A bank licence is a long, capital-intensive project in which the regulator assesses shareholders, business model, capital plan and control environment as a whole. Our team prepares the application and the operating framework behind it — business plan and financial model, governance, risk and AML frameworks, IT and regulatory reporting readiness — and, together with local counsel, supports the dialogue with the supervisor.
A bank — in EU terms a credit institution — is a company authorised to take deposits or other repayable funds from the public and to grant credit for its own account. Because it works with depositors' money, banking is the most closely supervised part of the financial sector: the regulator examines who owns and controls the bank, how much capital is committed, how risks are measured and limited, and whether management can run the bank safely from the first day.
Several jurisdictions offer narrower entry routes: a specialised bank in Lithuania, the Swiss FinTech licence for deposit-taking without lending, a mobilisation phase with restricted deposit-taking in the United Kingdom, and separate permissions for Accepting Deposits and Providing Credit in the Astana International Financial Centre (AIFC). The choice between them determines capital, timeline and the business the bank may conduct.
A banking licence differs from a payment institution or electronic money institution authorisation: those firms hold client funds but may not use them for lending. If the model does not require deposit-taking or own-account lending, a lighter regime may be sufficient — this is the first question we answer.
The table shows regimes for which the key parameters have been checked against official sources. Capital figures are statutory minimums; the amount a regulator expects to see in the capital plan is usually higher.
| Jurisdiction | Regulator | Regime | Key points |
|---|---|---|---|
| EU — euro area (e.g. Lithuania, Estonia, Cyprus, Malta) | European Central Bank (ECB); national competent authority as entry point | Licence (credit institution) | Minimum initial capital €5 million under the Capital Requirements Directive (CRD). The application is filed with the national authority, which assesses it together with the ECB; the ECB grants or refuses the licence. |
| Lithuania | Bank of Lithuania; ECB | Licence (bank or specialised bank) | Specialised bank: initial capital €1 million, activities limited to an exhaustive statutory list (no investment services). Decision within 6 months of a complete application, at most 12 months. |
| Czech Republic, Poland | Czech National Bank; Polish Financial Supervision Authority (KNF) | Licence (credit institution) | Outside the euro area, the national authority licenses banks itself. The EU minimum initial capital applies. |
| United Kingdom | Prudential Regulation Authority (PRA) and Financial Conduct Authority (FCA) | Authorisation (dual regulation) | The PRA is responsible for prudential supervision and the FCA for conduct. A new bank may start in mobilisation: authorisation with restrictions for up to 12 months, deposits capped at £50,000, lower capital during the phase. |
| Switzerland — bank | FINMA | Licence | Fully paid-in minimum capital of at least CHF 10 million; capital, liquidity and management requirements, with the bank managed from Switzerland. |
| Switzerland — FinTech licence | FINMA | Licence (Art. 1b Banking Act) | Public deposits up to CHF 100 million or crypto-assets in collective custody; deposits not invested and not interest-bearing; Swiss AG, KmAG or GmbH; no deposit insurance. Capital depends on deposits taken, with a fixed floor — confirmed at assessment. |
| AIFC (Kazakhstan) | Astana Financial Services Authority (AFSA) | Authorisation (licence) | Accepting Deposits: base capital USD 10 million. Providing Credit: USD 2 million. Process: pre-application meeting, draft regulatory business plan, application, in-principle approval with conditions, licence. |
| Kazakhstan — national regime | Agency for Regulation and Development of the Financial Market (ARDFM) | Licence | A new Law on banks and banking activity entered into force in 2026 and revised the licence structure. Licence types and minimum capital are confirmed against the current official texts during the assessment. |
| Kyrgyzstan | National Bank of the Kyrgyz Republic (NBKR) | Licence | Minimum charter capital for new banks, including branches of foreign banks: KGS 3 billion (NBKR resolution of 29 December 2025). Existing banks raise capital in stages from KGS 1 billion on 1 July 2026 to KGS 3 billion by 1 July 2030; systemically important banks need KGS 8 billion from 1 July 2027. |
| Georgia | National Bank of Georgia (NBG) | Licence (commercial bank; microbank) | Commercial bank: regulatory capital of GEL 50 million (NBG Order No. 61/04 of 3 May 2017); the NBG indicates a review period of up to 6 months, and in practice timing depends on the quality of the application. Microbank (since 2023): regulatory capital of GEL 10 million. Licensing fees are paid separately from capital. |
Regulatory capital is separate from state and application fees, operating costs and our fees. Our fees are agreed after the project assessment.
We test the model against bank and non-bank regimes, compare jurisdictions and estimate capital and running costs. Result: a reasoned choice of regime and a project plan.
Meetings with the regulator to present the business model and agree the scope of the application. Result: a clear understanding of the regulator's expectations before drafting begins.
Business plan, financial model, capital plan, governance, risk, AML and IT documentation, shareholder and management files. Result: a complete and consistent application.
Regulator questions, management interviews, document revisions. Result: timely answers and an updated package.
Capital paid in, key staff hired, systems tested; in the UK, the mobilisation phase. Result: readiness for full operation.
Licence granted or restrictions lifted, operations launched with reporting in place. Result: a bank operating within its licence.
In the euro area, as published by the Bank of Lithuania, the decision on a bank licence is taken within 6 months of a complete application and in any case within 12 months; in the UK a new bank may spend up to 12 months in mobilisation. In practice a bank project takes considerably longer than the formal review: preparation, the completeness check, regulator questions and capital raising all add time, and no regulator commits to a decision date.
Authorisation or registration of a payment service provider in the EU, UK, UAE, Singapore, Kazakhstan or the AIFC — from the choice of regime to launch.
Learn moreLicensing of electronic money institutions and stored value facilities in the EU, UK, UAE, Hong Kong, Singapore and the AIFC, and e-wallet models for Kazakhstan.
Learn moreAuthorisation for brokerage, order execution, dealing on own account and portfolio services in securities and other financial instruments.
Learn moreRisk assessment, policies, KYC/KYB, sanctions and transaction monitoring, travel rule and inspection readiness for licensed and to-be-licensed financial and crypto businesses.
Learn moreDescribe your project in a few sentences. We will give you a substantive reply: which questions need answering and where to start.
Discuss your projectIf the business only holds client funds to execute payments or issue e-money, a payment or e-money institution is usually the appropriate regime. A bank licence is needed when deposits are taken and used for lending on own account. We assess this first, because the difference in capital and timeline is substantial.
Statutory minimums range from €1 million for a Lithuanian specialised bank and €5 million for an EU credit institution to CHF 10 million in Switzerland and USD 10 million for an AIFC deposit-taker. The actual need is higher: the regulator expects capital to cover prudential ratios, buffers and losses in the first years. We calculate it in the capital plan; regulatory capital is separate from state fees, operating costs and our fees.
In the euro area the decision period is 6 months from a complete application, at most 12 months, but preparation and the completeness check come first. A bank project should be planned with a substantial horizon; we give a realistic schedule after assessing the model, the shareholders and the capital.
A new bank may be authorised with restrictions for up to 12 months while it completes its build-out; deposits are capped at £50,000 during this period, and capital may be lower than at full operation. The application to exit mobilisation is made at least three months before the period ends.
It is a licence under the Swiss Banking Act for public deposits up to CHF 100 million or crypto-assets in collective custody, but the deposits may not be invested or bear interest and are not covered by deposit insurance. It suits models that hold funds without lending. A reform replacing it with a new category was under consultation and had not been enacted as of October 2026.
A bank can be authorised in the AIFC by AFSA (Accepting Deposits, Providing Credit) or licensed in the national regime by ARDFM. These are separate regimes with different law, supervisors and client perimeters. The national banking law was replaced by a new law in 2026; we confirm current licence types and capital against the official texts during assessment.
No. The decision belongs to the regulator, and no adviser can promise a licence or a decision date. We prepare the project so that the application is complete, consistent and supported by a realistic capital plan, and we support the dialogue until the decision.
Send us a short description of the business model, target markets and shareholders. We will confirm whether a bank licence is needed, which regime fits and what capital, team and timeline the project requires. Our fees are agreed after this assessment.
We will review the description and give you a substantive reply: which regime may apply and where to start.
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