Online banking services
FinTechs belonging to this area offer traditional banking services in a modern way, usually through online services or mobile applications as well as ancillary services – e.g. enabling customers to manage their giro- or custody-accounts online and in real time or offering e-wallet services. Keywords in this context are also API-Banking or Banking as a Service (BaaS)/ Bank as a Platform (BaaP).
API stands for application programming interface and is offered to access data banks and to extract and insert information. API-Banking consequently means the access to data banks of banks to offer new and innovative banking applications.
Through these services FinTechs offer services with new functions, e.g. enabling customers to manage their accounts online and in real time.
BaaS – Bank as a Service/BaaP – Bank as a Platform:
The API-based Bank as a Service platform has a full banking licence, but merely serves as the back end for standalone independent FinTechs, which “use” the licence and the back end of the bank to offer new financial services, launch additional financial products or expand into additional markets.
Attitude of the country towards online-banking services
The Romanian social and political climate is favorable towards online banking services, as Romania is currently trying to increase the percentage of its population having a bank account.
Obligations and requirements to provide online-banking services described above
API-Banking was not regulated in Romania until Directive (EU) no. 2015/2366 on payment services in the internal market (also known as the “PSD 2”) was transposed into Romanian legislation by Law no. 209/2019 on payment services. Starting from 13 December 2019, entities providing such services are qualified as third-party providers (“TPPs”) under the Romanian law and, as of this date, credit institutions operating in Romania are obliged to provide access to their payment infrastructure - application programming interfaces (“APIs”) and customer data to TPPs who can then develop their information and payment services and other financial services to bank customers. Such TPPs fall into two categories: Payment Initiation Service Providers (“PISPs”) and Account Information Service Providers (“AISPs”), both of which must be authorised by the National Bank of Romania (the “NBR”) prior to providing these services. However, it should be noted that there are two types of licenses, i.e., PISPs must apply for authorisation as a payment institution, while AISPs must apply for authorisation as an account information service provider.
We have not identified any Bank as a Service and Bank as a Platform entities active in Romania, however an entity providing such services would have to be registered as a credit institution. The minimum share capital requirement of a credit institution may vary and is calculated in accordance with the law on credit institutions and the regulations of the National Bank of Romania updated repeatedly based on test performed on the balance sheets of the banks. The licensing requirements are generally in line with the European Union banking legal framework.
Additional comments regarding the legal situation for online-banking services or what FinTech’s must be aware of in this business area
Market size for online-banking services and biggest companies in this business area
As of 2020, of all Romanian citizens using the internet, 11% use the internet for online banking. The low level of online banking is due to more than two out of five (42%) Romanian adults not having a bank account. Consequently, the potential for the growth of the users of online banking is high and credit institutions are currently offering clients ever more banking products online.
At the end of 2021, Romania had a total of 35 credit institutions, the biggest companies providing online banking services being the credit institutions which also have a physical presence across the country.
According to the payment institutions’ register held by NBR, as of 7 February 2022, there is only one entity who is licensed both as PISP and as AISP in Romania
We did not identify Bank as a Service or Bank as a Platform entities currently registered in Romania. However, such services may be performed by entities authorised in other member states of the European Union based on the passporting provisions.
Additional comments regarding the economic situation for online-banking services or what FinTech’s must be aware of in this business area