Payment Firms Passport Into 29 Countries, or None

The European Banking Authority publishes the full register of licensed payment firms as a downloadable file, updated at least once a day. HaiPay downloaded today's copy, checked it against the checksum the EBA publishes beside it, and counted.

Of the 1,455 payment institutions and e-money institutions authorised across the European Economic Area, 581, or 39.9%, are listed in no country other than their own. They have a licence that works in 30 countries and use it in one.

That matches the four-in-ten figure circulating this week. The more striking number is at the other end.

What the passport is

A payment firm licensed in one EEA country can serve customers in the other 29 without applying again. It tells its home regulator where it intends to operate, the home regulator notifies the host, and the entry appears in the register the EBA maintains under Article 15 of the second Payment Services Directive. National authorities own the data and update it at least daily; the EBA publishes the whole file, and a checksum, for anyone to download.

That single filing is the legal basis of most cross-border payment businesses in Europe. It is also, for most licence holders, unused.

Almost everyone who leaves home goes everywhere

Of the 874 firms listed outside their home country, 476 are listed in all 29 of the others. Another 123 are listed in 26 to 28. Only 142 are listed in between one and five.

The register, in other words, has almost no middle. A firm either stays home or files for the entire single market. The median passporting firm covers 29 countries.

The pattern is strongest among e-money institutions, the licence most used by prepaid, wallet and card programme businesses. There are 429 of them. Only 105 stay home, and 236, more than half of all of them, are listed in every other EEA country.

Payment institutions, the broader licence covering acquiring, money remittance and payment initiation, are more domestic: 476 of 1,026 are listed nowhere else.

In every market, most licensed providers are foreign

Turn the data around and count, for each country, the firms licensed there against the firms from elsewhere listed as providing services there.

Every one of the 30 countries has more of the second than the first. Germany has 95 home-licensed firms and 705 passported in. Slovenia has five and 653. Austria has ten and 699. Even Lithuania, which has more home-licensed payment and e-money firms than any other EEA country at 151, has 563 listed in from elsewhere.

This is what a single market looks like on paper. Whether those firms serve anyone in those countries is a different question, and the register does not answer it.

Where the licence is used, and where it is not

Home countries differ sharply in how much their firms travel.

Ninety-two per cent of Belgium's 47 firms are listed abroad, 85% of Luxembourg's 39 and 84% of Ireland's 63. Lithuania, the largest home base, sits at 73%.

Italy is the outlier at the other end. Of 75 Italian payment and e-money institutions, 12 are listed in another EEA country. Romania is at 29% and Hungary at 30%.

Age does not explain much. Firms authorised in 2019 or earlier passport at 58%, those authorised from 2020 to 2023 at 65%, and those authorised since 2024 at 58%. New entrants are not noticeably more European than old ones.

What this data is not

Being listed in a country is a notification, not evidence of business. A firm can be listed in 29 countries and have customers in two. The register carries no volumes, no revenue and no customer counts, and HaiPay makes no claim about any firm's activity.

The register covers payment institutions and e-money institutions. It does not cover banks, which passport under separate banking rules, and it is not a count of everyone who can process a payment in Europe.

HaiPay's count excludes three other categories in the same file: 2,759 exempt small payment institutions, none of which lists a host country; 129 registered account information service providers; and 323,867 agents, the distribution networks that firms register under their own licences.

National authorities supply and correct the data, and the file shows the seams. Seventeen entries use a country code, "EU", that does not appear in the EBA's own list of EEA country codes; 12 of those have no other country recorded. And 319 entities carry more than one authorisation date. HaiPay used the earliest.

What to watch

Whether the all-or-nothing shape holds when the register is counted again next quarter. It is the kind of pattern that a change in how authorities file notifications could flatten, without anything changing in the market.

Whether Italy's rate moves. Among the countries with more than 20 licensed firms, its 16% is the lowest in the EEA.

And the agent numbers. There are 223 registered agents for every authorised payment or e-money institution in the file, and that is where the actual distribution of payments in Europe sits. It deserves its own count.