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Account Information Service Provider (AISP)

Account Information Service Provider (AISP)

An account information provider is an entity that obtains and processes information about account holders’ payment accounts based on their consent via bank APIs. This type of service is a key element in the modern payment ecosystem, especially in connection with the development of open banking under PSD2.

A payment account information service is a service consisting of providing information about a payment account via the internet by an administrator who is not the bank managing the account. In practice, this means that if an entity aggregates or processes information about payments on a client’s payment account and provides it to the client without being the person directly managing the payment account, it must be authorised to act as an account information service provider.

One of the main uses of this service is to increase transparency and control over one’s own finances by linking information about accounts held with different providers and displaying it in one place.

Obtaining AISP licences is one of our areas of expertise. We helped our client obtain the first licence of this kind in the Czech Republic.

What can we do for you?

  • We will assess your business model and evaluate it from the perspective of the appropriate licence to provide payment services (payment account information institution, payment institution, etc.).
  • We will prepare a detailed checklist for the licence application.
  • 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 advise you on the appropriate 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, regulations on risk management, conflicts of interest and outsourcing;
  • We will help you describe the connection to the bank’s API and secure access;
  • We will assess the requirements for senior management, including their trustworthiness and expertise;
  • 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 contract with an insurance company that will insure you in connection with the provision of payment services, or in obtaining the necessary security;
  • We will guide you through the entire licensing process;
  • We will actively communicate with the CNB throughout the licensing process 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;
  • Once you have obtained your 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 account information 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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