Offer your customers added value on the basis of account data, also under PSD2.

The figo RegShield makes it possible to continue your service – under certain circumstances – without your own licence or registration with the Financial Supervisory Authority despite PSD2 or the National Payments Supervision Act, so you can focus on the essentials – providing the best service to your customers. Put your resources where they bring you the most value and leave the regulatory compliance to us.

Who is this for?

Anyone who theoretically has to apply for a registration/licence as a account information service or payment initiation service in order to continue offering their services since the national implementation of PSD2 in January 2018. The obligation arises as soon as you wish to offer your service. Important: In the final analysis, BaFin will decide on registration and licensing requirements on an individual basis or a possible integration of figo RegShield!


The figo RegShield is the right choice for you.

If you access the payment account data of your customers (consumers or companies) via the online banking credentials and/or want to enable your customers to initiate payments from within your application!

Since 2018, the BaFin requires for precisely these cases the registration as an account information service provider (AISP) or a licence as a payment initiation service provider (PISP).

The figo RegShield saves you from the enormous effort that comes along with your own registration or licence!

The figo RegShield offers you a strong partner with extensive PSD2 compliance expertise and an entire team that ensures that your service does not require its own BaFin registration or licence.

How does it work? Since August 16th 2018, figo is a regulated payment institution under the Payment Services Supervision Act (Zahlungsdiensteaufsichtsgesetz – ZAG), granting figo authorisation by the Federal Financial Supervisory Authority (BaFin) to provide AIS and PIS. With our permission, we enable you to leave the new supervisory duties to figo, via the so-called ‘tripartite contract model’. This saves you from having to build up compliance know-how and resources that have nothing to do with your core business.


The primary objective of financial supervision is to ensure a stable and sound financial system that consumers and businesses can trust. For this reason, those companies that have a contract with the account holder for access to his payment account, must be supervised as AISP or PISP. Through the ‘tripartite contract model’ developed by us, we want to make sure that you act PSD2 compliant without your own registration/licence.

  • The figo RegShield Model

Customer Journey

The figo RegShield provides a user flow compliant with BaFin requirements. It is possible to adapt this to your individual use case. 

  1. Your customer wants to use your service including an account information (AIS) or payment initiation service (PIS). To do so, they  switch to the figo application.
  1. The AIS or PIS process is carried out by figo – a regulated payment institution under the Payment Services Supervision Act (Zahlungsdiensteaufsichtsgesetz – ZAG) and therewith PSD2 compliant.
  2. Back in your application, you can offer your customer the best possible service, based on the obtained account information or initiated payment.
  • Customer Journey


With the new PSD2 approval requirements, there are many requirements that will require both resources and expertise, as well as a high level of administrative and procedural effort on behalf of your business. In order to avoid such complications, we have created the figo RegShield, which relieves you of the burden.

The idea behind this ‘Licence as a Service’ model is perfect for anyone who can not afford the expense of having their own supervision or simply wants to concentrate on their core business.

  • Your Values

The figo RegShield includes four scenarios

One-time and ongoing account information service (AIS and AIS+) as well as one-time and ongoing payment initiation service (PIS and PIS+).

These are reflected in the products below.  

An API gives you access to sophisticated data from various financial sources, such as bank accounts, credit cards, deposits, PayPal and FinTechs in Europe. The aggregator enables you to design new digital products around account details - such as transactions, revenue history and customers’ financial behaviour - and to satisfy your customers with innovative digital financial services.
  • The aggregator provides you with connectivity to standardised raw data for your product development.
  • The aggregator brings bank data from different accounts into a context - relevant to everyday life.
  • The aggregator is market-proven, secure and scalable.

As a payment initiation service, financial transactions are an important part of your business and you don't want to refer your customers to another service or provider? With the initiator, your customers can easily make secure bank transfers out of your service.
  • The initiator helps you to design processes as seamlessly as possible under PSD2 and to improve the user experience.
  • The initiator helps you to keep customers in your service and to increase customer loyalty.

The tagger automatically translates and categorises financial data and transactions into an understandable language for people & machines. Transaction elements such as reference, amount or transaction type are analysed and categorised based on machine learning (ML) technology. ML enables a continuous improvement of the recognition rate.
  • The tagger enables services such as financial forecast, liquidity determination, intelligent contract management.
  • Understanding transactions & account holders’ behavior made easy.
  • The tagger empowers data to tell a story.

The verifier lets you easily verify all relevant details of a bank account (account owner, balance, transactions, etc.). On the basis of this real-time data, you can make business decisions, such as granting credit or opening an account, in a simplified and immediate manner.
  • The verifier is your tool for automatic, immediate confirmation of bank account data.
  • Allows you to make decisions based on real-time data.
  • Use the verifier e.g. for automatic onboarding of your customers.

Use Cases

These companies trust in the figo RegShield.

With its innovative JustOn Billing & Invoice Management software, JustOn offers a solution for digitising the accounting, payment and receivables processes for medium-sized companies. With this service, JustOn is one of the leading providers on the Salesforce platform.
The integration of the RegShield for ongoing account information services (AIS+) enables the automatic reconciliation of account movements with incoming and outgoing invoices. As a payment institution regulated under the Payment Services Supervision Act (Zahlungsdiensteaufsichtsgesetz – ZAG), figo ensures that the retrieval of account information is carried out in compliance with PSD2. This allows JustOn to automatically reconcile transaction data without being a registered account information service provider.
NIST is the digital financing assistant for real estate purchases. The NIST financing certificate offers fast and reliable confirmation of the customer’s creditworthiness. A suitable real estate budget is defined for the user through a PSD2-compliant analysis of incoming payments.
The integration of RegShield for one-time account information services (AIS), enables NIST to carry out automatic, PSD2-compliant credit checks for the creation of individual financing certificates. With the help of these certificates, users can quickly prove their solvency to sellers and brokers. Thus securing an advantage over other buyers in the real estate market.


PSD2 Passporting

In August 2018, figo received as first provider in Germany, the ZAG licence (AIS/PIS). As of May 2019, the transposition of this licence has been successfully approved in Austria, Belgium, Czech Republic, France, Italy, Netherlands, Poland, Slovakia, Spain and the United Kingdom (figo is part of Open Banking UK).      

Service Levels

If you need us, we are there for you. We offer you different service packages to suit every need. Just talk to us for more details!


Is RegShield right for you? Contact us for further information and your non-committal, individual quote!

Your contact person

Head of Partnerships
Tel.: +49 40-228212710

Talk to us!

Over the last two years, figo has built up the expertise that made the RegShield possible. Our team regularly publishes the most important changes and their impact on market participants in the Compliance Blog. It also includes the ‘figo talks PSD2 Podcast’, which offers orientation and discussion on current topics. Take a look and listen!

Payment & Banking FinTech Podcast: PSD2 and figo Regshield

figo Blog und Podcast Logo