What this is
Licensing under the Central Bank's payment token and payment services regimes, and answering the prior question of whether you need to be.
The characterisation question
The Central Bank regulates functions, not labels. Issuing a token that references fiat, converting one, holding or transferring one for others, operating a wallet that holds client fiat — each is a distinct activity with a distinct answer.
We characterise the flow of funds before anyone builds it, so the perimeter question is answered on paper rather than discovered in an application.
What the work involves
Mapping the arrangement against the payment token, retail payment services and stored value regimes. Drafting the application. Structuring safeguarding of client funds, which is a structural requirement rather than a policy. Building the consumer protection and complaints documentation the Central Bank expects.
The overlap nobody plans for
A firm can sit inside the Central Bank perimeter and VARA's at the same time. That is normal. What is not normal is discovering it late.
Aufsichtsbehörden
Häufige Fragen
Is a stablecoin a payment token?
Often, but the answer depends on the mechanics — what backs it, who can redeem it, and what it is used for. That analysis is the first piece of work, not an assumption.
Quellen
- Scope of work described here reflects our practice, not a regulatory requirement — Regulatory statements on these pages carry the same review status as elsewhere on the site