# An EU Banking Licence via the ECB: the Route, the Capital, the Timelines > €5m on paper versus €20–50m in practice, 12–24 months, the choice of entry country and the buy-a-bank alternative: the credit institution route under the SSM. Author: Gordey Bolotko — Partner, Corporate & Commercial (https://wiki.private.law/en/authors/bolotko) Last modified: 2026-08-14T13:12:00.000Z Canonical: https://wiki.private.law/en/eu-banking-license-ecb Topics: banking Jurisdictions: eu Product tags: banking, bank, company Semantic tags: banking, bank, company --- 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". This page maps the whole credit institution route — who actually grants the licence, how much capital the directive demands versus what practice demands, which country to enter through, and at what point an EMI project should grow up into a bank. ## 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](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32014L0049): €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 our [Luxembourg piece](https://wiki.private.law/en/emi-license-luxembourg), and life without any licence at all in the guide to [BaaS and sponsor banks](https://wiki.private.law/en/baas-sponsor-bank). ## 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](https://www.ecb.europa.eu/press/intro/news/html/ecb.mipnews20240719.en.html): the policy was announced on 19 July 2024, and from April 2025 payment institutions and EMIs can settle in T2 and TIPS directly, without a sponsor bank. 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](https://wiki.private.law/en/psd3-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](https://www.bankingsupervision.europa.eu/ecb/pub/pdf/ssm.201901_guide_assessment_credit_inst_licensing_appl.en.pdf) 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](https://wiki.private.law/en/eu-aml-package), while operational and IT resilience dovetails with [DORA](https://wiki.private.law/en/dora-eu). For neobanks and platforms there is a [dedicated fintech guide](https://www.bankingsupervision.europa.eu/ecb/pub/pdf/ssm.201803_guide_assessment_fintech_credit_inst_licensing.en.pdf), published [in March 2018](https://www.bankingsupervision.europa.eu/press/pr/date/2018/html/ssm.pr180323.en.html): 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. ## Which door: Lithuania, France, Germany, Luxembourg, Ireland **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](https://www.lb.lt/en/news/revolut-granted-specialised-bank-and-electronic-money-institution-licences), a [full licence in 2021](https://www.lb.lt/en/news/banking-licence-granted-to-revolut-bank-uab). After the sector clean-up the entry bar has risen markedly — see our piece on [Lithuanian licences](https://wiki.private.law/en/emi-license-lithuania). **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 door 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 door 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. ## Cases, 2023–2026 | **Project** | **Door** | **Outcome** | **When** | **Comment** | | --- | --- | --- | --- | --- | | Trade Republic | Germany, BaFin | full ECB licence | December 2023 | upgrade from a limited securities-trading bank licence | | ClearBank Europe | Netherlands, DNB | credit institution | 2024 | a UK clearing group entering the EU | | Scalable Capital | Germany, BaFin | full ECB licence | September 2025 | a BlackRock-backed broker grown into a bank | | Revolut Bank S.A. | France, ACPR | the group's second EU licence | August 2026 | roughly 15 months from announcement to decision | | Qonto | France, ACPR | application pending | July 2025 → | positive regulator feedback, decision ahead | 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. ## 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 should grow up: the checklist Signs it is time: client balances are consistently large and want to become deposits; clients borrow from your competitors; partner banks take the margin and constrain the product or the geography; counterparties need your ECB-supervised status specifically. Signs it is early: 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. Interim moves: a Lithuanian specialised bank at €1 million as a training rung, or [renting someone else's licence](https://wiki.private.law/en/license-for-rent) until the economics mature. > 🍓 An EU banking licence buys three things: deposits under the €100,000 DGS guarantee, a credit margin on your own balance sheet, and the status of an ECB-supervised institution. The price: €5 million of formal capital versus €20–50 million-plus in practice, 12–24 months of the dual "national regulator → ECB" procedure, and a permanent supervisory burden afterwards. Entering via Lithuania is cheaper \(a specialised bank from €1 million\); buying a ready-made bank is faster, but the qualifying holding exam is the same in substance. Since April 2025 non-bank PSPs settle in TIPS directly, so you grow into a bank for the deposits and the credit — not for the rails. ## Q/A ### **Is it time for my EMI to become a bank?** Count three numbers: how much margin goes to partner banks, how much deposit funding you would gather under a DGS guarantee, and how much of your clients' credit demand you hand to competitors. If the total comfortably repays €20–50 million of capital and two to three years of procedure, start the pre-application dialogue. If not, staying an EMI is rational: direct TIPS access since April 2025 covers the payments side without a banking licence. ### **What does an EU banking licence really cost?** The directive requires €5 million of initial capital, but the ECB assesses own funds against three years of business-plan losses, so real projects capitalise at €20–50 million and above — a consensus of practice, not a legal norm. Add the team, advisers and IT through 12–24 months of procedure, and permanent supervisory costs after the grant. ### **Can we just buy a bank that already has a licence?** Yes, but acquiring 10% or more of capital or votes triggers the qualifying holding procedure: 60 working days of assessment, scrutiny of reputation, origin of funds and the plan for the bank, with the ECB deciding. For scale: UniCredit closed its purchase of Aion Bank and Vodeno in March 2025 after all approvals. You save time; the exam remains. ### **Where is the easiest place to get an EU banking licence?** "Easier" does not mean "easy": the ECB decides everywhere. Lithuania's specialised bank cuts the capital threshold to €1 million — that is how Revolut started in 2018. Germany has a working broker-upgrade conveyor \(Trade Republic, Scalable Capital\), France is collecting headquarters \(Revolut, Qonto's application\), and Ireland's Starling case — four years in process and a withdrawn application — is a reminder that the door may simply never open. --- ## FAQ ### Is it time for my EMI to become a bank? Count three numbers: how much margin goes to partner banks, how much deposit funding you would gather under a DGS guarantee, and how much of your clients' credit demand you hand to competitors. If the total comfortably repays €20–50 million of capital and two to three years of procedure, start the pre-application dialogue. If not, staying an EMI is rational: direct TIPS access since April 2025 covers the payments side without a banking licence. ### What does an EU banking licence really cost? The directive requires €5 million of initial capital, but the ECB assesses own funds against three years of business-plan losses, so real projects capitalise at €20–50 million and above — a consensus of practice, not a legal norm. Add the team, advisers and IT through 12–24 months of procedure, and permanent supervisory costs after the grant. ### Can we just buy a bank that already has a licence? Yes, but acquiring 10% or more of capital or votes triggers the qualifying holding procedure: 60 working days of assessment, scrutiny of reputation, origin of funds and the plan for the bank, with the ECB deciding. For scale: UniCredit closed its purchase of Aion Bank and Vodeno in March 2025 after all approvals. You save time; the exam remains. ### Where is the easiest place to get an EU banking licence? "Easier" does not mean "easy": the ECB decides everywhere. Lithuania's specialised bank cuts the capital threshold to €1 million — that is how Revolut started in 2018. Germany has a working broker-upgrade conveyor (Trade Republic, Scalable Capital), France is collecting headquarters (Revolut, Qonto's application), and Ireland's Starling case — four years in process and a withdrawn application — is a reminder that the door may simply never open. --- ## Factual claims - On 10 August 2026 Revolut received its second full EU banking licence: the ACPR and the ECB approved the French Revolut Bank S.A. - 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. - Formally the CRD sets minimum initial capital at €5 million — the figure comes from the same ECB guide.