To AISP or not to AISP
This is a continuation of the journey of the money-saving product I have the ambition to build.
UPDATE: I have a scheduled phone call with InnovationHub, seems like they want to evaluate my specific situation. Exciting!
After some research I’ve found the Dutch (at least) definition of what constitutes an Account Information Service.
What is an account information service?Answer:An account information service is an online service for providing consolidated information on one or more payment accounts held by a payment service user with one or more other payment service providers.Explanation
Providing consolidated online information to payment service users means they can obtain an overview of their financial situation. Account information service providers can categorise expenditure, which also offers users a better insight into their spending patterns.A licence is required in order to provide account information services (as referred to under point (8) of Annex I to PSD2). There is a lighter licensing regime for account information services as these providers do not at any time hold funds, and are not therefore subject to particular prudential requirements.With the consent of the user, the account information service provider has access to the current accounts of the account servicing payment service provider. This can be a bank, but also a payment institution that offers the services under points (1) and (2) of Annex I to PSD2.
It seems as what I am intending to do with the Hands-off Money Flow companion Add-On falls within the scope of what constitutes an AIS. So.. this means a license would need to be in place before this Add-On could be in production without breaking any laws.
If I would need a license I would for sure need to know that there is enough demand in the market for this product before continuing with the production.
Next steps
- Research if there are any exemptions I can make use of or would fall within
- Piggy-back on another license? This would mean I would need to form a partnership with someone who is already registered as an AISP
- IF there is sufficient market demand, consider pivoting to increase the scope of the Add-On to make it more viable from a business perspective. This would mean a few marketing campaigns to test out the waters.
- Completely verify that I am not missing a technical detail which would mean a license would not be necessary
