Specialized Banking License (Fintech Bank) is a bank authorisation with a narrower list of permitted activities and lower minimum capital than a full banking licence, designed for technology-led firms that want to take deposits and offer payments and lending without an investment business. The holder is usually a real credit institution with deposit insurance and central bank account access, unlike an EMI. In Lithuania a specialised bank needs €1m of initial capital against €5m for a regular bank, is barred from investment services, and is assessed jointly by the Bank of Lithuania and the ECB; it can passport across the EEA. Switzerland's FinTech licence caps public deposits at CHF 100m. Acquisitions require ECB change-in-control approval.
Lithuania's specialised bank licence
Lithuania created the best-known version. A specialised bank needs initial capital of €1m, against €5m for a regular bank, and may need more depending on its activities. In exchange, the Law on Banks restricts it from investment services such as investment advice, securities brokerage, fund management and custody of client financial instruments. Apart from capital and activity scope, the requirements, authorisation process and supervision are the same as for a regular bank, and applications are assessed jointly by the Bank of Lithuania and the European Central Bank.
Because a specialised bank is an EU credit institution, it can passport its permitted activities across the EEA, and its deposits are covered by the Lithuanian deposit guarantee scheme up to €100,000 per depositor. Revolut received a Lithuanian specialised bank licence in 2018.
Switzerland's FinTech licence
Switzerland's equivalent, in force since 1 January 2019, works differently. A FINMA FinTech licence holder may accept public deposits up to CHF 100m but may neither invest those funds nor pay interest on them. Minimum capital is 3% of deposits and at least CHF 300,000. It suits payment and wallet businesses that need to hold client money, not lenders.
Specialised bank vs EMI
An EMI holds customer money as e-money and must safeguard it; it cannot lend those funds or pay interest. A specialised bank holds deposits, can lend them out, and protects customers through capital requirements and deposit insurance instead of safeguarding.
An illustrative case: a fintech with €400m of customer balances held as an EMI must keep all €400m in safeguarding accounts or low-risk assets, earning only what those assets pay. As a specialised bank, it could lend part of the balances, earn a lending margin, and offer insured deposits, but it would hold capital against its loans and accept bank-level supervision.
Value in a fintech acquisition
Specialised bank licences are rare and slow to obtain, which makes them among the most valuable regulated assets in European fintech M&A. A buyer acquiring one takes on bank-level change-in-control approval by the ECB, which assesses the acquirer's capital, business plan and fit-and-proper status. Due diligence must cover capital adequacy, the loan book, deposit concentration and any supervisory findings. Buyers seeking a digital banking licence route in the EU often compare a specialised bank acquisition with a full application, where timelines are measured in years.