Small-scale payment service providers, SPIs, (“Providers”) and small-scale electronic money issuers, SEMIs, (“Issuers”) authorised by the Czech National Bank (CNB) before 13 January 2018 should take note.
If they have not already done so, they must demonstrate to the CNB by 13 October 2018 that they meet the relevant requirements under the new legislation governing payment transactions. Failure to do so will result in the CNB revoking their authorisation to operate.
While the CNB has published basic guidance on its website outlining the documents required to maintain authorisation, it is important to emphasise that compliance extends beyond meeting the deadline. The CNB may still initiate proceedings to revoke a licence if the Provider or Issuer fails to adequately document compliance with the requirements.
Proper preparation and a high degree of expertise in drafting the relevant documents are therefore essential. The documentation must not only comply with the legal requirements at the time of submission but also remain complete and accurate when the CNB requests any additional information or clarification.
