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What Is Banking as a Service (BaaS)? A Founder's Guide (2026)

What is Banking as a Service (BaaS)? The founder's guide to operating a fintech product without an EMI licence — providers, costs, and timelines.

Jahja Nur Zulbeari | | 10 min read

Most fintech founders encounter the same realisation at some point during product scoping: offering payment accounts, issuing cards, or holding user funds requires a banking licence — and obtaining one takes 12–24 months and costs €500,000+. Building a fintech SaaS product without understanding this landscape first leads to expensive architectural rework.

Banking as a Service exists to solve this problem. Here is what it is, how it works, and when you need it.

The Short Answer

Banking as a Service (BaaS) is a model where a licensed bank or e-money institution provides its financial infrastructure — accounts, cards, payments, compliance — via APIs to non-bank companies. Instead of obtaining your own licence, you build on top of a BaaS provider’s licence and infrastructure. You own the product experience and the customer relationship; the BaaS provider handles the regulated infrastructure underneath.

Why BaaS Exists

Financial regulation requires a licence to: hold customer funds, issue payment accounts (IBANs), issue payment cards, initiate payments on behalf of users, and operate as an e-money institution.

Obtaining an EMI (Electronic Money Institution) licence in the EU takes 12–18 months, costs €200,000–€500,000 in legal and compliance fees, requires a minimum capital requirement (typically €350,000), and demands ongoing compliance infrastructure that adds €100,000–€300,000/year in operational cost.

For most fintech startups, this is not the right investment at the early stage. BaaS provides access to the same regulated infrastructure as a service — at a fraction of the cost and time.

How BaaS Works

A BaaS provider sits between the regulated banking infrastructure and your product:

Your Product (UI, UX, Business Logic)
        ↓ API calls
BaaS Provider (Accounts, Cards, Payments, Compliance)
        ↓ Regulated infrastructure
Banking Licence / Central Bank Settlement

Your product calls the BaaS provider’s APIs to: create a payment account for a user, issue a virtual or physical card, initiate a SEPA transfer, check a balance, receive webhook notifications for transactions.

The BaaS provider handles: regulatory compliance, KYC/AML checks, transaction monitoring, card scheme membership (Visa/Mastercard), SEPA connectivity, and central bank settlement.

What BaaS Enables vs What It Does Not

BaaS enables:

  • Issuing IBANs or sort codes / account numbers to your users
  • Virtual and physical Visa/Mastercard card issuance
  • Holding e-money balances on behalf of users
  • SEPA credit transfers and direct debits
  • Faster Payments (UK)
  • Transaction webhooks and account data access
  • Spend controls and card programme management

BaaS does not replace:

  • Your product’s UI and user experience (you build this)
  • Your business logic and product differentiation (you build this)
  • A payment gateway for card acceptance (use Stripe or Adyen)
  • Open Banking data access (use TrueLayer or Nordigen)
  • Your own KYC flow UI (you build the UX; BaaS provides the verification service)

Leading BaaS Providers in Europe (2026)

ProviderLicenceStrengthsBest For
ModulrUK FCA EMI + EUPayroll, B2B payments, strong UK coverageUK-focused B2B fintech
SwanFrench ACPR EMIExcellent developer experience, embedded financeEuropean consumer and B2B products
SolarisGerman BaFin Banking LicenceFull banking products, strong German marketConsumer banking products, DACH market
RailsrUK FCA EMIBroad product range, global coverageMulti-market fintech
Stripe TreasuryMultiple (via partners)Seamless Stripe integrationCompanies already using Stripe
Adyen for PlatformsDutch DNB BankingEnterprise-grade, strong complianceScale-ups and enterprise
Treezor (Société Générale)French BankingEstablished European bank backingFrench market, risk-averse buyers

BaaS vs Open Banking — When to Use Each

This is one of the most common points of confusion for fintech founders:

CapabilityOpen Banking (PSD2)BaaS
Read bank account data
Initiate payments from existing accounts
Create new payment accounts / IBANs
Issue payment cards
Hold user funds (e-money)
Required licenceAISP / PISP registrationOperates under BaaS provider’s licence
Time to integrate4–8 weeks8–16 weeks
Cost€0–€500/month€500–€5,000+/month

Use Open Banking when your product needs to read account data or initiate payments from existing bank accounts. Use BaaS when your product needs to create new financial accounts, issue cards, or hold funds. For UK-based products, the FCA regulation guide for fintech startups clarifies which regulatory regime applies to each approach.

Many fintech products use both: Open Banking to aggregate and read existing account data, BaaS to issue new accounts and cards.

BaaS Cost Structure

BaaS pricing is more complex than most SaaS pricing. Expect:

Setup costs:

  • Technical integration: €5,000–€50,000 (typically done by your development team or agency)
  • Compliance onboarding: €2,000–€15,000 (due diligence, legal review)
  • Programme setup: €5,000–€25,000 (card programme setup, product configuration)

Ongoing costs:

  • Monthly platform fee: €500–€5,000/month
  • Per active account: €0.50–€5.00/account/month
  • SEPA transactions: €0.10–€0.50 per transaction
  • Card transactions: 0.1–0.3% + €0.05–€0.10 per transaction
  • Card issuance: €2–€10 per physical card, €0.50–€2 per virtual card

At 1,000 active accounts with moderate transaction volume: estimate €3,000–€8,000/month in BaaS fees.

When to Get Your Own Licence

Operating under a BaaS provider’s licence is the right approach at the early stage. Consider obtaining your own licence when — for UK products, the FCA authorisation process sets out the full requirements and timelines:

  • Your BaaS fees exceed €100,000/year and the economics of your own licence make sense
  • Your BaaS provider’s product limitations are constraining your roadmap
  • Enterprise clients require direct regulatory relationships rather than a white-label arrangement
  • You need greater control over compliance processes for specific markets

The timeline for an EMI licence in the EU is 12–18 months. Most fintech companies reach Series B or significant ARR before this investment is justified.

Integration Timeline

Integrating a BaaS provider into a fintech SaaS product typically takes:

PhaseDuration
Provider selection and commercial negotiation4–8 weeks
Technical integration (API, webhooks, KYC flow)6–10 weeks
Compliance onboarding and due diligence4–8 weeks (runs in parallel)
Testing in sandbox environment2–4 weeks
Production launch1–2 weeks
Total12–20 weeks

This is why fintech MVPs take 16–24 weeks rather than the 10–16 weeks of a standard SaaS MVP — a gap that custom SaaS MVP development engagements should account for in scoping.


Zulbera builds fintech SaaS products and BaaS integrations for European founders — from API integration through KYC flow design and compliance architecture. If you are building a financial product and want to understand which BaaS provider fits your use case, request a private consultation.

Jahja Nur Zulbeari

Jahja Nur Zulbeari

Founder & Technical Architect

Zulbera — Digital Infrastructure Studio

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