PSP registers compared: eight EU national registers
PSP registers across the EU rest on the same two articles of PSD2, and they still answer a counterparty check in eight different ways. Every member state must keep a public register of its payment institutions and their agents, and the EBA must republish all of them in one central register. What the national registers add on top differs: whether they show inbound passports, where agents sit, whether e-money distributors are listed, and whether you can download the data. This hub compares the registers of France, Spain, Italy, Germany, the Netherlands, Luxembourg, Ireland and Belgium, and links to a full guide on each.
1. The EU baseline: Article 14 PSD2 and EMD2
Article 14 of Directive (EU) 2015/2366 (PSD2) requires each member state to set up a public register of authorised payment institutions and their agents, of exempted persons under Articles 32 and 33 and their agents, and of the institutions in Article 2(5) that national law allows to provide payment services. A payment institution’s branches are entered in the home register when they operate in another member state.
The register must identify the payment services for which each firm is authorised or registered, list authorised institutions separately from exempted persons, be online and free to consult, and be updated without delay. Withdrawals of authorisation or exemption must be entered, and their reasons notified to the EBA.
E-money institutions come in through Directive 2009/110/EC (EMD2). As amended by Article 111 PSD2, Article 3(1) EMD2 applies Article 5 and Articles 11 to 17 PSD2, Articles 14 and 15 included, to e-money institutions with the necessary changes. EMD2 also lets an e-money institution distribute and redeem e-money through persons acting on its behalf, but not issue it through agents.
Two things are missing from the baseline. Article 14 says nothing about listing EEA firms that passport into a member state, and nothing about e-money distributors. Both gaps were filled nationally, and differently.
2. The EBA central register
Article 15 PSD2 requires the EBA to run an electronic central register built from the information national authorities enter in their Article 14 registers. The authorities notify it without delay and stay responsible for its accuracy; the EBA is responsible for presenting it accurately. Two Commission acts of 29 November 2018 govern the mechanics:
- Implementing Regulation (EU) 2019/410 sets what each authority sends, in eight tables: payment institutions, exempted persons, account information service providers, e-money institutions, exempted e-money issuers, agents, credit institutions entitled to provide payment services, and providers relying on the limited-network and electronic-communications exclusions. For an institution, that includes the national identification number (which may be an LEI), authorised services, status, dates of authorisation and withdrawal, and host member states by mode and service.
- Delegated Regulation (EU) 2019/411 sets how. Authorities transmit manually or by daily batch file. Grants and withdrawals of authorisation or registration must reach the EBA register the same day. Agents are displayed both as their own record and inside their principal’s record. The full content is downloadable as a standardised file refreshed at least twice a day.
3. Eight national registers side by side
| Country | Register | Authority | Legal basis | Agents shown | Inbound passports shown | Export / API | Guide |
|---|---|---|---|---|---|---|---|
| France | REGAFI | ACPR | Code monétaire et financier | Yes, agents of French principals, at home and abroad | Yes, LPS and passported branches, with the home supervisor | Open dataset and APIs since the July 2026 relaunch | REGAFI |
| Spain | Registro de entidades, with a separate Registro de agentes | Banco de España | Art. 13 RDL 19/2018; Art. 5 RD 736/2019; Art. 5 RD 778/2012 | Yes, in the separate agents application | EEA branches; for free provision and agents the BdE points to the EBA register | Downloadable files, including a distributors list; alert subscriptions | Registro de entidades |
| Italy | Albo IP and Albo IMEL, plus an AISP section | Banca d’Italia | Arts. 114-septies and 114-quater TUB | Yes, in Italy (with OAM number) and abroad | In a separate view of foreign intermediaries | PDF and Excel export | Albo |
| Germany | Zahlungsinstituts- and E-Geld-Instituts-Register | BaFin | §§ 43 and 44 ZAG | Yes, with start and end dates, kept up to five years | No | Online search with a data date | ZAG register |
| Netherlands | Openbaar Register | DNB | Art. 1:107 Wft | Yes, Dutch principals’ agents at home and abroad | Yes, branches and cross-border services, not agents | XML and CSV downloads and an API, updated each business day | DNB register |
| Luxembourg | Search Entities | CSSF | Art. 36 Law of 10 November 2009 | Yes, in an agents and branches table | EEA branches only | CSV export; changes since a chosen date | CSSF register |
| Ireland | Central Bank register | Central Bank of Ireland | National transposition of Art. 14 PSD2 and EMD2 | See the dedicated guide | CBI register | ||
| Belgium | NBB register | National Bank of Belgium | National transposition of Art. 14 PSD2 and EMD2 | See the dedicated guide | NBB register | ||
Read the table as a map of where to look, not as a ranking. Every register on it shows a firm’s authorised services; only some show where else it operates.
4. Agents: one go-live rule, local clocks
Article 19 PSD2 makes the register the agent’s starting gate. The principal sends its home authority the agent’s name and address, its AML/CFT controls, its managers (with fitness evidence unless the agent is itself a PSP), the mandated services and any identification code. Within two months the authority says whether the agent has been entered, and the agent may start only once it has. If the authority is not satisfied the information is correct, it refuses the listing.
For an agent in another member state, Article 28 adds a passport step. The home authority forwards the file to the host within one month, the host may raise concerns, including on money laundering, and the home authority decides within three months. Again, activity starts on entry in the home register.
- Spain, Germany, the Netherlands, Luxembourg: the two-month window, written into national law in near-identical terms.
- Italy: Banca d’Italia’s provisions set 60 days for a domestic agent and 90 for an agent abroad, from a complete notification. The agent also needs OAM enrolment.
- France: the ACPR states that an agent may carry out no operation until it is entered in REGAFI.
In every market the principal files and the principal corrects. An agent cannot fix its own entry, and a stale termination is the principal’s breach.
5. E-money distributors: three answers
Because Article 14 does not mention distributors, member states split three ways:
- Registered and published. Spain requires distributors to be registered with the BdE before operating and publishes a list. A missing distributor is a finding.
- Notified, outside the main register. In Italy, distribution runs through soggetti convenzionati, notified but not agents, and communicated to the OAM registry. Germany treats distributors as E-Geld-Agenten under § 25 ZAG, without the fitness evidence, and the register covers e-money institutions’ agents.
- Not on the public register. France does not register distributors mandated domestically by a French issuer. Luxembourg’s register has columns for agents and branches only.
A cross-border distributor is a different matter everywhere: Article 3(4) EMD2 sends it through the PSD2 passport procedure. The practical rule is that absence from a register means nothing until you know which of the three regimes applies.
6. Inbound passports: whose register is authoritative
An EEA firm serving a host market does so on its home licence. Its authorisation, its branches abroad and its agents abroad all sit in the home register under Article 14. What the host shows is a courtesy, and it varies:
- France and the Netherlands list inbound cross-border services and branches, naming the home supervisor.
- Italy lists them in a separate foreign-intermediaries view, not in the albi.
- Spain and Luxembourg list inbound branches; for free provision, the BdE sends you to the EBA register.
- Germany lists none of them in the ZAG register.
Agents of EEA firms are the sharpest trap. DNB and BaFin say they appear in the home register, not theirs, and the ACPR points users to the home register. An EEA firm’s agent missing from the host register is normal; one missing from the home register and the EBA register is not.
7. Identifiers to store
Each register has its own key, and names change while keys do not. Store the register code with the country:
| Country | Register key | Also match on |
|---|---|---|
| France | Identifiant REGAFI; CIB for French institutions | SIREN, LEI |
| Spain | Código BE | NIF, LEI |
| Italy | Codice meccanografico | Codice fiscale, LEI |
| Germany | Register ID; BaFin-ID in the Unternehmensdatenbank | BaK number |
| Netherlands | DNB relatienummer | KvK number, LEI |
| Luxembourg | CSSF code, Z for payment and W for e-money institutions | Name history, RCS number |
In the EBA register, the national identification number field may carry a national number or an LEI, depending on the authority. Do not assume one key works across both.
8. When the national and EBA registers disagree
They will, occasionally. Delegated Regulation 2019/411 forces same-day transmission only for grants and withdrawals; other changes travel in a daily batch, and each national feed is only as current as the national register behind it. The hierarchy is simple: the home national register is the record, and the EBA register is a republication of it. A discrepancy in your own entry is fixed through the national filing route, never by writing to the EBA.
A revision of the framework, a third payment services directive and a Payment Services Regulation, was proposed by the Commission in June 2023. At the time of writing we could not find a final text published in the Official Journal, so Articles 14 and 15 PSD2 and the 2019 acts remain the operative rules.
9. Worked examples
Counterparty check on an EEA payment institution.
Facts: a Spanish e-money institution plans to use a payment institution authorised in another member state for payouts to Italian and Dutch customers. The partner says it is “licensed in Italy and the Netherlands”.
What the rule says: the firm works on its home authorisation. Article 14 puts its services and branches in the home register, and the EBA register shows the host member states it has notified, by service.
What the practitioner does: verifies the authorisation and services in the home register, then checks the EBA record for Italy and the Netherlands under the right mode. Looks up the DNB inbound entry and the Italian foreign-intermediaries view as corroboration, and saves all four with dates.
Outcome: the file shows a passported firm, the services notified per country and the supervisor that would act.
Agent onboarding check.
Facts: a German payment institution wants to launch cash services through retail outlets in the Netherlands. The commercial team asks Dutch compliance to “check DNB”.
What the rule says: under Article 28 PSD2 and § 38 ZAG, the agents are notified to BaFin, which forwards the file to DNB within a month and decides within three. The agents may start on entry in the home register.
What the practitioner does: tracks the agents in BaFin’s register, not DNB’s, and confirms they appear with the Netherlands and the right services in the EBA register. Agent access goes live only after entry.
Outcome: no outlet acts before entry, and nobody escalates a “missing” DNB record.
Discrepancy between national and EBA register.
Facts: at periodic review, the EBA register still shows a Luxembourg e-money institution’s agent in France. The CSSF’s Search Entities shows it as withdrawn.
What the rule says: the CSSF is responsible for the data it sends the EBA, and the EBA states its register has no legal effect.
What the practitioner does: relies on the CSSF entry, records both screenshots, and asks the principal for the termination date before treating any payment through that agent as attributable to it.
Outcome: the decision rests on the national record, and the lag is documented rather than acted on.
10. FAQ
Which register is authoritative for an EEA payment institution?
Its home member state’s register. Host registers may list it as a courtesy, and the EBA register republishes the home data without legal effect.
Does PSD2 require host registers to list inbound passports?
No. Article 14 covers authorised institutions, exempted persons, their agents and branches abroad. Inbound listings are national additions, and they vary.
When may a new agent start?
On entry in the home register. Article 19 PSD2 gives the authority two months to say whether the agent is entered; Italy sets 60 days in its supervisory provisions.
Are e-money distributors on the register?
It depends on the country. Spain registers and publishes them; France and Luxembourg do not list domestic distributors; Italy and Germany route them through separate notifications.
Can I download the EBA register?
Yes. Delegated Regulation 2019/411 requires a downloadable standardised file updated at least twice a day.
How do I fix a wrong entry about my own firm?
Through the filing that created it, with your home authority. The EBA register follows the national data.
11. What to do, today
- COO: pull your own entry in your home register and the EBA register, and reconcile services, host countries and agents against your authorisation file.
- Head of partnerships: make a dated home-register and EBA check a contract precondition for every PSP counterparty; treat host listings as corroboration only.
- Agent network owner: gate every go-live on entry in the home register, and plan launches around two months at home and three months abroad.
- E-money product owner: map each distribution market to its regime: registered list, separate notification, or none.
- Compliance data lead: store each counterparty’s register key with country and type, plus the LEI, and schedule an automated pull where the register offers one.
Related: REGAFI, the French register · The Banco de España Registro de entidades · BaFin’s ZAG register
