Four in ten EU payment firms have never used their passport

FintechZoom’s analysis of the EBA PSD2 register finds a sharply split European payments market, where many firms never notify cross-border activity while others passport across nearly the entire EEA. The findings raise fresh questions about how much the EU passport is actually used in practice as lawmakers move ahead with PSD3 and the Payment Services Regulation.

Why it matters: - The EU passport is supposed to let one payments licence open access to 30 countries. - FintechZoom’s analysis suggests many firms do not use that access at all, while a smaller group uses it almost everywhere. - That gap matters for fintech growth, cross-border competition and how policymakers judge the effectiveness of the single market.

What happened: - FintechZoom analyzed the EBA PSD2 register in a snapshot taken on 22 September 2026. - The register covers all 1,444 authorised payment and electronic money institutions in the European Economic Area. - 565 institutions, or 39.1%, have never notified into another member state. - 474 institutions have notified into 29 or 30 member states, effectively the whole bloc. - Only 28% of institutions sit between those two extremes.

The details: - Licensing geography strongly tracks cross-border reach. - In Ireland, Luxembourg, Cyprus, Lithuania, Latvia and Malta, the median licence holder reaches 29 countries. - In Germany, the median is one country. - In Spain, the median is one country. - In Portugal, the median is zero countries. - In Italy, the median is zero countries, and 84% of institutions have never notified anywhere. - Italy is the second most notified-into market in Europe, with 696 foreign institutions entering it. - German, Spanish and Portuguese firms show a similar pattern: these markets attract many foreign firms but produce few outward passporters. - New authorisations peaked at 272 in 2019 during PSD2 implementation. - New authorisations fell to 68 in 2025, a 75% decline.

Between the lines: - The data points to a market that is split between true pan-European operators and firms that stay local. - FintechZoom also looked at real-world presence using 323,860 agent records and 248 branch records. - Among the 217 institutions with both passports and agent networks, the median has notified into 29 countries but has an agent or branch in only one. - 31% of those institutions have no presence in any country they passported into. - FintechZoom treats that presence figure as a floor, because agents are only part of some business models. - The 29-country notification figure is also a ceiling, because notification does not equal trade or active operations. - The European Commission’s last comparable measurement, in a 2013 impact study on the original Payment Services Directive, found firms typically served no more than four EEA states outside their home country. - PSD3 and the Payment Services Regulation were agreed by EU co-legislators in 2026 on the assumption that the passport works.

What's next: - FintechZoom published the full report, the register snapshot with checksum, the extraction script and all derived tables for reproducibility and correction. - The evidence may feed into ongoing debates about whether the EU passport is delivering real cross-border access or just formal notification. - More information is available in FintechZoom’s announcement.

The bottom line: - The EU passport exists on paper for almost everyone in the market, but in practice many firms either never use it or use it at near-full scale, with little middle ground.