On 9 November 2026, the European Banking Authority published a short consumer factsheet on white labelling: bank accounts, cards, e-money and buy-now-pay-later sold under the brand of a retailer, an app or a telecom company, while a licensed bank or payment institution provides the service in the background.
The advice to consumers is simple. Before you sign up, check four things: who actually provides the product, whether it fits your needs, who handles your complaints, and how you end the agreement.
Nothing in the factsheet is a new rule. But when a regulator starts explaining your business model to your customers, it is usually because it has started looking at it closely. White label is not dead. The free ride is over.
Why the EBA is looking at white label banking
White labelling is not a niche any more. In its 2025 report on the subject, the EBA found that 35% of the banks that answered its risk questionnaire use white labelling. The report saw real benefits, more competition and easier access to financial services, but also two problems. Consumers often do not know which company is responsible for their money, and supervisors do not always see the partners who sell under someone else’s licence.
The EBA’s answer was to ask national supervisors to put white labelling on their 2026 list of supervisory priorities, and to help consumers tell the brand from the provider. The factsheet is the second part. The first part is already happening in supervisors’ offices.
What happens when the licence holder does not watch its partners
Denmark gave the market a clear example. In January 2026, Saxo Bank accepted a fine of DKK 313 million, about USD 50 million, from the Danish Financial Supervisory Authority. One of the two breaches of the anti-money laundering rules concerned its white label clients, the firms that offered Saxo’s trading platform to their own customers: the bank had not monitored those relationships closely enough.
The lesson is not about Saxo. It is about who pays. In a white label model, the licence belongs to the provider, and so does the responsibility. When the regulator comes, it does not fine the brand on the app. It fines the bank or payment institution behind it. Every licence holder in Europe has read about that fine, and every one of them has drawn the same conclusion: watch the partners more closely, or stop taking them.
What this means if you run on someone else’s licence
If your fintech sells accounts, cards, e-money or payments under a provider’s licence, expect your provider to change its behaviour in the coming months. In practice:
- More checks on you. Your ownership, your management, your finances and your own controls will be reviewed more often, and more deeply.
- More checks on your customers. Expect stricter onboarding, more questions on unusual activity and less patience with high-risk sectors and countries.
- More reporting and audits. Regular data, regular reviews, and the right for the provider, and sometimes its supervisor, to come and look.
- Clearer branding. Your customers must be able to see who the provider is. Presenting someone else’s licence as if it were your own is exactly what the EBA has in its sights.
- Harder contract terms. Shorter notice periods, wider termination rights for the provider and less room to negotiate.
None of this is bad news for a serious business. A provider that checks its partners carefully is a provider that will still have its licence next year. The real risk is the opposite one: a provider that checks nothing, until its supervisor arrives and it drops its partners overnight. Then your customers lose access to their money, and you lose your business, in the same week.
Stay white label, or get your own licence?
White label remains the fastest and cheapest way to bring a financial product to market. For a new brand testing a market, it is often the right choice. I explained the same logic for crypto in White Label Crypto Under MiCA: Can You Run Your Business on Someone Else’s CASP Licence? The question is not whether white label is good or bad. It is how long it stays the right model for you.
A licence of your own starts to make sense when:
- your volumes are large enough that the provider’s margin costs you more than running your own licence would;
- your whole business depends on one provider that can change its terms, or end the relationship, at short notice;
- investors or buyers value your company less because it owns no licence;
- you want to control your own onboarding, your own risk appetite and your own product roadmap.
There is also a third route that many founders overlook: buying a company that already holds a licence. It takes a regulator’s approval of the new owners and a proper due diligence, but it is often faster than applying from scratch. I compared the three routes in White Label, Your Own EMI Licence, or Buy an EMI? Three Ways to Launch a Payments Business in 2026, and the real numbers are in How Much Does an EMI Really Cost? Capital, Software, Office and Running Costs Before You Apply.
How FintechLex can help
Whichever route you choose, we help you take it with your eyes open:
- If you stay white label: we help you choose a provider that will still be there next year, review the contract, and prepare the controls, documents and reporting your provider will now ask for;
- If you want your own licence: we help you choose the right licence and country, build the application and prepare the people, procedures and capital the regulator expects;
- If you want to buy a licensed company: we find suitable payment institutions and e-money institutions for sale, run the due diligence and manage the change of control with the regulator.
Before your provider reviews you, review your provider. Write to us at insight@fintechlex.com or on WhatsApp +41 787 983 770.
Rene-Philippe
Sources: European Banking Authority, consumer factsheet on white-labelled financial products and services (9 November 2026); European Banking Authority, Report on white labelling (October 2025), based on its 2025 risk assessment questionnaire; Danish Financial Supervisory Authority and press reports on the DKK 313 million fine accepted by Saxo Bank (January 2026).
This article is for general information only and does not constitute legal advice.
