🇪🇺EU Banking Licence Through the ECB: Requirements, Capital and Timing

On 10 August 2026 Revolut received its second full EU banking licence: the ACPR and the ECB approved the French Revolut Bank S.A. — alongside Lithuania's Revolut Bank UAB — with a Western Europe headquarters in Paris from 2027 and a pledged billion euros for the region. From the Choose France announcement on 20 May 2025 to the decision took roughly fifteen months: a rare public benchmark for a procedure usually described as "multi-year".

What a banking licence buys — and what an EMI lacks

On the depositor's side, the difference comes down to one word: guarantee. Balances at an EMI or payment institution are protected by segregation (safeguarding) — client money sits apart from the company's own — but there is no state insurance on top. A deposit at an EU bank is covered by a national deposit guarantee scheme under Directive 2014/49/EU: €100,000 per depositor per bank. For a family or group treasury these are two different risk classes — a wallet for turnover, a bank for balances.

For the fintech itself, the licence changes the economics. A bank takes deposits and turns them into a loan book: deposit funding and the interest margin stay inside the group instead of going to the partner banks every EMI product sits on. Qonto's founder Alexandre Prot puts it bluntly: being a bank is more profitable than being a payment institution. On top comes status — an ECB-supervised institution talks to correspondents, custodians and institutional counterparties on different terms. The ceiling of the EMI regime is dissected in the Luxembourg EMI guide, and life without any licence at all in the guide to BaaS and sponsor banks.

The 2025 counterpoint: payment rails are no longer a bank monopoly

The classic argument — "our own access to the payment system" — has weakened over the past year. Following the Instant Payments Regulation, the Eurosystem opened TARGET to non-bank providers: the policy was announced on 19 July 2024; the Settlement Finality Directive has admitted payment institutions and EMIs since 9 April 2025, and after ECB Decision 2025/1148 deferred the start from 16 June, they have been able to request access to T2 and TIPS directly, without a sponsor bank, since 6 October 2025. The limits are real: the central bank account balance is capped at what settlement requires, and the Eurosystem deliberately offers no safeguarding accounts for client funds. The conclusion is simple — if all a project needs is instant payment rails, a banking licence is overkill; you grow up for the deposits and the credit. How PSD3 and the PSR will redraw the EMI regime itself is a separate page.

The route: enter via the national regulator, the ECB decides

Since the SSM launched in 2014, granting and withdrawing banking licences in the euro area has been the ECB's exclusive competence, less significant banks included. The procedure is dual, and the ECB Guide to assessments of licence applications says so plainly: the entry point is always the national regulator. BaFin, the ACPR or the Bank of Lithuania runs the file and drafts the decision; the final word belongs to the ECB's Governing Council. Under the CRD the assessment of a complete application takes six months and must not exceed twelve including suspensions. The clock, however, only starts on a complete file — before that comes the pre-application dialogue, which for serious projects eats six months or more. The working range for the full cycle is 12–24 months; Revolut's French case came in at roughly fifteen from the public announcement.

Four blocks get tested: a viable business plan, governance with three lines of defence, fit and proper checks on the board and qualifying shareholders, and the origin of capital — the latter dovetails with the new EU AML package, while operational and IT resilience dovetails with DORA. For neobanks and platforms there is a dedicated fintech guide, published in March 2018: IT outsourcing, cloud, credit scoring models and an orderly exit plan.

Capital: €5 million in the directive, €20–50 million in real life

Formally the CRD sets minimum initial capital at €5 million — the figure comes from the same ECB guide. The same guide contains the requirement that makes the formal threshold theoretical: own funds must be sufficient to absorb the losses of the first three years of activity under a conservative business plan scenario. A retail or SMB neobank with marketing, an IT platform and a compliance staff burns tens of millions before breaking even, so the €20–50 million-plus benchmark at the moment of authorisation is a consensus of law firms and visible cases, not a norm from the directive; ambitious retail projects capitalise at multiples of that. Nor does the pressure end at the grant: the SREP cycle, supervisory fees and capital adequacy requirements accompany a bank permanently.

Choosing the jurisdiction: ten entry points

Lithuania built an intermediate rung into the ladder — the specialised bank: a full bank in its right to take deposits and lend, but without investment services, with minimum capital of €1 million; the licence is likewise granted by the ECB. Revolut climbed the whole ladder: a specialised bank licence in December 2018, a full licence in 2021. After the sector clean-up the entry bar has risen markedly — see the guide to Lithuanian licences.

France — the ACPR: Qonto's application and the fresh Revolut Bank S.A. licence show Paris deliberately collecting fintech banks. Germany — BaFin: N26 back in 2016, Trade Republic in December 2023, Scalable Capital on 10 September 2025 — a well-oiled conveyor upgrading brokers to full banks. Luxembourg — the premium entry point via the CSSF with maximum substance requirements; PayPal has held its banking licence here since 2007. Ireland — formal refusals are rare, but Starling withdrew its application in July 2022 after nearly four years in process, which the market read as a soft form of "no".

Choosing the jurisdiction means choosing a supervisory style and the weight of the licence: the Lithuanian one is cheaper and faster, the German and French ones heavier but weightier in correspondent relationships. The decision-maker is the same ECB either way.

Ten entry points on one grid

The five countries above are the usual shortlist; the grid below adds the Netherlands, Malta, Spain and Italy from the euro area and Poland as the control case outside it. The directive sets the floor and the clock for all of them — €5 million of initial capital under article 12 of the CRD, and a decision within six months of a complete application and never later than twelve months after receipt under article 15 — so the columns that move are the national floor, the existence of a lighter rung, and who signs the licence.

The capital column matters only where the national floor rises above the directive, and in three countries it does. Royal Decree 84/2015 requires a Spanish bank to have initial share capital of at least €18 million, fully paid in cash; the Banca d'Italia asks €10 million of a bank organised as a joint-stock company and €5 million of a credit cooperative; Luxembourg's financial sector law sets €8.7 million of paid-up capital, as the Chambers banking guide for 2026 summarises it. Everywhere else the €5 million floor of the CRD stands, and Lithuania alone uses the article 12(4) option to authorise a category of credit institution below it, at €1 million. The ECB's three-year loss test then sits on top of whichever floor applies, which is why the national figure decides only for a lean business plan.

The clock column is identical by law and different in practice. Spain writes the CRD rule into its decree as six months from a complete file with an absolute twelve-month limit, after which silence means refusal; Italy states 180 days from receipt within the same twelve-month ceiling; the CSSF works to the same six and twelve months. What varies is the pre-application dialogue, which the statute does not count: Revolut's French licence took about fifteen months from public announcement to decision, while Starling's Irish file ran for nearly four years before it was withdrawn.

The last column separates the euro area from the rest of the Union. In every euro-area state the national authority runs the file but the ECB grants and withdraws the licence. In Poland and the other member states outside the SSM the national supervisor decides alone; the licence passports across the EEA on the same terms, but the bank is not supervised within the SSM framework. For a fintech whose counterparties read "ECB-supervised" as a credential, that is a real difference; for one whose market is domestic, it is not.

Read by profile, the grid gives four answers.

A worked comparison on one set of inputs. A B2B lending platform plans losses of €3 million a year for three years. The ECB's loss-absorption test asks for own funds covering roughly €9 million of losses, before any buffer. In Germany, France, the Netherlands, Ireland or Malta that test, not the €5 million floor, sets the capital; in Luxembourg the €8.7 million floor and the test land in the same place; in Spain the €18 million floor binds first and doubles the ticket; in Lithuania a specialised bank would start at €1 million of statutory capital but would still face the same three-year test. A retail neobank burning €15 million a year faces €45 million of projected losses, and at that scale no national floor in the table matters at all — which is why the €20–50 million range above is a statement about business plans, not about countries.

Cases, 2023–2026

The pattern is consistent: licences go to mature, mostly profitable platforms with an existing client base — the "bank from scratch for its own sake" has all but vanished from the euro area. ClearBank Europe arrived with UK clearing experience; Qonto filed with the ACPR in July 2025 after two years of profitability and by July 2026 was getting positive regulator feedback. One caveat: the loud Wise and bunq banking headlines of recent years are US stories — they have nothing to do with the ECB procedure.

Outside the euro area the same money buys a narrower licence. A UK, Swiss or US bank serves only its own market, a Puerto Rico IFE or a Dominican offshore bank serves only non-residents and carries no deposit insurance, and only the EU licence passports; the twelve banking licences are set side by side on capital, clock, depositor protection and reach in the bank licence grid of the fintech licence map.

The alternative: buy a licensed bank

Buying control of a licensed bank is not a way around the exam — it is the same exam under a different name: the qualifying holding procedure. The thresholds are 10, 20, 30 and 50 per cent of capital or voting rights; the supervisor has 60 working days to assess, with the right to stop the clock by requesting documents; the decision, again, is the ECB's. Scrutiny covers the buyer's reputation and financial soundness, the origin of funds, the business plan for the bank and fit and proper checks on the incoming team — the methodology is collected in the ECB's 2023 guide on qualifying holding procedures. A fresh benchmark of scale: UniCredit agreed to buy Aion Bank and Vodeno for roughly €370 million in summer 2024 and closed the deal in March 2025 after all regulatory approvals. Buying wins time but brings a legacy balance sheet and old liabilities, and a dormant shell licence is treated in substance as a new authorisation — recapitalisation against the new business plan is unavoidable.

When an EMI grows into a bank

Maturity shows on the balance sheet and in the client base: balances are consistently large and want to become deposits, clients borrow from competitors, partner banks take the margin and constrain the product or the geography, and counterparties need an ECB-supervised status specifically.

The signs that it is early run the other way: payment rails are enough for the product — TIPS is now directly accessible; investors are not ready to lock up €20–50 million for two to three years; there is no team for a CRO, a CFO and internal audit; the economics cannot carry a permanent supervisory burden.

Between the two states sit interim moves: a Lithuanian specialised bank at €1 million as a training rung, or renting someone else's licence until the economics mature.