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!

Functionality
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.
Model
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.
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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.
- 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.
- 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.
- Back in your application, you can offer your customer the best possible service, based on the obtained account information or initiated payment.
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Customer Journey
Values
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.
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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.
Use Cases
These companies trust in the figo RegShield.
Add-ons
PSD2 Passporting

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

Your contact person
Chris
Head of Partnerships
Tel.: +49 40-228212710
E-Mail: inbound-connect@finleap.com
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!