# Finom — Multi-Country EMI Business Account: A Case Study **Type:** [[Electronic Money Institution]] (EMI) · [[Business Account]] · [[BaaS]] **Archetype:** [[eu-sme-fintech-market-map|Integrated SME Finance]] **Trade name:** Finom (operated by PNL Fintech BV) **Licensed entity:** Finom Payments BV · KVK 78680751 **Regulator:** [[DNB]] (De Nederlandsche Bank) · Licence R180074 **Incorporated:** Amsterdam, Netherlands (Jachthavenweg 109h, 1081KM) **Founded:** 2019 **Founders:** Andrey Petrov, Oleg Laguta, Konstantin Stiskin, Yakov Novikov **Investors:** Target Global, General Catalyst, FJ Labs · $54M raised (Feb 2024) **Scale:** 200,000+ users across Europe **Markets:** Germany · France · Italy · Netherlands · Belgium · Spain · Poland · Portugal · Austria · Ireland + EU --- Finom is a multi-country EMI built on a country-by-country licensed banking partner model: instead of one central BaaS provider, it uses **[[Solaris Bank]]** in Germany and Italy, **[[Treezor]]** in France, and its own Dutch EMI licence ([[DNB]]) for the Netherlands and EU. This gives it genuine local IBANs per country — a German IBAN from a BaFin-licensed bank, a French IBAN from an ACPR-licensed EMI — rather than a single IBAN ported across borders. The result is a more locally embedded product than most pan-European EMIs, but a significantly more complex infrastructure to operate and maintain. ## The Infrastructure Stack ``` Customer (SME / Freelancer / Company in formation) ↓ Finom (product layer — app, dashboard, invoicing, accounting) ↓ ↓ ↓ Germany / Italy France Netherlands / EU Solaris Bank Treezor Finom Payments BV (BaFin-licensed (ACPR-licensed (DNB-licensed EMI bank → German / EMI → French R180074) Italian IBAN) IBAN) ↓ BNP Paribas ← safeguarding / fund custody Aksys Global Markets Europe Ltd ← interest account yield Visa ← card network ``` ### [[Solaris Bank]] Solaris (now Solaris SE) is a German BaFin-licensed banking-as-a-service provider. In Germany and Italy, Finom's business accounts operate on Solaris infrastructure, which gives customers a **genuine German IBAN** (DE prefix) and **Italian IBAN** (IT prefix) issued under a full banking licence. This matters for credibility with traditional German SMEs and suppliers who may be wary of non-German IBANs. Crucially, Solaris is a full bank — not an EMI — which means German Finom accounts qualify for **deposit insurance up to €100,000** under the German deposit guarantee scheme. This is a material safety advantage over pure EMI structures (including wamo/Banking Circle), where safeguarding provides protection but not deposit insurance per se. ### [[Treezor]] Treezor is a French [[Payment Institution]] (PI) and EMI licensed by ACPR. In France, Finom uses Treezor to issue French IBANs (FR prefix) and process payments under French regulatory cover. Treezor is owned by Société Générale. ### Finom Payments BV (DNB licence) For the Netherlands and broader EU expansion, Finom operates its own EMI licence issued by the [[DNB]] (De Nederlandsche Bank) under registration R180074. This gives Finom direct regulatory standing in the Netherlands and the ability to passport services across the EEA without relying on a banking partner. ### Safeguarding: BNP Paribas + Safeguarding Foundation Finom holds customer funds with **[[BNP Paribas]]** and manages them through a **separate Safeguarding Foundation** supervised by the DNB. This structure — a dedicated foundation ring-fenced from operating entities — is one of the stronger safeguarding models in the EMI space, providing an additional layer of insolvency protection beyond standard Article 10 EMD2 ring-fencing. ### Interest Account: [[Aksys Global Markets Europe Ltd]] Finom's interest-bearing "Interest Wallet" is **not** provided by Solaris or Finom Payments — it is provided by **Aksys Global Markets Europe Ltd**, a separate regulated firm. This is significant: the yield product is a distinct regulatory relationship, not a feature of the business account itself. Yields currently advertised: 5% p.a. for 5 months (promo), then standard rates of 0.25–2% depending on plan. ## The Product Universe ### Business Account - German IBAN in 24 hours (via Solaris Bank) - French IBAN (via Treezor), Italian IBAN (via Solaris), Dutch IBAN (via Finom Payments BV) - Fully online onboarding via smartphone or desktop - Supports **companies in formation** (GmbH i.G., UG i.G.) — can open account before company registration completes, deposit share capital (Stammkapital), obtain bank statements for notary ### Payments | Rail | Coverage | Notes | |---|---|---| | SEPA transfers | Euro zone | Free monthly volume by plan (€2.5k–€100k+) | | SEPA Direct Debit | EU | Mandate management included | | International payments | 150+ countries, 17+ currencies | 0.20–1% fee by plan; 0% on Grow plan | | Bulk / scheduled | — | Available from Basic plan | No explicit [[SCT Inst]] (instant payments) visible — standard SCT only. ### Cards - Free Visa physical + virtual cards by plan (1–3 physical, 1–20 virtual per user) - **Prime Card** (€9.99–€14.99/month): higher cashback, global perks - **Metal Card** (€29.99/month, 1 included on Grow plan): premium tier - Apple Pay, Google Pay, PayPal supported - Up to €5,000/month ATM withdrawal (free in Germany/Italy) - **Cashback**: 0% (Solo) → 1% (Basic) → 3% (Smart) → 4% (Core) → unlimited up to 1% (Grow) ### E-Invoicing This is Finom's most differentiated product for the German market. It supports both: - **[[XRechnung]]** — the structured XML invoice format mandated for B2G (business-to-government) invoicing in Germany, and now progressively for B2B from 2025–2027 under the German e-invoicing mandate - **[[ZUGFeRD]]** — a hybrid format (PDF + embedded XML) that satisfies the German e-invoicing requirement while remaining human-readable Finom positioned this product ahead of Germany's B2B e-invoicing mandate enforcement (2025 for receiving, 2027 for issuing), giving it a first-mover advantage among challenger banks for German SME invoicing compliance. Claimed impact: customers paid 20%+ faster, 60-second invoice creation, automated payment notifications, one-click payment links. ### Accounting Integrations 50+ accounting and bookkeeping tool integrations including: - **[[DATEV]]** — the dominant accounting software in Germany; critical for working with German Steuerberater (tax advisors). This integration alone differentiates Finom significantly for German SMEs. - **[[Xero]]** — international accounting platform - **Sorted** — expense categorisation - Receipt scanning (photo → attached bill) - Automated VAT extraction - **AI Accounting Agent** — launched 2025, AI-assisted transaction categorisation and accounting automation ### Multibanking Finom offers **multibanking** — connecting other bank accounts (traditional and digital) into the Finom dashboard for a unified view. In Italy, this is powered by **[[Klarna]]** (Klarna's open banking aggregation layer). This is an [[AISP]] (Account Information Service Provider) function under [[PSD2]], allowing read-only access to external accounts. ### Interest Account - Yield product provided by **Aksys Global Markets Europe Ltd** (separate regulatory entity) - Promo rate: 5% p.a. for first 5 months on all plans - Standard rates after promo: 0.25% (Solo) → 1% (Basic) → 1.25% (Smart) → 1.45% (Core) → 1.75% (Pro) → 2% (Grow) - Cash held separately from operating account; not SEPA-transferable in real time ## Pricing Model (Germany, Growing Businesses — monthly) | Plan | Monthly | Users | Cashback | Free SEPA vol | Virtual cards/user | |---|---|---|---|---|---| | Solo | €0 | 1 | 0% | €2,500 | 1 | | Basic | €8 | 2 | 1% | €25,000 | 3 | | Smart | €19 | — | 3% | €50,000 | 10 | | Core | €38 | — | 4% | €100,000 | 20 | | Pro (SME) | €149 | — | up to 0.5% | Unlimited (new) | Unlimited | | Grow (SME) | €339 | — | up to 1% | Unlimited | Unlimited | Annual billing gives ~15–20% discount. 30-day trial on paid plans. ## Regulatory Framework ### Dutch EMI Licence (Finom Payments BV) Finom's own EMI licence is issued by the **[[DNB]]** (De Nederlandsche Bank). The Netherlands has emerged as a preferred jurisdiction for EU fintech licensing due to its well-established regulatory infrastructure and DNB's track record with payment institutions. The EMI licence provides EEA passporting rights across all 36 SEPA member states. ### Country-Level Banking Partners The Solaris Bank (Germany/Italy) and Treezor (France) relationships are **agent banking arrangements**, not sub-licences. Finom acts as a payment services agent of the local licensed entity in each country, distributing those services under the local bank's authorisation. This is a common structure but creates regulatory complexity: Finom is simultaneously a licensed EMI in the Netherlands and a regulated agent in Germany and France. ### [[EMD2]] — Electronic Money Directive 2 Same framework as wamo. Customer funds safeguarded via a dedicated foundation under DNB supervision, with custody at BNP Paribas. ### [[PSD2]] Obligations - Open banking API for AISP/PISP access (powers multibanking feature) - SCA on payment initiation (passkeys + 3D Secure) - [[DORA]] compliance (ICT risk management) required from January 2025 ### German E-Invoicing Mandate Germany transposed the EU e-invoicing directive into national law with a phased B2B e-invoicing mandate: - From **1 January 2025**: all German businesses must be able to **receive** e-invoices in XRechnung/ZUGFeRD format - From **1 January 2027**: all German businesses above €800k turnover must **send** structured e-invoices - From **1 January 2028**: universal B2B e-invoicing mandatory Finom's XRechnung/ZUGFeRD support makes it one of few challenger banks directly addressing this compliance requirement. ## Finom vs. wamo: Key Structural Differences | Dimension | Finom | wamo | |---|---|---| | Regulator | DNB (Netherlands) | FIN-FSA (Finland) | | Banking partner | Solaris (DE/IT), Treezor (FR) | Banking Circle | | Deposit insurance | Yes (via Solaris, up to €100k in DE/IT) | No (EMI safeguarding only) | | IBAN origin | Genuinely local (DE, FR, IT, NL) | EU IBAN via Banking Circle | | Cashback | Up to 4% (Core) | None | | Interest account | Yes (via Aksys) | None | | E-invoicing | XRechnung + ZUGFeRD | Not offered | | POS terminal | No | Yes | | DATEV integration | Yes | No | | Multibanking | Yes (PSD2 AISP) | No | | Users | 200,000+ | 13,000–15,000 | | Price floor | €0 (Solo) | €0 (Freemium) | | Partner program | Not prominently advertised | Yes (up to €270/referral) | | International payments | 150+ countries, 17 currencies | 22 currencies (FX) | ## EU Market Entry Angles ### 1. German Market: E-Invoicing Compliance as the Hook For any business operating in Germany (especially B2B), the XRechnung/ZUGFeRD compliance angle is the strongest reason to consider Finom over alternatives. From 2025, German businesses must be able to receive structured e-invoices; from 2027, must send them. Finom is one of the few banking products that directly handles this in the account layer, avoiding a separate e-invoicing tool. Combined with the DATEV integration (connecting to the dominant German tax advisor software ecosystem), Finom becomes genuinely embedded in the German SME accounting workflow — a deep switching cost. ### 2. Companies in Formation Finom explicitly supports GmbH i.G. and UG i.G. account opening — businesses can bank and deposit share capital during the Handelsregister registration process. This is a specific German-market product feature that most pan-European EMIs don't offer, and it creates customer acquisition at company formation — the earliest possible point in a business's lifecycle. ### 3. Multi-Country Presence For a cross-border EU business with operations in Germany, France, and Italy, Finom can provide local IBANs in all three countries from a single app. The alternative (opening three separate accounts with three institutions) is far more operationally complex. This is a genuine structural advantage that wamo cannot currently match. ### 4. Cashback as P&L Lever The cashback proposition (up to 4% on Core) is real and meaningful for businesses with significant card spend. At 3–4% cashback on all card transactions, a business spending €10,000/month on cards earns €300–400/month back — enough to offset the plan cost on Core (€38/month) many times over. Most traditional banks offer 0%. ### 5. Interest Account for Treasury Optimisation For SMEs holding cash buffers, the 5% promo rate (first 5 months) and then 1–2% standard rate on idle balances turns the business account into a lightweight treasury tool. The Aksys relationship means the yield is provided outside the EMI envelope — worth understanding the counterparty risk profile of Aksys if relying on this for material cash holdings. ## What Finom Doesn't Yet Have | Gap | Why It Matters | |---|---| | No SCT Inst | EU mandatory by Jan 2026 for Eurozone PSPs. Solaris Bank in Germany may carry this obligation. | | No VOP | Mandatory for Eurozone PSPs from Oct 2025. | | No POS terminal | Finom is app/desktop only for payments; no in-person payment acceptance. | | No visible partner program | No affiliate/referral structure comparable to wamo's €270/referral program. | | SWIFT not available | Only SEPA and their international payment corridors; no raw SWIFT wires. | | Aksys counterparty risk | Interest account is with a separate firm; the creditworthiness of Aksys is a separate risk to assess. | --- ## Connected Concepts - [[Electronic Money Institution]] — Finom's licence type in the Netherlands (Finom Payments BV via DNB) - [[EMD2]] — the EU legislative framework under which Finom operates - [[DNB]] — De Nederlandsche Bank; Finom's primary regulator (licence R180074) - [[Solaris Bank]] — BaFin-licensed bank providing German and Italian IBAN infrastructure for Finom - [[Treezor]] — ACPR-licensed French EMI providing French IBAN infrastructure; owned by Société Générale - [[BNP Paribas]] — custodian for Finom customer funds (safeguarding) - [[BaaS]] — Banking-as-a-Service; Solaris and Treezor are BaaS providers in Finom's stack - [[Safeguarding]] — EMD2 Art. 10 ring-fencing; Finom uses a dedicated foundation supervised by DNB - [[IBAN]] — local IBANs (DE, FR, IT, NL) are Finom's key structural differentiator - [[Visa]] — card network for all Finom Visa debit cards - [[PSD2]] — framework governing Finom's payment services, open banking, and SCA obligations - [[AISP]] — Account Information Service Provider; Finom's multibanking feature uses AISP access - [[DORA]] — Digital Operational Resilience Act; applicable to Finom from January 2025 - [[SCA]] — Strong Customer Authentication; implemented via passkeys and 3D Secure - [[XRechnung]] — German structured e-invoice format (XML); Finom supports natively - [[ZUGFeRD]] — German hybrid e-invoice format (PDF + embedded XML); Finom supports natively - [[DATEV]] — dominant German accounting software; Finom integration is critical for German SME market - [[SCT Inst]] — SEPA Instant; not visibly offered by Finom despite EU mandate - [[VOP]] — Verification of Payee; EU-mandatory Oct 2025; status on Finom unknown - [[Deposit Insurance]] — available on Finom German/Italian accounts via Solaris Bank (up to €100k) - [[wamo-emi-case-study]] — comparable EMI case study; see comparison table above - [[Klarna]] — powers Finom's multibanking open banking aggregation layer in Italy - [[SEPA Credit Transfer]] — primary payment rail used by Finom for euro transfers - [[Open Banking]] — Finom participates as both AISP (multibanking) and a PSD2-regulated PSP - [[eu-sme-fintech-market-map]] — full EU SME fintech market map; Finom sits in the Integrated SME Finance archetype --- *FintechGraphs · Last updated: June 2026 · [[about|Who we are]]*