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Fintech · Financial Services

Groupe NovaPay

“Obtaining the EMI license in 14 months — 3 times faster than average.”

Durée : 14 mois Équipe : 3 consultants 2022 – 2024 Paris
14 mois
to obtain the European EMI license
01

Context & Challenges

Founded in 2019, the NovaPay platform had won over 40,000 corporate clients thanks to a seamless B2B payment experience and an API integration highly valued by software vendors. However, its growth was hitting a structural obstacle: without an Electronic Money Institution (EMI) license, NovaPay could neither issue electronic money for its own account nor offer payment accounts directly to businesses. It had to rely on a banking partner whose pricing and technical conditions limited its competitiveness.

The pressure intensified further after signing an LOI (letter of intent) with a paneuropean distributor that conditioned the finalization of the contract on obtaining regulatory approval. The stakes were therefore not just strategic — they were contractual and urgent.

“We felt like we were building a highway without a license to drive on it. The license was not just one goal among others — it was the lock blocking everything else.” — NovaPay Executive Management.

02

Our Diagnostic

Upon our arrival, we conducted a complete three-week diagnostic. Two major findings emerged: first, the existing documentation suffered from significant gaps in governance and risk mapping — the two subjects on which the ACPR is most demanding. Second, the executive teams had never been prepared for a regulatory interview and underestimated the level of detail expected.

We also identified that the application could be filed earlier than expected, provided priorities were reorganized. The natural tendency in this type of project is to want to finalize everything before filing — an approach that mechanically leads to delays of 2 to 3 years. We advocated for an iterative approach.

03

Approach & Methodology

Our intervention was structured around four complementary pillars. First, the structuring of the regulatory application: a complete redesign of the 5-year business plan in the format expected by the ACPR, drafting the activity program and the operational procedures manual.

In parallel, we worked on the AML/KYC governance: laundering risk mapping, drafting client vigilance policy, and setting up the compliance function, including the recruitment of the Compliance Officer (RCSI).

The third pillar focused on executive preparation: two rounds of mock hearings with a former licensing official, ensuring the founders mastered the most technical as well as unexpected questions.

Finally, we managed the dialogue with the supervisor: coordinating exchanges with ACPR officers, anticipating requests for additional information, and managing the review schedule.

04

Mission Roadmap

Months 1 – 2
Diagnostic & roadmap
Audit of the existing state, identification of regulatory gaps, and validation of the iterative filing strategy with management.
Months 3 – 7
Building the application
Drafting the activity program, risk mapping, and AML/KYC manual. Recruiting and onboarding the RCSI.
Month 8
ACPR application filing
Official filing, opening the review phase. First contact with the assigned supervising officers.
Months 9 – 13
Review & additions
Responding to 47 follow-up questions, mock hearings, and finalization of the business continuity plan.
Month 14
Obtaining the EMI license
Positive notification from the ACPR. Triggering the passporting process to 5 EEA countries.
05

Results Achieved

14 mois
Total time to obtain (vs 36 – 42 months on average)
6 pays
Covered by the license via EEA passporting
+€ 8 M
Distributor contract unlocked within 3 months of licensing

Beyond the figures, obtaining the license radically transformed NovaPay's credibility with banking partners and key accounts. The company was able to raise a Series A a few months after the positive notification, at a valuation significantly higher than it would have obtained without approval.

06

Scope Exclusions

Our intervention deliberately excluded several topics that fell under other areas of expertise or internal decisions at NovaPay:

Selection and implementation of transaction monitoring software (IT topic entrusted to a specialized vendor).
Negotiating the terms of the European distributor contract (managed by NovaPay's external legal counsel).
Series A fundraising (conducted in parallel but independently of our mission).
Recruitment of the entire compliance team post-licensing (only the RCSI was recruited within our scope).
Any licensing applications in non-EEA jurisdictions (UK, Switzerland) which constitute a subsequent phase.

“Meridian Consulting made the difference on two points: the clarity of the roadmap and the ability to prepare us for the hearings. We would have taken 3 years without them — and we might not have survived that wait.”

Alexandre Krömer — CEO, NovaPay Group

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