A Georgian payments company serving several million customers at home wanted European users, which meant an electronic money institution licence.
Its board had been advised to budget two years. The obstacle was definitional. The product had grown up outside European regulatory categories and sat across the boundary between two of them, so the opening question from any supervisor would be what, precisely, this business was. Applications that raise that question tend to spend a year answering it.
Where to apply came before how. We compared candidate member states on supervisory temperament and published processing times, weighing how each had handled firms with comparable models. Austria came out ahead, partly because the Finanzmarktaufsicht engages substantively with applicants before filing and partly because the client's Georgian shareholding structure raised fewer questions here than in the alternatives.
Then came the categorisation argument. We built the case for how the model should be classified under European rules and tested it with the FMA through pre-application dialogue, a route open in most member states and used by few applicants from outside the EU.
That exchange reshaped the application before it existed. The client rebuilt its safeguarding arrangements and adjusted its governance to fit the category it was applying under.
The licence was granted eleven months after submission, against a board expectation of two years. The pre-application work removed the two issues most likely to have caused a substantive review round. The client passported into three further member states in the following year and has retained us on the supervisory relationship.