Four in Ten European Payment Firms Have Never Used Their EU Passport

FintechZoom’s analysis of the EBA PSD2 register finds a split European payments market, where many firms never notify beyond their home state while others passport across nearly the entire bloc. The findings raise questions about how widely the EU payments passport is actually used as policymakers move ahead with PSD3 and the Payment Services Regulation.

Why it matters: - Europe’s payments passport is meant to let one licence reach 30 countries. - FintechZoom’s analysis suggests that promise is uneven in practice, with many firms staying home and a smaller group operating almost everywhere. - The gap matters for fintech founders, regulators and investors because market access on paper does not always translate into real cross-border reach.

What happened: - FintechZoom analyzed the EBA PSD2 register in a snapshot taken on 22 September 2026. - The register covered 1,444 authorized payment and e-money institutions across the European Economic Area. - 565 institutions, or 39.1%, had never notified into another member state. - 474 institutions had notified into 29 or 30 member states, effectively the whole bloc. - Only 28% of institutions sat between those two extremes.

The details: - The pattern is close to binary: firms are either using the passport broadly or not using it at all. - In Ireland, Luxembourg, Cyprus, Lithuania, Latvia and Malta, the median licence holder reaches 29 countries. - In Germany, the median reaches one country. - In Spain, the median reaches one country. - In Portugal, the median reaches zero countries. - In Italy, the median reaches zero countries, and 84% of institutions have never notified anywhere. - Italy is the second most notified-into market in Europe, with 696 foreign institutions entering the country. - Italian firms, by contrast, almost never leave home markets. - Germany, Spain and Portugal show the same inversion: they are major destinations and weak origins for passported activity. - New authorizations peaked at 272 in 2019, during PSD2 implementation. - New authorizations fell to 68 in 2025, a 75% decline. - FintechZoom also examined 323,860 agent records and 248 branch records to gauge physical presence. - Among the 217 institutions with both passports and agent networks, the median had notified into 29 countries and had an agent or branch in one. - 31% of those institutions had no presence in any country they passported into. - 1,119 of the 1,444 institutions had no agents at all. - FintechZoom says the physical-presence figure is a floor, not a final measure, because agent networks reflect only certain business models. - FintechZoom also says the 29-country notification figure is a ceiling, because notification does not equal trade. - The European Commission’s last comparable measurement, in its 2013 impact study on the original Payment Services Directive, found that firms typically served no more than four EEA states outside their home country. - PSD3 and the Payment Services Regulation were agreed in 2026 on the assumption that the passport works. - The full report, the register snapshot with its checksum, the extraction script and all derived tables were published together for reproduction or correction. - The analysis is available with supporting materials from FintechZoom, a financial technology news and analysis publication covering payments, banking and markets.

Between the lines: - The data suggests the EU passport is strongest for a concentrated group of firms and weakly used by many others. - That could mean the single market works better for licensing than for actual distribution, especially outside a few passport-friendly jurisdictions. - The physical-presence data points to an even narrower reality than notification counts alone.

What’s next: - Policymakers working on PSD3 and the Payment Services Regulation are likely to face fresh scrutiny over whether passport rights are delivering practical cross-border competition. - The published dataset and methodology make it easier for others to test, refine or challenge the findings. - Further public measurement would be needed to narrow the gap between notified access and real operations.

The bottom line: - Europe’s payments passport appears widely available, but only unevenly used, and actual cross-border presence may be much smaller than the paperwork suggests.