Disclaimer
This analysis includes only neobanks operating under an EMI (Electronic Money Institution) licence issued by an authority in one of the 27 EU Member States. Lighter licence types, such as PI and others, are outside the scope of this document.
Key trends
- There are 405 active neobanks operating as EMIs in the EU.
- Despite the overall tightening of licensing rules, some countries remain relatively comfortable places to obtain a licence. In those countries, the main difficulties arise after licensing, when the EMI is integrated into the global financial system. Connecting an EMI from such a country may be impossible, or abnormal fees may make the connection economically questionable.
- Countries that have issued many licences differ in regulatory quality. One external indicator is the number of licences available for sale.
- The EMI M&A market is undergoing a major adjustment. Norlerr Analytics will publish separate analysis on this topic. Renaming an EMI company is one sign that an M&A transaction has taken place.
- The market’s public image is still shaped by companies that provide financial services to an undefined group of people, such as Revolut (No. 229). In reality, these companies are not the majority of the market. A significant number of players come from other sectors, including banks and corporates.
- Banks are interested in an alternative financial perimeter subject to non-bank regulation. Examples include Banque Edel (No. 120), Banco Santander (No. 88), Danske Bank (No. 76), JPMorgan Chase (No. 294) and DZ BANK (No. 70).
- Corporates seek to reduce their dependence on financial institutions and integrate neobanks seamlessly into their internal business processes. Large groups moved first, including Facebook (No. 151), Booking (No. 146), Amazon (No. 210), Google (No. 210), Uber (No. 381), BP (No. 61) and Enel (No. 182); other corporates followed, including Hrvatski Telekom (No. 139) and Mercedes (No. 297).
- Since 2026, with the introduction of MiCA, a number of crypto companies have sought EMI licences, creating a two-core model — crypto and fiat — with an internal bridge between them. The process began with the largest companies, including Coinbase (No. 290) and Ripple (No. 299), while smaller companies have also started EMI licensing.
Summary
- Overall, since 2025 the market has shifted from the difficulty of obtaining a licence to the difficulty of retaining it. Over the shorter term, much depends on integrating an EMI and connecting it to key nodes of the international financial system.
- The EMI market has passed through several stages. It began as a market for enthusiasts, then became a market for companies providing financial services to an undefined group of individuals. It is now gradually becoming a respectable market for banks and corporates.