Fintech Lawyer Romania — PSD2, EMI, PI Licensing
From neobanks and PSPs to lending platforms and crowdfunding, we help fintechs structure, license and scale across the EU from Romania.
Industry challenges we solve
BNR authorization timelines
Payment Institution (PI) and Electronic Money Institution (EMI) files at the National Bank take 9-12 months. PSD3 transition adds complexity.
Safeguarding & own funds
EMIs need EUR 350K initial capital + permanent safeguarding of client funds. PIs scale with payment volume.
Open banking & PSD2 strong customer authentication
TPP registration, eIDAS-compliant SCA, dispute handling under BNR Regulation 5/2018.
Crowdfunding under ECSPR
Investment-based and lending-based platforms need ASF authorization under EU Reg. 2020/1503.
Services we provide
PI / EMI license file at BNR
Business plan, risk framework, IT governance, AML program, qualifying shareholders fit & proper, board composition.
EU passporting
Notification procedure for freedom of services across EU/EEA — Romanian license unlocks the single market.
Crowdfunding (ECSP) authorization
ASF authorization for lending or investment-based platforms under Reg. EU 2020/1503.
Consumer credit & BNPL
OUG 50/2010 compliance, APR calculation, pre-contractual disclosure, IFN registration with BNR.
AML/KYC program & DORA
Risk assessment, transaction monitoring, plus operational resilience under EU DORA (Reg. 2022/2554).
Outsourcing & cloud governance
BNR Regulation 18/2009 + EBA Guidelines outsourcing — cloud register, exit plan, sub-outsourcing.
Applicable regulations
Law 209/2019 (PI/EMI)
Romanian transposition of PSD2 + EMD2.
BNR Regulation 4/2019
Authorization procedures for PIs and EMIs at the National Bank of Romania.
DORA (EU 2022/2554)
Digital Operational Resilience Act — applicable from 17 Jan 2025 to financial entities.
ECSPR (EU 2020/1503)
European Crowdfunding Service Provider Regulation — single license for platforms across the EU.
OUG 50/2010
Consumer credit framework for non-banking financial institutions (IFN).
Frequently asked questions
Can I get an EU-passportable EMI license in Romania?
Yes — once authorized by BNR, the EMI license is passportable across all EU/EEA member states via notification procedure.
What is the minimum capital for a Romanian EMI?
EUR 350,000 initial capital + ongoing own funds proportional to e-money outstanding (min 2% of average outstanding).
How long does BNR authorization take?
Realistic: 9-12 months for a complete file. Pre-application meetings with BNR significantly shorten cycles.
Can a non-EU founder hold an EMI?
Yes — but the qualifying shareholder must pass BNR fit & proper review, with documented source of funds.
Need Fintech & Payments legal counsel in Romania?
Introductory consultation in English — we'll map your regulatory exposure and a realistic compliance plan.