Licensing guide · 10 min read
How to Start a Neobank
Licensing routes, partner models and the technology stack behind a digital bank launch.
"Neobank" is a product category, not a licence. Most consumer neobanks launched without a banking licence, using an EMI licence or a partner bank.
Three common routes
- Partner bank / BaaS. Accounts are held at a licensed bank or EMI. By far the fastest, easiest, and least costly solution. Product, pricing and risk appetite depend on the banking partner.
- Own EMI or payment licence. You hold customer funds as safeguarded e-money, issue cards via a card programme manager and cannot lend deposits. EU initial capital for an EMI is EUR 350,000.
- Own banking licence. Required if you want to take deposits and lend them. EU initial capital is at least EUR 5 million and supervisory expectations are extensive. The UK offers a mobilisation route.
What actually takes time
Governance, risk frameworks, capital planning, AML controls, outsourcing oversight and IT resilience documentation take far longer than building an app.
Technology you will need
Customer onboarding (KYC), account and balance management, a transaction ledger, payment-scheme connectivity (via a bank or EMI), card programme integration, AML transaction monitoring, customer support tooling and regulatory reporting. Read What Software Does a Neobank Need? for detail.
Official sources
General information, not legal advice. Confirm current requirements with the competent authority.