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Small-scale Payment Institution (SPI)

Small-scale Payment Institution (SPI)

A small-scale payment institution licence is an ideal solution for entities that want to enter the payment services market but do not need extensive payment institution authorisation. This licence allows the provision of payment services in the Czech Republic up to a limit of EUR 3 million per month in payment transaction amounts, calculated over the last 12 months, i.e. a maximum of EUR 36 million per 12 months.

This approach provides a pragmatic pathway into the financial services market, allowing you to test your business model in local conditions without large investments while providing sufficient room for growth.

What can we do for you?

  • We will assess your business model and evaluate it from the perspective of the appropriate licence for the provision of payment services (payment institution, small-scale payment institution etc.).
  • We will discuss with you the scope of payment services you should apply for in the licensing procedure before the CNB.
  • We will prepare a detailed checklist for the application for the relevant licence.
  • We will advise you on the appropriate organisational structure and internal management.
  • We will help you prepare a detailed business plan as one of the most important parts of the licence application, including financial forecasts.
  • We will arrange a personal meeting with the CNB to discuss the business plan before submitting the licence application;
  • We will prepare all necessary internal regulations, including AML/CFT guidelines, regulations on the provision of payment services, risk management and outsourcing;
  • We will assess the requirements for persons with qualified participation in the client and senior management, including their trustworthiness;
  • We will create the necessary client documentation;
  • We will help you prepare all other relevant documents for the licence application, including resumés, affidavits and other declarations;
  • We will assist you in obtaining a draft agreement with a bank for the management of bank accounts on which users’ funds will be held, or in obtaining a draft agreement with an insurance company or the necessary insurance;
  • We will ensure that the authorised representatives through whom you will provide payment services are entered in the list maintained by the CNB;
  • We will guide you through the entire licensing process;
  • We will actively communicate with the CNB throughout the licensing procedure and, in cooperation with you, we will ensure that any information and documents requested by the CNB are provided, including participation in any meetings with CNB representatives;
  • Once you obtain the licence, we will be happy to assist you in fulfilling your regular reporting obligations to the CNB, ensure compliance, assist you in the event of an inspection by the CNB, or provide you with any other legal services.

If you are interested in obtaining a small-scale payment institution licence, arrange an initial meeting with us, where we will discuss all the steps that need to be taken together to achieve this.

People

Jan Šovar, partner Finreg Partners

Jan Šovar

Partner

Ondřej Mikula, partner Finreg Partners

Ondřej Mikula

Partner

Petra Šimůnková, advokátka Finreg Partners

Petra Šimůnková

Associate

Denis Tichánek, advokátní koncipient Finreg Partners

Denis Tichánek

Associate

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