Licence route · PISP
Payment Initiation Service Provider
For firms that initiate payments on behalf of customers. Provided under an authorised payment institution permission with its own capital and PII expectations. Genesis support is in development.
In DevelopmentApplication depth: Substantial
Who this route is generally for
Open-banking firms that initiate payments on a customer's behalf.
Typical activity
Payment initiation services — an activity provided under an authorised payment institution permission.
Key indicators
Regulatory status
Authorised (PIS is an activity under an API permission)Source: PSRs 2017, reg. 6 · Position at 2026-07-30
Initial capital
€50,000 initial capital (PIS-only)Source: PSRs 2017, Sch. 2 · Position at 2026-07-30
Ongoing own funds
Initial capital held on an ongoing basis; PII also requiredSource: PSRs 2017, reg. 22 · Position at 2026-07-30
Safeguarding
Not applicable where no relevant funds are heldSource: PSRs 2017 · Position at 2026-07-30
Route indicators are informational and require confirmation against the full business model and applicable law.
How Genesis supports the route
Building a PISP the regulator expects.
- Determines route eligibility from actual activities and funds flow
- Builds the regulatory business plan and programme of operations
- Constructs the route-specific financial model
- Designs safeguarding where applicable and reconciles it
- Assembles the evidence schedule and challenges the application before submission
Common weaknesses
What delays applications.
- Financial model that contradicts the business narrative
- Safeguarding design that does not reconcile with funds flow
- Governance that exists on paper but not in operating reality
- Evidence gaps against stated regulatory claims
- Permissions that do not match the actual activities
Current Genesis route status: In Development
This route is not yet certified. Support status is shown honestly and updated as it graduates.