Banking as a Service: who is behind your fintech app?

You open an app to check your account. Its logo is familiar; the institution named in the contract may be less so. Banking as a Service explains this separation between the interface you use and the financial service provider.

What is Banking as a Service?

Banking as a Service lets a company integrate a financial institution’s services into its own product. Accounts, cards or payments become available through a technical interface. The provider’s authorization does not transfer to the partner: their roles and obligations remain distinct.

Swan’s documentation gives a concrete example. A partner may present services under its brand, while Swan remains the payment service provider. Contract disclosures and the partner’s status must reflect that division. Integrating an API does not make a company a bank.

Who are Treezor, Swan and Mangopay?

Treezor offers a historical example. Founded in Paris in 2014, it supported the early development of Qonto and Shine. Société Générale announced its acquisition in 2018. Exclusive negotiations with Shares were announced in January 2026; announced talks do not establish that a sale was completed.

Swan, founded in 2019 in the eFounders startup studio, is the API-first generation: software companies embed accounts, cards and IBANs directly into their product, so an accounting tool like Pennylane can hold money without ever showing the user a separate bank. It holds a French e-money license, raised 37 million euros in September 2023 and 42 million in January 2025, and reports more than 1.5 billion euros in monthly transactions across 30 countries.

Mangopay, spun out of the gift-pot service Leetchi in 2013 and licensed in Luxembourg, specializes in marketplaces: it holds and routes money between buyers and sellers on platforms like Vinted, Leboncoin and Chrono24. Crédit Mutuel Arkéa bought it in 2015; the private equity firm Advent International took a majority stake in 2022, injecting 75 million euros of fresh capital.

Where is your money, actually?

Read how funds are treated in the provider’s contract. A payment account, an e-money balance and a bank deposit should not be presented as interchangeable. Applicable protections and procedures after a failure depend on that status and the institution involved.

Eligibility is another filter. A provider may accept some sectors and exclude others; one offer does not describe the whole BaaS market. A company must establish whether its specific activity, customers and flows fit the proposed partner’s conditions.

What happens when a BaaS provider fails?

The last three years supplied real answers. In April 2024, France’s ACPR sanctions committee issued Treezor a reprimand and a 1 million euro fine over anti-money-laundering failures found in a 2021 inspection: risk profiles that classified 99.8% of clients as low-risk, weak transaction monitoring, and suspicious-activity reports filed late or not at all. The regulator noted the significant remediation Treezor had undertaken since.

Germany’s Solaris, once Europe’s BaaS flagship, spent years under reinforced supervision by the regulator BaFin, which appointed a special monitor and restricted new partnerships. In February 2025 an emergency 140 million euro round made Japan’s SBI Group its majority shareholder, and in June 2025 BaFin fined it again, 500,000 euros, for repeatedly exceeding large-exposure limits. In the UK, Railsr went through a rescue sale in March 2023. The pattern is consistent: the failure mode of BaaS is rarely a lost database, it is compliance debt coming due.

These cases show that several companies can participate in one customer journey. During an incident, identify who maintains balances, who can execute payments and who handles complaints. A protection mechanism alone does not guarantee immediate service continuity.

Where is the sector heading?

Compare offers through available services and contractual commitments: coverage, timing, fees, incident handling and the ability to change providers. A new partnership or reform announcement does not establish that your own journey has changed.

For users, the practical lesson is simpler and worth keeping: the brand on the app and the institution holding the money are often two different companies, and knowing who actually holds the license is the single most useful question you can ask of any finance app.

The logo helps you recognize the service. The contract identifies who is responsible for it.

Following the journey between a wallet and a bank account

Sources

Additional source checked on October 10, 2026

• EUR-Lex, Payment Services Directive (PSD2): safeguarding, agents and passporting.
• EUR-Lex, first E-Money Directive (2000/46/EC): the e-money institution and its 1 million euro initial capital.
• EUR-Lex, E-Money Directive (EMD2): the e-money institution license and fund protection.
• ACPR, sanctions committee decision on Treezor (April 2024).
• ACPR, full sanctions committee decision on Treezor, including the 99.8% low-risk profiling (April 2024).
• Shares, exclusive negotiations to acquire Treezor from Société Générale (January 29, 2026).
• Bpifrance, Swan’s 42 million euro Series B extension and business figures (January 30, 2025).
• Maddyness, Swan’s 37 million euro round of September 2023 and 42 million euro round of January 2025 (January 30, 2025).
• Mangopay, Advent International majority investment (April 7, 2022).
• European Central Bank, Instant Payments Regulation deadlines and payment-system access.
• BaFin, fine against Solaris SE (June 13, 2025).
• CNBC, the Synapse bankruptcy and frozen customer funds (June 2024).
• Swan, public documentation on restricted activities.