Payment Institution Licensing
Payment Institution (PI) licensing enables companies to offer payment initiation, money remittance, and merchant acquiring services under a regulated framework, a critical step for any business embedding payments into its product.
Payment Institution status sits below EMI licensing in regulatory scope but covers a broad range of commercially essential services: executing payment transactions, payment initiation (PIS), account information (AIS), money remittance, and card-based payment instruments. For many technology companies, a PI licence is the most proportionate regulatory route, carrying lower capital thresholds than full EMI authorisation while still enabling a regulated payments business.
GlobalB Law advises on PI licensing under Türkiye's Payment and Securities Settlement Systems Law (ÖHKAS), supervised by the BDDK and TCMB, as well as under PSD2 and the incoming PSD3 framework across EEA jurisdictions. We assess which licence category and jurisdiction best match your transaction flows, prepare the full application package, and manage the regulatory dialogue from first submission through to authorisation.
Our advice does not stop at the licence grant. Payment institutions face ongoing obligations, safeguarding of client funds, transaction monitoring, incident reporting, strong customer authentication compliance, and regular regulatory reporting. We build these into your compliance programme from day one so that growth does not outpace your regulatory obligations.
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常见问题
常见问题解答
What is the difference between a Payment Institution and an Electronic Money Institution?
The key distinction is the ability to issue electronic money. An EMI can issue e-money (store value on behalf of customers) and provide payment services. A PI can only provide payment services, it cannot hold customer funds as e-money. EMIs face higher capital requirements as a result. The right choice depends on your specific product and business model.
Can a Turkish-licensed Payment Institution passport into the EU?
Türkiye's ödeme kuruluşu regime is domestic and does not grant automatic EU passporting rights. If EU access is part of your strategy, you would need a separate EEA-based PI or EMI licence. GlobalB Law can design a dual-entity structure that efficiently serves both the Turkish and EU markets.
What ongoing obligations does a PI face after licensing?
Key ongoing obligations include: maintaining minimum capital and own-funds requirements, safeguarding client funds in separate accounts or through insurance, filing periodic regulatory reports, implementing and updating an AML/CFT programme, complying with Strong Customer Authentication requirements, and promptly notifying the regulator of operational incidents or changes in control.
How does PSD3 change the licensing landscape compared with PSD2?
PSD3 (expected to enter into force in stages from 2025–2026) introduces mandatory open finance provisions, stronger fraud liability rules, refined SCA requirements, and enhanced supervisory powers. Existing PI licences will not automatically comply; firms will need to update their programmes, contracts, and technical standards. We advise clients on PSD3 readiness as part of our ongoing retainer work.
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