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Corporate law Payment systems technology operator license

Taras Miroshnychenko

Head of practice

E-mail

miroshnychenko@prikhodko.com.ua

Phone numbers

Head of Corporate Law and Fintech Practice. Expert in the creation and reorganization of companies, support of M&A transactions, as well as legal support for opening and running a business in the EU, Asia, and North America.

Payment systems technology operator license

In the modern conditions of financial technology development and digital payment services, technological operators of payment services occupy an important place in the infrastructure of the payment market. Such entities ensure technical interaction between participants of payment systems, process payment information, and support the functioning of software and technical complexes used for the transfer of funds. In Ukraine, the activities of technological operators are subject to mandatory regulation by the National Bank of Ukraine, which requires obtaining the appropriate license and inclusion in the payment infrastructure register.

A technological operator license is issued by the National Bank of Ukraine based on the results of a comprehensive review of the applicant for compliance with the requirements of legislation in the field of payment services and financial monitoring. Obtaining such a license is a necessary prerequisite for the lawful provision of technological support for payment operations, including transaction processing, transmission of payment messages, operation of processing centers, and maintenance of electronic payment infrastructure.

Specialists of the company “Prikhodko and Partners” in this consultation discuss the practical aspects of the licensing process in the context of a technological operator.

It will also be useful: Obtaining a license from the NBU to provide financial services

Consultation with a lawyer on obtaining a license

Key stages of obtaining a license

The process of obtaining a technological operator license generally includes the following main stages:

Establishing a legal entity in accordance with the legislation of Ukraine.
Forming a transparent ownership structure with disclosure of ultimate beneficial owners.
Preparing a package of documents for the NBU, including founding documents, a description of the business model, and internal policies.
Developing internal operational regulations, including risk management and information security policies.
Confirming the company’s technical capability to perform processing and handle payment data.
Submitting documents to the National Bank of Ukraine and undergoing regulatory review.

Each of these stages requires proper legal and organizational preparation, as the NBU conducts a comprehensive assessment of the applicant’s activities.

Main requirements for the applicant

To obtain a technological operator license, a company must comply with a number of requirements established by the regulator. Among the key requirements are:

Organizational and corporate requirements:

registration of a legal entity in Ukraine;
transparent ownership structure;
disclosure of information about ultimate beneficial owners;
proper business reputation of owners and managers;
relevant professional experience of management.

Requirements for the internal management system:

availability of a risk management system;
internal compliance procedures;
information security policies;
regulations on protection and processing of payment data;
business continuity procedures.

Technological requirements:

availability of software and technical infrastructure;
use of reliable data transmission channels;
protection of payment information;
stability and scalability of technological solutions;
ability to integrate with payment systems and financial institutions.

Calculate the cost of legal services for obtaining a license

Potential risks when obtaining a license

In practice, the licensing process may be accompanied by certain legal and regulatory risks. The most common among them are:

non-compliance of the ownership structure with the regulator’s requirements;
insufficient detail in internal policies;
absence of a comprehensive risk management system;
insufficient description of the technical infrastructure;
non-compliance with information security standards;
comments from the NBU regarding the business model or financial plan.

If such shortcomings are identified, the National Bank may require revision of the documents or even leave the application without consideration, which leads to delays in the licensing process.

Given the complexity of regulatory requirements and potential risks, engaging the lawyers of “Prikhodko and Partners” can significantly facilitate the licensing procedure and increase your chances of obtaining authorization as a technological operator.

Comprehensive legal support from “Prikhodko and Partners” ensures:

structuring the company’s corporate model;
analysis of the business model’s compliance with NBU requirements;
preparation of a complete package of documents for submission to the regulator;
development of internal policies and procedures;
legal support in communication with the NBU;
assistance during the regulator’s review of documents.

Obtaining a technological operator license is a complex and multi-level process that combines corporate, regulatory, and technological aspects of a company’s activities. Proper preparation of documents, correct structuring of the business model, and compliance with the requirements of the National Bank of Ukraine are key prerequisites for successfully completing the licensing procedure.

Engaging professional support from the law firm “Prikhodko and Partners” allows not only to accelerate the licensing process but also to minimize regulatory risks, ensure compliance of the company’s activities with legal requirements, and create a reliable legal foundation for business development in the field of financial technologies.

Calculate the cost of services

1 question

Do you already have a registered company?

Yes

2 question

Does your company have an already established or planned technological infrastructure (processing platform, software, server solutions) for processing payment transactions?

Payment systems technology operator license

Key stages of obtaining a license

Main requirements for the applicant

Potential risks when obtaining a license

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