Launching a fintech company is sometimes treated primarily as a licensing project. In practice, a licence or registration is only one part of a much wider operating model. A payment business also needs a clearly defined product, compliant processes, suitable technology, banking relationships and access to the infrastructure required to move and safeguard money.
The logical starting point is therefore not the licence. It is the business model. Regulation, software and payment infrastructure should be built around what the company intends to offer.
1. Define the business model and services
Before choosing a jurisdiction, technology platform or banking provider, founders need to define exactly what the company will do.
This starts with market and competitor analysis. The objective is not simply to identify companies offering similar products, but to understand where existing solutions fall short. There may be an underserved customer segment, a difficult payment corridor, a specialist industry with specific requirements or a customer experience that existing providers handle poorly.
The target audience should then be defined clearly. A fintech serving consumers sending international remittances operates very differently from one serving online merchants, crypto companies or SMEs using multi-currency accounts. Customer type affects onboarding, AML controls, transaction patterns, product design and even which financial institutions may be willing to work with the business.
The next step is to map the products and customer journey. Will customers hold balances? Exchange currencies? Send domestic or international payments? Receive local account details? Use payment cards? Accept payments from their own customers? Convert between fiat currencies and digital assets?
Geography is equally important. Founders need to decide where customers will be located, where funds will move and which currencies the company intends to support. These choices influence both regulation and the banking and payment infrastructure that will eventually be required.
An initial business plan and financial model should also cover projected transaction volumes, pricing, provider costs, staffing, compliance expenditure, technology costs and capital requirements.
The key principle is simple: the regulatory framework and technology should follow the business model, rather than forcing the business into a structure selected too early.
2. Obtain the appropriate licence or registration
There is no single “fintech licence”. The appropriate regulatory route depends on the services provided, target markets, whether client funds are held and how transactions are executed.
Canada — Money Services Business registration
For many payment, foreign exchange and money-transfer models, Canada is one jurisdiction founders may consider.
Businesses conducting specified money services can be required to register with the Financial Transactions and Reports Analysis Centre of Canada, or FINTRAC, as a Money Services Business (MSB).
Activities that can fall within the MSB framework include foreign exchange dealing, remitting or transmitting funds, issuing or redeeming certain negotiable instruments and dealing in virtual currency. Whether registration is required must be assessed against the company’s actual activities and structure.
It is equally important to understand what MSB registration does not provide. FINTRAC registration is a regulatory registration requirement; it is not a banking licence or an endorsement of the company. An MSB must continue to meet its applicable AML obligations, including requirements relating to customer identification, record keeping, reporting and its compliance programme.
Canada can be relevant to fintech founders because it provides a defined federal framework covering a range of money-service activities. However, obtaining MSB registration does not mean that the company is ready to launch.
The business still needs compliance procedures and personnel, transaction monitoring, banking or account partners, appropriate software and the payment connections required to deliver its services.
Other Canadian regulatory requirements may apply as well. In particular, businesses conducting certain retail payment activities may separately fall within the Retail Payment Activities Act and need to register as a payment service provider with the Bank of Canada. FINTRAC MSB registration and Bank of Canada registration are therefore separate questions and should be assessed independently.
Switzerland — SRO membership
Switzerland has a different structure for certain financial intermediary business models.
Under the Swiss Anti-Money Laundering Act, certain financial intermediaries can be supervised for AML purposes through membership in a FINMA-recognised self-regulatory organisation (SRO).
This structure may be relevant to particular payment, exchange or financial-intermediation activities. It should not, however, be treated as a general alternative to every type of Swiss financial licence. Founders need to assess whether their planned activities fall within the SRO framework or require another form of regulatory authorisation.
EEA — Payment Institution or Electronic Money Institution licence
For companies planning regulated payment or e-money services across European markets, a Payment Institution (PI) or Electronic Money Institution (EMI) licence may be appropriate, for example, Emoney Institution License in Malta.
At a high level, a PI is authorised to provide specified payment services. An EMI can issue electronic money and may also provide payment services within the scope of its authorisation. This distinction becomes particularly important where the business intends to allow customers to hold stored monetary value.
Depending on the jurisdiction and business model, authorisation requirements can include capital, governance, compliance arrangements, safeguarding of customer funds, risk management, security controls, local substance and regulatory approval of the proposed operating model.
Canada, Switzerland and the EEA should not be compared simply on the basis of which registration appears easier to obtain. The appropriate regulatory route depends on the services, customers, target markets and long-term strategy of the fintech company.
3. Select the right fintech software
Once the operating and regulatory model is clear, the company can select technology that matches it.
A business managing customer accounts, balances, transactions and internal ledgers will typically require core banking software. A model combining fiat accounts with digital assets may require crypto-fiat wallet software. Merchant-focused companies may need acquiring software, while a cross-border money-transfer business may require remittance software designed around beneficiaries, payment corridors and FX.
The platform with the longest feature list is not necessarily the right choice. What matters is whether the software supports the actual product, regulatory obligations and operational processes of the business.
Important factors include APIs, integrations, scalability, compliance functionality, KYC and AML workflows, reporting, reconciliation, security, audit trails and the ability to connect external financial providers.
Technology should also leave room for growth. Adding a new currency, bank, payment rail or market should ideally be an integration project rather than a reason to replace the company’s core system.
4. Build the banking and payment infrastructure
A licensed or registered fintech company still needs external financial infrastructure before it can operate effectively.
Depending on the business model, this can involve banking and account providers, payment service providers, safeguarding accounts, card issuing or card programme partners, FX providers, correspondent or settlement relationships and KYC/KYB and AML technology providers. Businesses involving digital assets may also need crypto on-ramp and off-ramp providers.
The company may need access to payment rails such as SWIFT, SEPA, ACH, EFT or other local systems, either directly where available or through another financial institution.
In practice, several providers often need to work together. A bank may provide accounts but not support every required payment corridor. Another provider may offer payment connectivity but decline certain customer categories. Card providers, safeguarding institutions and FX partners may each have their own due-diligence and compliance requirements.
This is why payment infrastructure can sometimes be harder to establish than the original registration or licensing. The challenge is not simply finding individual providers. It is creating a network of providers, integrations and operational processes that works reliably as one system.
Conclusion
Launching a fintech payment company is not a single licensing exercise. It requires alignment between:
business model → regulation → software → banking and payment infrastructure.
These elements should ideally be planned together from the beginning. Changing the target customer, adding a new service or entering another country can affect regulation, technology and provider relationships at the same time.
A well-structured fintech project therefore starts with a clear business model and builds each subsequent layer around the same operating reality.
