Stay compliant with PSD2 — without the complexity
Artlex Consult provides end-to-end legal and compliance support for fintech companies, payment institutions, and EMIs operating across the EU. From licensing to day-to-day compliance management.
PSD2 legal & compliance
PSD2 compliance covers one of the most detailed regulatory regimes in EU financial services — governing how payment institutions and electronic money institutions are licensed, how they manage customer data and third-party access, how they authenticate transactions, and how they report operational incidents. With PSD3 and the Payment Services Regulation expected to apply from 2027-2028, the compliance landscape is set to change significantly.
Artlex Consult provides legal and compliance advisory services for payment institutions, electronic money institutions, fintech companies, and crypto asset service providers operating under PSD2. Our services cover the full regulatory lifecycle — from assessing whether your business model falls within scope, through licensing and operational compliance, to ongoing regulatory monitoring and PSD3 readiness.
PSD2 + PSD3
Full directive coverage, include upcoming PSD3
EU-wide coverage
We work across all 27 member states and understand passporting, local implementation differences, and each national regulator.
Legal + compliance
We combine legal and compliance expertise that most firms separate into two different engagements.
Our services
Regulatory Applicability Assessment
Analysis of whether the business model falls within the scope of PSD2, covering payment service categories under Annex I, applicable exemptions, and mixed-activity entities. Includes assessment of cross-border applicability and interaction with MiCA and EMD2 where relevant. The output is a Regulatory Scoping Report setting out conclusions and recommended next steps.
Licensing Analysis
Assessment of whether the business model requires a Payment Institution or Electronic Money Institution licence, identification of the optimal licensing jurisdiction within the EU, and mapping of passporting options for cross-border operations. Takes into account the specific nature of the payment services provided and applicable exemptions under PSD2 Annex I.
Licenсe Application Support
Preparation of the full licence application package, including business plan, AML and compliance framework, governance structure, and capital requirements documentation.
TPP & Contract Documentation
Drafting and review of agreements with Third Party Providers, open banking API frameworks, user consent documentation, and service contracts in accordance with PSD2 Article 66 and 67 requirements. All documentation is adapted to the specific business model and the regulatory requirements of the applicable jurisdiction.
PSD2 Gap Analysis
Structured assessment of current operations against PSD2 requirements, covering strong customer authentication, incident reporting obligations, API access and TPP management, and operational resilience measures. Each identified gap is assigned a risk rating and addressed in a prioritised remediation roadmap.
AML / Fraud Compliance Programme
Design and implementation of a transaction monitoring framework, internal AML controls, SCA policy, and fraud detection procedures in accordance with PSD2 Article 95 and 96. Includes development of operational incident reporting procedures and internal escalation processes.
Crypto & PSD2
Assessment of whether crypto asset service providers authorised under MiCA also fall within the scope of PSD2, covering fiat payment services, fiat on/off-ramp operations, and electronic money issuance. Includes structuring of the correct licence combination across both frameworks.
Internal Compliance Audit
Combined legal and operational review of the compliance framework against PSD2 requirements, covering AML controls, SCA implementation, incident reporting procedures, TPP management, and operational resilience. Assesses both the legal adequacy of internal documentation and the operational effectiveness of compliance controls in practice. Delivers a findings report with prioritised remediation recommendations.
Why Artlex Consult
Scoping & proposal
We define the exact scope, deliverables, timeline, and fixed fee within 48 hours.
Analysis & delivery
We carry out the work — gap analysis, legal opinion, policy drafts, or licence preparation
Ongoing support
Optional retainer to keep you compliant as regulation evolves toward PSD3.