EMI · PI · CASP licensing
Fintech licensing & operational advisory. Italian boutique, European scope.
Bizando works alongside founders, COOs and operational teams through the decisive steps: securing an EMI, PI or CASP licence, scaling the structure, keeping the regulatory setup aligned. Monthly retainer or fixed-scope packs. Proprietary CAI methodology.
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4 pages, 6 minutes' reading
Who Bizando works with
Bizando works with regulated operators, or operators on their way there: early-stage fintechs preparing a licence application, EMIs and PIs already authorised and now scaling or extending scope, CASPs structuring their MiCA arrangements, payments operators with cross-border exposure in the EU.
A monthly retainer is the right arrangement when the need is continuous — recurring regulatory decisions, dossiers that evolve over time, alignment to be maintained. When the need is instead specific and bounded (an AML manual, an EMI gap analysis, a MiCA whitepaper), the correct model is a fixed-scope pack.
Engagement model
Three retainer tiers
Light
€2,500
/ month
For early-stage fintechs in strategic exploration or pre-application.
Structured senior sparring: a weekly call on regulatory decisions and roadmap, asynchronous support within 48 working hours, one operational document a month (memo, brief, targeted gap). It is the right tier when the client is building its own regulatory thesis and needs a continuous senior reference point, not yet intensive documentation delivery.
Standard
€3,500
/ month
For EMIs, PIs or CASPs scaling after authorisation.
It also applies in active licensing, with an application already filed with the authority. Continuous operational support: a structured weekly call, extended asynchronous support, one substantial documentation deliverable a month (policy, extended gap analysis, board memo, scope extension dossier). The Standard retainer becomes a stable part of the client's internal workflow: most steady-state engagements land on this tier.
Pro
from €5,000
/ month — scope-based
For operators with complex parallel dossiers.
End-to-end active licensing, multi-jurisdiction extensions, evolving scope touching several regulatory areas at once. Close leadership on the dossier. Intense call cadence, several documentation deliverables in parallel, presence at the critical moments — preparing interactions with the authority, a steady advisor on decisions that shape the company's trajectory. The price is set after the discovery call, according to actual scope, the sub-dossiers involved and the cadence required.
Terms common to all tiers
All amounts are exclusive of VAT. Three-month minimum term. Rolling monthly from then on, cancellable with 30 days' notice. Payment at the start of the month. Tier upgrades take effect immediately, downgrades from the following month. One month's pause per year is available: the suspended month is not invoiced and does not count towards the minimum term.
Declared scope
Where the retainer's scope ends
The retainer covers operational advisory and the documentation produced inside the client's regulatory work. Some areas stay outside — priced separately, or referred to dedicated partners:
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Formal legal opinions and representation in court.
The professional judgement of a lawyer admitted to the bar is a different thing from operational advisory: where it is needed, I refer to partner law firms I work with regularly.
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Direct dealings with the authority on the client's behalf.
I prepare the documentation and build the strategic shape of the responses, but the signature and the formal exchange remain the client's or its legal representative's.
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Software development and technical implementation.
Regulatory advisory defines the what and the why; IT implementation — AML systems, SCA engines, scheme integrations — remains with the client's internal technical team or with specialised vendors.
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Extensive training of the client's team.
Short working sessions are part of the retainer; structured training programmes require a dedicated SoW.
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Travel and in-person meetings.
Calls are part of the retainer; travel is reimbursed separately and agreed case by case.
How I work: the CAI methodology
At Bizando I apply an internal Collective Artificial Intelligence (CAI) methodology, proprietary, developed on years of real regulatory advisory work. It is how I produce what the client receives, and it is worth saying plainly, because it is the main operational differentiator against a traditional firm.
In practice it means this: my senior judgement — on strategy, on reading the rules, on the wording addressed to an authority, on the choices that carry consequences — is amplified by AI systems specialised in fast regulatory research, first drafts of documents, comparison across versions and dossiers, and the synthesis of extensive bodies of regulation. The human part stays where it counts: critical decisions, validation of every section, dialogue with the client, regulatory positioning choices.
The practical result for the client is twofold. First: a first draft of a standard regulatory section — a business plan chapter, an AML policy, a governance arrangement — can be ready for my review and for the client's review in 48 to 72 hours instead of one to two weeks, leaving real room for more iterations in the same interval. Second: regulatory consistency is maintained even across parallel dossiers or interconnected sections, because the consistency check is systematic rather than entrusted to operational memory.
What the client receives is always the finished output of the process: documents reviewed, validated, signed off by my judgement. Not raw AI output. Not unchecked drafts. CAI is the how the work gets done; the what the client receives is unchanged — a senior-grade deliverable ready for the regulator, or for the internal decision it has to support.
Five practical points, in plain terms
No quotes, no client logos, no packaged case studies. What follows are five factual points about how I work: what I cover, what I have already done, how I control quality, what I bring the client from day one, and what I explicitly do not guarantee.
1. Regulatory frameworks actively covered
Bizando's advisory moves within a defined regulatory scope. The frameworks I work on daily, named with their technical names because a technical reader recognises them:
- PSD2 and the PSR/PSD3 evolution
- AMLD6 and the EU AML package (AMLR, AMLA, the European AML authority)
- MiCA for crypto-asset service providers
- DORA for digital operational resilience
- IFR (Interchange Fee Regulation)
- The EMI and PI regimes (Title II PSD2)
- EBA outsourcing guidelines and the related supervisory expectations
- EU sanctions frameworks and restrictive measures
- ESMA/EBA technical standards and opinions relevant to fintech
2. Proprietary assets available from day one
The client does not start from zero. What I have accumulated at Bizando and what enters the retainer from the first operational day:
- A private knowledge base of document templates for the recurring regulatory sections (business plan, AML setup, governance arrangement, IT risk, outsourcing register, capital adequacy)
- Operational gap-analysis checklists specific to EMI, PI and CASP applications
- Comparative matrices of authorisation requirements across active EU jurisdictions: initial capital, governance structure, AML scope, typical supervisory expectations
- A curated library of EU regulatory precedent: EBA opinions, ESMA guidance, published supervisory decisions, national authority Q&As
3. Quality control on every deliverable
The CAI methodology is not "AI writes and a human approves". It is a controlled process with three explicit safeguards on every deliverable that goes out:
- Two-pass QA. Every document produced goes through two successive reviews of mine: the first on regulatory content (technical correctness, completeness, consistency with the client's strategic position), the second on form (readability for the actual recipient — authority, board, internal team).
- AI red-teaming on the draft. Before delivery, I use specialised CAI systems to stress-test the wording, identify logical gaps, and surface any internal contradictions. It is an additive control, not a substitute for human review.
- Versioned traceability. Every deliverable carries a full trail (initial prompt → generated drafts → revisions → final validation) that lets me reconstruct after the fact the reason behind every single documentation choice. Useful during a client's internal audit or in an exchange with the authority.
4. Recurring types of engagement
In recent years the work at Bizando has settled around three recurring clusters, matching the moments when a fintech operator typically looks for senior regulatory advisory:
- Initial authorisation. End-to-end support in preparing EMI, PI or CASP applications: structuring the dossier, drafting technical and regulatory annexes, handling the authority's requests for further information, holding cross-document consistency across successive iterations.
- Regulatory scaling. Extending the scope of authorisation, passporting into new EU jurisdictions, activating additional regulated products within an existing licence, evolving the governance setup.
- Continuous regulatory maintenance. Updating AML/CFT policies, ICAAP/ILAAP, recurring compliance programmes, handling inspections and audits, preparing responses to the authority's information requests.
Declared scope
5. What I do not guarantee — explicitly
Being transparent about the limits is part of the positioning. Three things said plainly in the discovery call and repeated in the contract:
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I do not guarantee that the competent authority will grant the licence.
The assessment of fitness belongs to the authority, not to me.
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I do not replace the formal legal opinion of a lawyer admitted to the bar.
Where a signed legal opinion is needed, I refer to the appropriate partner.
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I do not speak to the authority on the client's behalf.
I prepare the approach and build the wording, but the signature stays with the client.
Frequent questions
How does kickoff work, and how long until we are operational?
After the 20-minute discovery call, if there is mutual fit I send a written proposal within 48 working hours, with the recommended tier, the expected scope, and the deliverable expected in the first month. Once the proposal is signed and the first month is paid, we schedule a 90-minute kickoff call — usually within the following week — where we share inputs, align on the top three priorities for the first 90 days, and open the working channel (a dedicated Slack channel or a shared mailbox). From there I am operational. Typical total time from discovery to first work delivered: 7 to 10 working days.
What do I actually need to do after booking the discovery call?
Nothing is required in advance. The discovery call is exploratory: understanding where you are, where you want to go, and whether what I do at Bizando is the right thing for you at this moment. It helps — if you have it ready — to align briefly by email beforehand on three points: the kind of regulated operation you are building or running, the current stage (idea, pre-application, application filed, authorised and scaling), and the first regulatory decision facing you in the next 4 to 8 weeks. If you do not have those structured yet, we build them together on the call.
When do you invoice, when is payment due, and how do I exit the contract?
Invoicing at the start of the month, payment within 7 days of the invoice date. The first month is paid in advance as a condition of activating the retainer. The minimum term is three consecutive months: below that window the arrangement cannot deliver real value, to the client or to me. After the first three months the contract becomes rolling monthly and can be cancelled with 30 days' written notice, without penalty. Tier upgrades take effect immediately, downgrades from the following month. The retainer can be paused for one month per year: the suspended month is not invoiced and does not count towards the minimum term.
€2,500 a month is a significant figure for a small early-stage fintech. Why not just hire a junior compliance officer in-house?
Fair question, and in some cases the right answer is exactly that: hire. A junior in-house compliance officer costs €40–60K gross a year plus employment costs, is available full time, and grows inside the company. What that does not give you is immediate seniority on the decisions that bite — non-standard interpretation, strategic positioning towards the authority, scope choices with medium-term consequences. The Light retainer does not replace an in-house compliance officer: it works alongside one, or it comes before one while the company is not yet ready to hire. The typical use case for Light is an early-stage fintech that needs 10 to 12 hours a month of regulatory seniority, not an FTE.
For a significant regulatory dossier, why choose you over a large firm — a Big Four or an international law firm?
Different kinds of work, different choices. Big Four firms and international law firms are the correct choice when the client needs institutional cover, formal legal opinions, physical presence across several countries, an operational backup structure for reputational crises. Bizando is the correct choice when the client needs a senior operational advisor who gets inside the dossier — rather than orchestrating it from above — with a close cadence, direct access to the decision-maker, and speed of documentation delivery. The two models coexist regularly: a clean split between legal advisor and operational advisor is the most effective pattern on complex dossiers — the lawyer signs the formal opinion and handles the exchange with the authority, the operational advisor builds the scaffolding of the dossier and the documentation itself.
If part of the documentation production runs through AI systems, what guarantees that the document reaching the authority is not a plausible hallucination?
The answer is structural, not reassuring. Three specific safeguards. First: no deliverable leaves Bizando without two review passes of mine — regulatory content first, then form and readability for the actual recipient. Second: every regulatory claim in the documents is anchored to an identifiable primary source (legislative text, technical standard, authority opinion, published Q&A), not to a generated summary. Third: professional responsibility for the deliverable is mine, not the system's. When a document reaches the authority with my signature under it, the signature means I built it, I validated it, and I answer for it. CAI shortens production time; it does not move responsibility.
How do you handle confidentiality? Do you sign NDAs?
Yes, by default. A mutual NDA is signed before the discovery call if the client has sensitive material to share at that stage, or alongside the written proposal in every other case. For clients operating in regulated markets, confidentiality clauses are also built into the retainer contract and cover operational data, regulatory documents, communications with the authority, the client's internal structure, and personal data under the GDPR. I am willing to sign the client's own standard NDA — including with terms stricter than my default — if required.
How do you avoid conflicts of interest if you work with several operators in the same sector?
Three safeguards. First: before sending a proposal I always run an internal clearance check — verifying that the prospect is not in direct conflict with active retainer clients, with "direct" defined by overlap of product, geographic market, and licensing stage. If the conflict exists, I declare it to the prospect and decline the engagement. Second: the non-conflict clause is written into the retainer contract and is bilateral — the client can ask me to confirm the absence of conflicts at any time. Third: one client's material is never used as an operational reference for another. Bizando's private knowledge base is made of my own templates and frameworks, not of client output.
Twenty minutes to talk it through
If what you have read matches the moment you are in — initial authorisation, regulatory scaling, continuous maintenance — the next step is a short conversation, with no commitment. Twenty minutes to understand where you are, where you want to go, and whether Bizando is the right thing for you at this moment. If it is not, I will tell you on the call.
Opens the Cal.com calendar: you pick the date and time.
What to expect from a fintech advisory retainer: scope, cadence, deliverables, the real limits of professional judgement. Six minutes' reading, no commercial pitch.
Prefer to start by email? info@bizando.com — I reply within one working day.