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Payment Institutions (PI)

Payment Institutions (PI)

A payment institution licence is a comprehensive authorisation allowing the provision of a wide range of payment services without any volume limits. This differs significantly from a small-scale payment institution licence, which is limited to payments totalling EUR 36 million over a 12-month period.

This licence is intended for entities that plan to operate more extensive payment solutions, such as platforms for foreign payments, payment gateways or other payment solutions, including wallets or PSD2 services.

Obtaining licences in the field of payment services is one of the areas in which our law firm regularly specialises, and we therefore have extensive experience in this field. Thanks to our approach, we have managed to significantly shorten the length of the licensing procedure itself and obtain licences for our clients in record time, which is also appreciated by our competitors.

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, payment account information 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 projections.
  • We will arrange a personal meeting with the CNB to discuss the business plan before submitting the licence application.
  • We will help you establish appropriate rules for calculating capital adequacy.
  • We will advise you on the adequate setup of information and communication (ICT) systems and procedures, including in accordance with the regulations under the new DORA regulation.
  • We will prepare all necessary internal regulations, including AML/CFT guidelines, regulations on the provision of payment services, risk management, conflicts of interest or outsourcing.
  • We will assess the requirements for persons with qualifying holdings in the client and senior management, including their trustworthiness and expertise.
  • We will prepare the necessary client documentation.
  • We will assist you in preparing 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 maintenance of bank accounts on which clients’ 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;
  • We will help you secure the possibility of cross-border provision of payment services.
  • After obtaining the licence, we will be happy to assist you in fulfilling your regular reporting obligations to the CNB, ensure compliance and internal audit, 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 payment institution licence, arrange an initial meeting with us, where we will discuss all the necessary steps with you.

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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