Securing Your Financial Future: Why a Bank License Matters

Anna Schmidt, COUNSEL
12 December 2023

Table of Contents:

In the intricate world of finance, navigating the regulatory landscape is no less daunting than scaling the highest peak. A bank license, a crucial cog in this complex machinery, serves as a beacon of trust and security in the bustling financial marketplace. Why does it hold such significance, and what does it take to secure one? Let's embark on this exploration.

Key Takeaways

  • A bank license signifies adherence to stringent regulatory standards, ensuring customer protection and financial stability, and is critical for establishing trust in banking operations.
  • The process of acquiring a banking license is meticulous, involving comprehensive documentation and adherence to capital requirements, and can take between six to twelve months, depending on jurisdictional procedures.
  • While traditional banks follow established licensing protocols, digital-only banks and e-money firms navigate a distinct regulatory landscape, often leveraging fintech licenses and partnerships to expand their operations.

Understanding the Essence of a Bank License

Bank license
A banking license fundamentally serves as a seal of approval, as the banking licence certifies that a financial company complies with rigorous government regulations, ensuring adherence to regulatory requirements, customer protection, and oversight by regulatory bodies. More than just a legal requirement, it is a prerequisite for a company to be recognized as a bank, establishing trust and security in financial transactions.

Obtaining a bank license involves initiating a review with the national supervisory authority, complying with legal obligations, and demonstrating the bank's operational competence. The European Central Bank (ECB) evaluates applications based on four primary criteria, and large investment firms must also secure a banking license. It usually takes six to twelve months for the application decision to be made. The process can vary based on individual circumstances..

Acquiring a banking license requires a financial institution to meet stringent criteria, including:

  • Maintaining minimum capital requirements

  • Having a certain number of directors

  • Ensuring the spread and residence of shareholders

  • Revealing beneficial shareholders

  • Maintaining financial reserves

  • Ensuring the security of their data systems

The Role of Regulatory Bodies

Regulatory bodies like FINMA and BaFin serve as the guardians of the financial realm. They have several important roles, including:

  • Casting a watchful eye over banking operations

  • Ensuring adherence to strict government regulations

  • Safeguarding system integrity

  • Protecting customers

These regulatory bodies play a crucial role in maintaining the stability and security of the financial industry.

FINMA's specific role in the Swiss banking landscape involves monitoring supervised enterprises to guarantee their compliance with Swiss banking laws and regulations. On a global scale, FINMA represents Switzerland in the Basel Committee on Banking Supervision, which plays a significant role in the establishment of international banking standards and practices.

Types of Banking Licenses

The world of banking is not a monolith; it encompasses a spectrum of banking services, each requiring a specific type of license. Traditional banking licenses cater to the conventional licensed bank sector, particularly those with physical banking branches that provide in-person services.

On the other hand, obtaining an e money licence enables companies to provide payment and financial services such as transfers and currency exchange. It does not authorize them to function as a comprehensive bank or oversee deposits.

An institution holding a full banking license can partake in conventional banking operations, offering a broader spectrum of services. The distinction between these licenses has a profound impact on a business's service offerings, marketing tactics, and business models within the financial sector.

Protection Mechanisms for Customers

In the event of a bank's insolvency, customers' deposits are protected through the European Deposit Guarantee Scheme, which offers comprehensive coverage for deposits and safeguards eligible deposits of up to EUR 100,000 per depositor. This ensures that customers, in most cases, can recoup their funds should their bank fail.

The majority of banks in Germany, for instance, are part of voluntary deposit guarantee schemes that provide additional and broader protection. The deposit protection scheme in Germany safeguards all deposits of private individuals, private partnerships, and foundations, including sight, time, and savings deposits, as well as registered savings bonds.

Crafting a Business Plan for Bank Licensing

Bank license procedures
The process of acquiring a banking license can be likened to navigating a vast ocean. A compass in this voyage is a solid business plan, which forms the basis of the application. It encompasses:

  • Defining clear objectives

  • Articulating the regulatory business plan (RBP)

  • Incorporating sections pertaining to business operations, structure, and finances.

Grasping the minimum capital requirements is essential. The minimum tier 1 capital ratio mandated by financial regulators is typically set at 6%, and funds allocated to meet the capital requirements should not be utilized for covering mobilization expenses. Alongside capital requirements, the establishment of a robust organizational structure and governance system is equally vital. Good corporate governance ensures the efficient and proactive oversight of the bank's destiny by its board and senior management.

Minimum Capital Requirements

In the realm of banking, capital plays the role of a safety net. The minimum capital requirement functions as a reserve to mitigate potential losses resulting from the bank's exposure to risks. To illustrate, the minimum capital requirement for acquiring a full banking license in the European Union is 5 million, while for Switzerland, it is 10 million Swiss francs. In Germany, the requirements vary based on the type of institution.

The determination of the minimum capital requirement involves meeting regulatory frameworks. One approach involves meeting Pillar 2 requirements with at least 56.25% of Common Equity Tier 1, while another involves calculating the total capital ratio as the institution's total capital in relation to its total risk-weighted assets.

Organisational Structure and Governance

A well-defined organizational structure and governance system serve as the backbone of a bank. They provide essential checks and balances, mitigate excessive risk-taking, ensure transparent decision-making, and align stakeholder interests. The primary components of a bank's organizational framework usually encompass retail banking, commercial banking, and investment banking functions. A well-established organizational framework enhances transparency by establishing clear lines of responsibility and accountability.

The impact of governance on the operations of a bank is significant. It delivers:

  • Efficient control and supervision

  • Safeguards the interests of investors and beneficiaries

  • Combats corruption

  • Addresses potential risks encountered by banks

Banks are required to adhere to the 13 principles outlined by the Bank for International Settlements (BIS) to ensure robust and transparent risk management.

The Application Journey: Securing a Bank License

Application for the bank license
Securing a banking license can be a complex and challenging process. The first step involves reaching out to the Prudential Regulation Authority (PRA) and Financial Conduct Authority (FCA) authorizations teams, notifying them of your intention to apply for a banking license. However, obtaining the license could entail a protracted, intricate, and costly process, contingent on the type of banking license being pursued.

The typical documentation needed for a banking license application consists of application forms, supporting documents, and a comprehensive business plan. The application should demonstrate the institution's ability to accept customer funds and comply with regulatory requirements. The review process further comprises a 'high-level-summary meeting' during which the regulators request a summary of the bank's plans.

Documentation and Review Process

Acquiring a banking license is a challenging journey, each step of which necessitates thorough preparation. Providing extensive documentation to the regulator forms the first step. This includes a fully paid-up minimum capital, a business plan, proof of identity, and proof of address.

The national competent authority reviews the documents during the bank license application process to ensure compliance and grant approval. The criteria for review include the coherence of the documents with other necessary documents, independent review and scrutiny of the documents, and the thoroughness of the application.

Interview and Assessment Stages

The process of acquiring a banking license does not conclude with the submission of documents. The next stage involves interviews and background checks. The objective of these interviews and checks is to ascertain the trustworthiness and suitability of individuals responsible for overseeing or influencing the bank's operations, ensuring they possess the requisite knowledge and experience.

During the interview phase, inquiries may pertain to specifics regarding the bank seeking the license, such as familiarity with the current CEO, the business model, and comprehension of various types of banks and their operations. Regulators utilize a combination of qualitative and quantitative criteria when assessing applicants for a banking license during the evaluation process.

Special Considerations for Digital-Only Banks and E-Money Firms

The financial landscape is diverse, populated with a variety of entities, each facing its unique challenges and opportunities. Digital-only banks and e-money firms are no exception. These entities disrupt traditional banking by enabling customers to conduct financial management tasks online using smartphones, as opposed to visiting physical branches.

However, they encounter regulatory challenges such as:

  • striking a balance between innovation and risk management

  • creating robust regulatory frameworks

  • upholding excellent customer service standards

  • establishing efficient financial crime controls

  • complying with the regulations of systemic payment systems.

Navigating the Fintech License Pathway

The pathway to obtaining a fintech license differs from the traditional banking license trajectory. A fintech license is a regulatory authorization that permits institutions to accept public deposits or crypto-based assets, contingent upon specific conditions and criteria.

Acquiring a fintech license offers numerous advantages, including:

  • Expanded market reach and access to a wider customer demographic, particularly in the retail sector

  • Passporting privileges across various jurisdictions

  • Competitive edges over conventional banks, such as a startup-oriented environment and absence of legacy technology

Collaborations and Partnerships

In the world of fintech, collaboration is the key to success. Forming partnerships with established banks can help fintech companies operate under existing licenses and expand their services. Instances of successful partnerships include the collaboration between HSBC and Tradeshift in supply chain finance, and N26's partnership with Wise.

The Swiss and German Roadmaps to Banking Excellence

Swiss and German financial licenses
Just as each country has its own culture and traditions, they also have unique regulatory frameworks for banking. Switzerland and Germany, renowned for their precision and efficiency, are no exception. Each has its regulatory bodies, FINMA in Switzerland and BaFin in Germany, overseeing their respective banking sectors.

While the Federal Financial Supervisory Authority (BaFin) and the Deutsche Bundesbank (BBk) oversee the banking sector in Germany, the Financial Market Supervisory Act (FINMASA) serves as the overarching law for the banking sector in Switzerland.

Swiss Precision in Banking Regulation

The Swiss are renowned for their precision, and their approach to banking regulation is no exception. The primary law that governs Swiss banking regulation is the Financial Market Supervisory Act (FINMASA), which serves as the overarching law for the banking sector.

The Swiss Financial Market Supervisory Authority (FINMA) is responsible for establishing and enforcing regulations, carrying out inspections and audits, and overseeing the general financial stability of the banking industry. This approach ensures a stable and secure financial environment, making Switzerland a global banking hub.

Germany's Framework for Financial Institution Licensing

Germany, known for its robust engineering and craftsmanship, applies the same rigor to its banking sector. The Federal Financial Supervisory Authority (BaFin) serves as the principal regulatory authority for banking regulation in Germany. The legal framework encompasses aspects such as:

  • banking governance

  • internal controls

  • bank capital

  • supervision by the ECB and the Deutsche Bundesbank

  • a licensing system designed to ensure that only reliable institutions engage in business activities.

In Germany, specific types of banking business, such as specialized credit, necessitate banking licenses. The categories of banks operating in Germany encompass private commercial banks, public savings banks, and cooperative banks. These stringent and comprehensive requirements ensure a strong and reliable banking sector.

Prudential Oversight and Ongoing Compliance

Obtaining a banking license is just the beginning. Its maintenance necessitates continual oversight and compliance. The Bank of England, for instance, is tasked with the prudential regulation and supervision of banks, building societies, credit unions, insurers, and major investment firms, all of which require banking licences.

In Switzerland, the standard ongoing compliance obligations for banks encompass:

  • The protection of individual bank customers

  • The maintenance of stability

  • The fulfillment of obligations under pertinent acts, ordinances, and FINMA circulars

These efforts ensure the continued protection of customers and the stability of the financial sector.


Navigating the intricate labyrinth of banking regulation and securing a license is no easy task. It requires meticulous preparation, rigorous compliance, and constant vigilance. However, the reward at the end of this journey is the ability to provide secure, trustworthy banking services to customers, thereby playing a vital role in the stability of the global financial system. As the banking landscape evolves, so too will the path to securing a banking license. And as we have seen, whether it's a traditional bank, a digital-only bank, or an e-money firm, the journey is well worth the effort.

Frequently Asked Questions

A banking license is legal permission granted to a financial institution to carry on banking business, and it allows the institution to use the words "bank" in their name.