Many payment projects start from a product question — "we want to hold the customer’s money until delivery" — and end up, without noticing, in an activity that requires authorisation. The difference between facilitating a payment and providing a payment service lies in the details, and the details are checked before any code is written.
We work with companies seeking authorisation and with those that want to satisfy themselves they do not need one. The second conversation is as useful as the first, and usually cheaper.
Situations in which we are called
- You are building a product that collects money on behalf of someone else
- You want authorisation as a payment or e-money institution
- You offer payment initiation or account information services
- A bank is refusing you access to its third-party interface
- Strong customer authentication has to be implemented and you want to know your exemptions
- A marketplace wonders whether it falls under the commercial agent exclusion
What we cover
- Assessing how the activity is classified and whether authorisation is needed
- The authorisation file for payment and e-money institutions
- The programme of operations, governance and outsourcing
- General terms, user information and the charging regime
- Strong customer authentication and the applicable exemptions
- Account access and relations with account servicing institutions
How we work
The first deliverable is a written classification: what you do, which category it falls into and what you need. If the activity requires no authorisation, we say so with the reasoning on paper — a document that proves useful later, in conversations with banks and investors.
If authorisation is needed, we prepare the file alongside building the product, not afterwards. Governance and capital requirements shape the architecture, and reworking them at the end costs more than designing correctly from the start.
What helps us start
- A description of the money flow: who pays, whom, through whom, when
- The business model and the revenue sources
- The shareholding and management structure
- The contracts with partners who touch the payment flow
