licence request, as well as with acquiring and retaining the licence in an efficient manner. We follow a pragmatic approach in which we provide a clear overview of the requirements, how to embed these within your current business model and operations, and how to communicate with the supervisor effectively to ensure a lean and quick procedure (as these procedures can easily last over 9 months if done incorrectly).


Strategy l Quick scan 

Before launching a new product or service, the opportunities and (operational and compliance) costs involved need to be carefully considered. We help FinTechs developing a healthy business case through a tailored quick scan (approx. 4-6 weeks) on topics such as strategy validation (product, competition, market), regulatory assessment (gap analysis) and operational readiness. This way FinTechs can make a substantiated decision on whether to apply for a licence and what support is needed with the subsequent strategy execution.

Implementation Support l Licence applications & regulatory requirements 

We are experienced with licence applications and embedding the regulatory requirements in daily operations to ensure compliance by design. Next to implementing the licensed business environment, we can help with a better understanding of the requirements and strategic implications of regulations such as GDPR, PSD2 and AMLD5. Often all these regulations are seen as an impediment to innovation, but we are keen on identifying the opportunities that arise from them.

Implementation Support l Operating model (re)design 

Successful strategy execution is a key capability for sustainable growth and/or maintaining market position in the FinTech landscape, especially when providing regulated services. We support FinTechs who are struggling to align their strategy with their daily operations and at the same time need to strike a balance between innovation and compliance requirements. We help to (re)design the operating model from an integrated, activity-based perspective which ensures compliance by design without losing focus on your business goals.

Do you want to learn more? Contact us!


Do you need more information on how you can successfully obtain and retain a PSD2 license? Download our approach below:

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