Insights
News and articles on EU fintech topics — licensing, AML, payments, reporting for operators.
Safeguarding compared — how EMI and payment institution safeguarding actually differs across the EU
Safeguarding under PSD2 Article 10 and EMD2 Article 7: the segregation and insurance methods, the end-of-next-business-day rule, the five-business-day e-money deadline, mixed-purpose…
Modelo 720 — Spain’s foreign asset declaration, three thresholds and the post-2022 penalty regime
Modelo 720 explained: three separate obligations under articles 42 bis, 42 ter and 54 bis RGAT, each with its own EUR 50,000…
EBA remote customer onboarding guidelines — the pre-implementation assessment and the liveness rule
EBA/GL/2022/15 on remote customer onboarding, applicable from 2 October 2023: the pre-implementation assessment, the eIDAS shortcut that removes much of it, liveness…
Outsourcing under Circular CSSF 22/806 — the three-month notification and the critical-function test
Circular CSSF 22/806 as amended by 25/883: the test for what counts as outsourcing, when a function is always critical or important,…
PSD2 agents and distributors — the Article 14 register, the two-month clock and where liability sits
Using agents under PSD2 Article 19: what must be notified, the two months the home authority has to respond, why an agent…
Small payment institutions — the Article 32 exemption, and why it cannot be passported
The PSD2 Article 32 small payment institution regime: the EUR 3 million monthly-average ceiling, the one line that disapplies the passporting articles,…
SCA exemptions under the PSD2 RTS — thresholds, fraud rates and how the TRA exemption is lost
SCA exemptions explained: the EUR 50/150 contactless and EUR 30/100 low-value counters, the EUR 500/250/100 transaction-risk-analysis thresholds and their reference fraud rates,…
The MiCA transition is over — what the close of CASP grandfathering on 1 July 2026 means
MiCA transitional period for crypto-asset service providers: Article 143(3) expired 1 July 2026, earlier in states that shortened it, the simplified procedure…
CSSF legal reporting for a Luxembourg payment or e-money institution — the Z and W tables
CSSF legal reporting for Luxembourg payment and e-money institutions: the Z and W periodic tables under Circulars 11/511 and 11/522, the 20th-of-the-month…
Circular CSSF 26/906 — internal governance and central administration for Luxembourg payment and e-money institutions
Circular CSSF 26/906 explained: applies from 30 June 2026, repeals four older circulars, sets numeric proportionality triggers, requires daily safeguarding reconciliation and…