Under Article 66 of PSD2, a Payment Services User (PSU) has the right to use a Third Party Provider (TPP) licence to obtain payment services. These TPPs are Regulated Entities in their own right with Payment Initiation Services (PIS) or Account Information Services (AIS) roles.
However, in the real world, there are many examples where a ‘fourth party’ is involved. These fourth parties are separate entities contracted by TPPs to provide services on behalf of the TPP. Some of these fourth parties are listed on the National Competent Authority registers, but many are not and therefore sit outside the regulatory boundaries.
OBE’s research shows which of the 346 TPPs licensed in the EEA at the end of August 2022, provide their license to fourth party providers listed on the National registers and which countries have the highest concentration of such companies.
This report aims to outline the “TPP-as-a-Service” service across the EEA. This report provides:
- Overview of “License-as-a-Service” offering
- List of TPPs providing License-as-a-Service Agents listed on the NCA registers
- Profile of these TPPs
Note, this report does not cover the large number of commercial organisations also utilising TPP licences which are not listed on the NCA registers but can still participate within the open banking ecosystem.
