Multipass is a financial services provider offering global business accounts, multi-currency payments, and cross-border transaction solutions.
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Neobank Platform
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UK and EU · EMI
Launch a neobank now, move to your own EMI licence later
An EMI authorisation takes months, often more than a year. Many founders do not wait: they launch under a partner that already holds a licence, learn from real customers, and file their own application in parallel. The hard part comes at the end, when customers move from the partner's licence to yours. This page is about planning that move from day one.
- Go live under a partner's licence
- Your own FCA or EU EMI application
- Same apps and back office after the switch
- A migration plan your regulator can read
Case Studies
Paysend & Crassula - a banking solution for international companies
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LuxPay is at the forefront of providing advanced financial services, designed to meet the needs of modern businesses and consumers alike.
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Wickie offers secure and scalable fiat and cryptocurrency payment solutions, providing users with digital wallets and seamless financial services across multiple platforms.
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What you can run before and after your own licence
Phase 1: a branded app on a partner's licence
Customers open accounts in your app, but the e-money is issued by the partner EMI. You work as its registered agent or distributor, or as a programme manager under its BaaS contract.
Phase 2: the application file
While the product runs, you prepare the FCA or EU file. Your live platform, real volumes and real complaints data make the business plan far more credible than projections alone.
Phase 3: your own accounts and rails
After authorisation you connect your own safeguarding account and payment rails to the platform, so new customers open accounts under your licence from the first day.
Phase 4: moving the existing book
Existing customers are moved in waves: consent collected in the app, KYC refreshed where your MLRO requires it, balances redeemed by the partner and credited to accounts under your licence.
Multi-currency accounts and FX
Accounts in several currencies with exchange at rates set in your price lists, available in both phases because the ledger and pricing stay on the same platform.
Business customers
Company onboarding with its own questionnaire, several users per account and batch payments. Business clients need the same migration consent as consumers, signed by an authorised person.
What this licence does not cover
- Issuing e-money in your own name before authorisation. Until then the partner is the issuer, and your app and terms must say so.
- Moving customers to your licence by changing the terms quietly. The customer's contract and balance sit with the partner, so leaving its licence means a new contract with you.
- Keeping the partner's account numbers or card BIN by default. Whether they can move depends on the partner and its bank or issuer, so ask before you sign.
What the regulator asks about your IT
Each requirement, what the platform gives you for it and who owns it after launch.
Configurable terms, notices and app copy per phase, so customers see the partner's name before the switch and yours after it.
You and your lawyersIn-app notices and an onboarding questionnaire step that records each customer's answer with a timestamp in their client record.
You, with the partner's agreementExisting identity data and documents in the client record, plus fresh checks through your connected verification provider where your MLRO wants them.
Your MLROClient-level balances on the ledger, exported at the cut-off date so both firms can reconcile what leaves one safeguarding account and lands in the other.
Your finance team and the partnerNew accounts and virtual IBANs opened through your own account provider, with the old and new details shown side by side in the app during the changeover.
You and your banking partnerCard issuing through the API with the issuer you contract directly, so new cards can be ordered for migrated customers and old ones frozen on a date you choose.
You and your card issuerClient records and transaction history stay in the platform you use in both phases. Who controls which data, and on what legal basis it moves, is set in your contract with the partner.
Your DPO and the partnerTechnical input for your migration plan: dates, customer counts, account and card changes, fall-back steps.
You and the partner, each to its own regulator
Payment rails and providers
Rails your customers can use
Faster PaymentsBacsCHAPSSEPASEPA InstantSWIFT
ClearBank
For the UK route: a clearing bank that offers newly authorised EMIs safeguarding accounts, virtual accounts and direct Faster Payments, Bacs and CHAPS access.
Clear Junction
For the UK route: an FCA-authorised EMI (FRN 900684) that gives regulated firms GBP and EUR accounts and named virtual IBANs.
24/7
real-time processing, no batch window
60+
payment and provider integrations connected
150+
companies run on Crassula
15+
languages the platform speaks
Dates to plan around
Rules that change what you have to build, in the order they apply.
17 Jan 2025
DORA applies to EU EMIs. Your own application must show an ICT risk framework and list your technology providers, the platform included.
7 May 2026
CASS 15 took effect in the UK. If you migrate to an FCA licence, daily safeguarding reconciliation starts on the day the first customer balance moves.
9 Apr 2027
EMIs in the euro area must be able to send and receive SEPA Instant payments. Plan your EU rails with this date in mind.
10 Jul 2027
The EU Anti-Money Laundering Regulation applies. A migration that ends after this date should run its KYC refresh to the new rules.
Applying for your own EMI licence? Name us in the file.
A regulator assessing a firm that already trades under a partner will ask two questions: what runs the business today, and how customers will move. We help you answer the technical side of both.
01
A platform you can demonstrate
A configured environment to show the regulator, not slides. Often it is the same product your customers already use.
02
The technical part of your application, prepared
IT systems, outsourcing, security, business continuity and, for EU regulators, the ICT risk and DORA sections, plus the technical steps of your migration plan.
03
Providers lined up
For the UK, safeguarding and rails through partners including ClearBank and Clear Junction. For the EU, banking, safeguarding and KYC providers from our network, matched to your licence.
Crassula provides technology and documentation support. We do not provide legal or regulatory advice and cannot guarantee the outcome of an application.
A migration in practice
A Berlin team launches a spending account for nurses as the agent of an EMI that already holds a licence. Within a year they have 40,000 customers and file their own EMI application, naming Crassula as their technology provider and attaching a migration plan to the file.
After authorisation they open their own safeguarding account and connect it to the platform. New sign-ups go straight to the new licence. Existing customers get an in-app notice, accept the new terms with their passcode, and move in weekly batches. On each cut-off date the partner redeems the balances, the money lands in the new safeguarding account and new cards are ordered. Customers who do not respond stay with the partner until their account is closed under the partner's notice terms.
For the licence itself, read our EMI guide or, for the UK, the UK EMI guide and the guide to UK agent registration.
Read the licence guides
FAQ
Yes, if the app ran on Crassula from the start. The apps, back office, ledger and pricing stay the same. What changes is the legal entity behind the accounts, the safeguarding account, the banking and card providers, and the terms customers accept.
In most cases, yes. Before authorisation the e-money is issued by the partner, so moving to your licence means the partner redeems the balance and you issue new e-money under a new contract. Ask your lawyers how consent, notice and dormant accounts should be handled. In the UK, a provider can end an open-ended framework contract only with at least two months' notice.
Not always. UK rules let you rely on another regulated firm's checks, but you stay liable and must be able to get the identity data and documents straight away. Many MLROs prefer a refresh for higher-risk customers and reliance for the rest. Agree access to the partner's records in your contract early.
Usually not. Account details come from the partner's bank, not from the app, so you get new details from your own account provider. Plan for customers updating their salary details and direct debits, and keep both sets of details visible in the app for a while.
The FCA must decide on a complete EMI application within three months, and EU regulators work to the same statutory period, but questions and missing documents often push real timelines far beyond that. Migration then takes weeks to months depending on customer numbers and how quickly customers respond.
PSD3 will repeal the E-Money Directive and bring e-money into the new payments framework. Firms already authorised get a transitional period to show they meet the new rules. If you file now, expect a second look later. Our PSD3 and PSR guide covers the details.
Staying with a partner long term is a valid model. Our BaaS guide explains it. This page is for teams that know they want their own licence and want to avoid rebuilding everything when they get it. Request a demo to map your route.
