Open Banking: PISP and AISP Registration in Cyprus

PSD2 introduced open banking to the EU, creating a legal right for licensed third-party providers to access customer payment account data and initiate payments on a customer’s behalf, subject to consent. Cyprus follows the same framework, offering two lighter-touch registration routes for firms focused purely on these services.

Payment Initiation Service Providers (PISPs)

A PISP initiates a payment transaction at the request of the customer from an account held with another payment service provider, typically a bank. PISPs never hold customer funds themselves, which is reflected in a lighter capital and prudential regime compared to firms that execute payments directly.

Account Information Service Providers (AISPs)

An AISP provides consolidated information on one or more payment accounts held by the customer with other providers, commonly used in personal finance management apps, lending decision tools and accounting software integrations. AISPs are subject to registration rather than full authorisation, given the lower risk profile of the activity.

Access to Account Data

Account-servicing payment service providers, such as banks, are required to give PISPs and AISPs access to customer accounts through dedicated interfaces, generally APIs, enabling secure access without requiring customers to share their banking credentials directly with the third-party provider.

Professional Indemnity Insurance

PISPs and AISPs are required to hold professional indemnity insurance, or a comparable guarantee, to cover their liabilities in connection with the services provided, given they do not hold client funds and therefore are not subject to the same safeguarding regime as full payment institutions.

Is This the Right Route for You?

Firms building products purely around account data or payment initiation, without ever taking custody of client funds, should assess whether the PISP or AISP registration route, rather than a full payment institution licence, matches their business model and offers a faster path to market.

Enalian advises payment institutions, e-money institutions and fintech businesses on licensing, authorisation and ongoing regulatory compliance in Cyprus. If you are exploring a PSP or EMI licence, or need support with an existing authorisation, our team can help. Get in touch with our team to discuss your specific circumstances.

This article is provided for general informational purposes only and does not constitute legal, tax or regulatory advice. Regulatory requirements are subject to change; readers should seek specific advice on their circumstances before taking action.