Regulated activity

Payment initiation services

Initiating an online payment order straight from a customer's bank account, the open banking model, needs a PI, EMI or banking licence under PSD2 Annex I (7). A dedicated payment initiation service provider (PISP) needs EUR 50,000 of initial capital plus professional indemnity insurance. The licence then passports throughout the EEA.

Last verified 2026-09-24Markdown · Data (CC BY 4.0)
Payment initiation services: regulated activityPSD2

Definition

Initiating a payment order at the user's request from an account held with another provider, as in open banking.

Which licence you need

Licence families that typically permit this activity:

Where it can be licensed

Jurisdictions where payment initiation services can be licensedCzech RepublicEstoniaGeorgiaGermanyIrelandLatviaLithuaniaLuxembourgNetherlandsPolandSlovakiaSpainUnited Arab EmiratesUnited KingdomMaltaSingapore
Licences in the Atlas that permit this activity
EU/EEA passportDomestic
Czech Republic: Small-scale Electronic Money Issuer authorisation✓
Czech Republic: Electronic Money Institution licence✓
Czech Republic: Small-scale Payment Service Provider authorisation✓
Czech Republic: Payment Institution licence✓
Estonia: Electronic money institution operating with an exception✓
Estonia: Operating licence as an electronic money institution✓
Estonia: Payment institution operating with an exception✓
Estonia: Operating licence as a payment institution✓
Georgia: Payment institution licence✓
Germany: Electronic money institution licence✓
Germany: Payment institution licence✓
Ireland: Electronic Money Institution Authorisation✓
Ireland: Payment Institution Authorisation✓
Latvia: Registered electronic money institution✓
Latvia: Authorised electronic money institution licence✓
Latvia: Registered payment institution✓
Latvia: Authorised payment institution licence✓
Lithuania: Electronic money institution licence for restricted activity✓
Lithuania: Electronic money institution licence for non-limited activity✓
Lithuania: Payment institution licence for restricted activity✓
Lithuania: Payment institution licence✓
Luxembourg: Electronic money institution authorisation✓
Luxembourg: Payment institution authorisation✓
Malta: Electronic money institution licence✓
Malta: Payment institution licence✓
Netherlands: Electronic money institution licence✓
Netherlands: Payment institution licence✓
Poland: Electronic Money Institution licence✓
Poland: National Payment Institution licence✓
Poland: Small Payment Institution registration✓
Singapore: Major Payment Institution Licence✓
Singapore: Standard Payment Institution Licence✓
Slovakia: Electronic money institution licence✓
Slovakia: Payment institution licence✓
Spain: Electronic money institution authorization✓
Spain: Payment institution authorization✓
United Arab Emirates: Retail Payment Services Licence (Categories I to IV)✓
United Kingdom: Small Electronic Money Institution (SEMI) Registration✓
United Kingdom: Authorised Electronic Money Institution (AEMI)✓
United Kingdom: Small Payment Institution (SPI) Registration✓
United Kingdom: Authorised Payment Institution (API)✓

Frequently asked questions

Does a payment initiation service provider hold customer funds?

No. A PISP initiates the transfer directly between the payer's bank account and the payee's account, and never holds, settles or safeguards the money along the way. That is why its capital requirement sits below a full payment institution's.

How do banks provide access to payment initiation services?

PSD2's open banking rules make a bank provide a dedicated API, or a modified customer interface, for this purpose. An authorised PISP uses it to reach the account's payment functionality securely, once the account holder has given explicit consent.

Last verified 2026-09-24Author Danil Marmysh, Founder & CEO, ProtegraReviewed by Anastasia Sidorenkova, Head of Licensing, ProtegraReport an errorReference information, not legal advice.

Sources

  1. PSD2 Annex I (7) · retrieved 2026-09-24

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