A licence from a financial regulator doesn't guarantee you a bank account, and for payment firms that is the real trouble. If you run a licensed fintech and no bank will take you on, you have a business problem, not a licensing one. This briefing explains why e-money, payment and small-bank licences hit this wall, and how to design your application so a bank will say yes.

Which licences are we talking about, and where do banks stand in 2026?

Banks have become picky about which payment firms they'll take on. If the (the big banks that move your money between countries) don't like the country that licensed you, the licence is of little use, because you can't operate.

Many places license non-bank payment firms. Examples include the EU's /PI framework (e-money institutions and payment institutions), the UK's FCA regime, the UAE (CBUAE and VARA), Singapore (MAS PS Act) and various offshore centres.

After the Wirecard collapse, the top-tier correspondent banks (BNY, Citi, JPM, Deutsche, HSBC) cut back the number of EMIs they'll bank. Mid-tier correspondents followed.

Why do banks say no?

Banks' refusals tend to cluster around five themes. Check yourself against each one.

  • Where you're licensed. Some jurisdictions have too many licensees, too little supervision, or a record of failures. Lithuania, Malta and Cyprus went through this in different periods. Even a good operator in the wrong jurisdiction pays a premium.
  • What your business does. Cross-border, multi-currency, crypto-adjacent, gaming-adjacent and high-risk-merchant portfolios all reduce banks' appetite.
  • Who owns and runs it. Ultimate owners in high-risk jurisdictions, PEP exposure (politically exposed persons, meaning people in prominent public roles) and boards without banking experience all show up when a bank looks you over.
  • How good your compliance is. Off-the-shelf transaction monitoring, thin sanctions screening and no local MLRO (the money laundering reporting officer, the person responsible for spotting and reporting suspicious activity) all count against you. Banks look for real capability, not a tick-box.
  • How much capital you hold. A licence issued at minimum capital may satisfy the regulator but fail the bank's tier-one counterparty policy.
Why a licence alone doesn't open the door
Regulator
licensing country
grants the licence, which may pass at minimum capital
Your firm
applies for an account, with jurisdiction, business model, owners, compliance stack and capital all under review
Correspondent bank

How do you design for bankability?

Build your licence application with the future bank onboarding pack in mind. Here's what that means in practice.

  • Choose your licensing country by where banks want to see you, not by price. Ireland, Luxembourg, Germany and (for UK-scope) the FCA are the strongest current picks for EMI/PI.
  • Put in more capital than the minimum. Tier-one correspondents look for real capital, not just the €350k EMI floor.
  • Hire a board and MLRO with banking-grade CVs. Correspondents cite this factor more than any other.
  • Choose a tier-one transaction monitoring vendor. Be ready to show how you've validated and tuned its models.
  • Split your business plan into parts. Define the corridors (country-to-country payment routes), currencies and merchant categories, and show the anti-money-laundering controls that fit each.

What's the realistic route to a working bank setup?

Most EMIs and PIs can't open a tier-one correspondent account on day one. The practical route has three stages.

The three-stage route to bank access
  1. 1
    Launch
    Sponsor bank or BaaS provider
    a licensed sponsor lets you go live while your direct bank relationships mature
  2. 2
    For volume
    Second-tier correspondent
    typically a specialist Baltic, German, Dutch or UK bank willing to serve licensed EMIs with real controls
  3. 3
    For scale
    Tier-one correspondent
    usually 18-24 months into operation, with a clean audit history and demonstrable AML performance

Trying to skip steps is the most common cause of expensive licence pauses. Think of it like a credit history: nobody gets the premium card before the starter one.

How we approach this at Sovereign Signal

We work with fintech founders at the licence design stage, before the application is filed, so that bankability is part of the plan.

We introduce sponsor banks and correspondent candidates we've worked with directly. We help prepare the file the banks will actually read. We also coordinate with the regulatory counsel running the licence process.

We don't take referral fees from banks, because that would compromise the recommendation.

What does this look like in a real case?

FAQs

Which jurisdictions are correspondent-friendly for EMIs in 2026?

Ireland, Germany, the Netherlands, Luxembourg and, for UK sterling, the FCA regime. Lithuania and Malta remain licensable but bring friction with correspondent banks.

Can I use a BaaS provider indefinitely?

Yes, but it costs you. Margins are thinner and you carry the provider's own risk. Most scaling EMIs move to direct correspondents within two years.

How much capital should I actually put in?

For a serious EMI with correspondent ambitions, €1–3m is realistic. That's well above the €350k regulatory floor.

Do I need a physical office in the licensing jurisdiction?

Yes. Every major regulator now expects real presence, and correspondents check.