Four in 10 European payment firms have never used their EU passport

A FintechZoom analysis of the EBA’s PSD2 register finds Europe’s payments market split between firms that passport across nearly the entire bloc and firms that never leave home. The gap raises questions about how much real cross-border reach the EU’s payments passport actually delivers.

Why it matters: - Europe’s payments passport is meant to let one licence unlock 30 markets across the European Economic Area. - FintechZoom’s analysis suggests that promise is only partly real in practice. - Four in 10 authorised payment and e-money firms have never used the passport at all. - For firms that do passport, the pattern is often all-or-nothing: they notify into nearly every market, or none.

What happened: - FintechZoom reviewed the EBA PSD2 register in a snapshot taken on 22 September 2026. - The register covered 1,444 authorised payment and e-money institutions across the EEA. - 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 extremes.

The details: - Licensing location strongly tracked passport use. - In Ireland, Luxembourg, Cyprus, Lithuania, Latvia and Malta, the median licence holder reached 29 countries. - In Germany the median was one country. - In Spain the median was one country. - In Portugal the median was zero countries. - In Italy the median was zero countries. - 84% of Italian institutions had never notified anywhere. - Italy was the second most notified-into market in Europe, with 696 foreign institutions entering the market. - Italian firms, by contrast, almost never left the home market. - The same pattern showed up in Germany, Spain and Portugal. - New authorisations peaked at 272 in 2019, during PSD2 implementation. - New authorisations fell to 68 in 2025, a 75% decline from the peak.

Between the lines: - The analysis suggests the passport may be better at enabling market access on paper than at driving actual cross-border business. - FintechZoom measured physical presence using 323,860 agent records and 248 branch records. - 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 physical presence in any country they had passported into. - FintechZoom says the physical-presence figure is a floor, because agents are only used in some business models. - FintechZoom also says the notified figure is a ceiling, because notification does not equal trade. - For the median European payments firm, the number of markets genuinely served appears to sit somewhere between one and 29. - The European Commission last measured a similar gap in a 2013 impact study on the original Payment Services Directive, finding 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.

What’s next: - FintechZoom published the full report, register snapshot, checksum, extraction script and derived tables for replication or correction. - The public release gives regulators, investors and industry participants a new dataset to test whether passporting is translating into real cross-border expansion.

The bottom line: - Europe’s payments passport clearly exists, but the register suggests many firms either never use it or use it far less than the policy model assumes.