91����ԭ��

With white labelling now commonplace in the EU financial landscape, the European Banking Authority (EBA) has signalled that 2026 will mark the start of systematic supervisory mapping of the practice across the bloc.

In a  on the subject, the banking regulator said that 35 percent of banks responding to its 2025 Spring Risk Assessment Questionnaire engage in white-labelling arrangements, a trend increasingly driven by digitalisation and platform-based business models. 

Traditionally used between banks, the practice – when a company creates a product or service that another company rebrands and sells as its own – now often involves partnerships with non-financial firms such as online marketplaces, telecom operators and retailers.

White labelling allows a financial institution to supply regulated products, such as payment accounts, e-money or credit that are distributed under a partner’s brand. 

The EBA suggested that the model is a way of improving access to financial services and competition. However, it warned that it also introduces new risks to the market, especially around transparency, consumer protection and supervisory visibility.

Cost and inclusion benefits

In the report, the EBA identified several potential opportunities for providers, partners and consumers. 

For example, providers can expand their reach cost-effectively by utilising their partners’ brand visibility and customer-facing infrastructure, while partners can avoid licensing and compliance costs by leveraging the provider’s authorisation. 

Consumers may, in turn, benefit from wider access to financial products and potentially lower costs.

White labelling can also help firms test new products or enter markets via established partners, and providers may use partners’ customer data to better target and customise products. In addition, partners can use the provider’s back-office systems to expand their services without building costly infrastructure.

The EBA noted that the model can improve financial inclusion, particularly for consumers in rural or underserved areas where traditional financial institutions have limited physical presence. 

In such cases, the combination of a partner’s platform and a provider’s licence can significantly enhance access to financial products and improve the user experience.

FiDA’s role in data-driven expansion

The EBA also highlighted that the proposed  (FIDA) could support the scalability of white labelling by improving data standardisation and secure sharing across financial products, going beyond the scope of open banking under the second Payment Services Directive (PSD2).

FiDA’s introduction of financial information service provider (FISP) licences could create a new class of firms acting as white-label data providers, further blurring the lines between traditional finance and platform models. 

The framework’s focus on interoperability and data protection could also foster innovation and consumer trust in cross-border arrangements.

Mounting risks for consumers and supervisors

Although the EBA’s report highlights the benefits of white labelling, it also warns that the model’s growing complexity and cross-border reach pose challenges for consumers, firms and supervisors. 

Consumers often struggle to identify which firm is legally responsible for their product, particularly when brands and regulated entities differ, complicating complaints handling and redress.

The regulator also noted that some partners display the provider’s licence on their websites, potentially misleading customers into believing they are contracting directly with a regulated entity. It cited misleading or incomplete information, complex cost structures and opaque terms as common risks.

Fraud risks are also heightened when roles and responsibilities are unclear, or when customer due diligence (CDD) tasks are delegated without adequate oversight, raising compliance risks. 

The report draws parallels with authorised push payment (APP) fraud, warning that consumers may not know who is liable when scams occur through white-labelled apps.

“A risk of fraud might arise due to the lack of transparency and consumers' understanding of the roles and allocation of responsibilities between providers and partners,” the EBA said. 

“Weaknesses in partner CDD practices, and absent sufficient oversight by the provider, may also increase fraud risks.”

Data privacy risks were another concern highlighted by the EBA, which noted that as providers and partners share large volumes of customer data, the risk of misuse or breach increases. It called for transparency about how data is stored, used and protected under the General Data Protection Regulation (GDPR).

Consumer organisations have warned that digital-only white-labelled services could exclude elderly or less technically astute users, emphasising the need to comply with accessibility standards and to strengthen financial literacy initiatives.

“Further actions at the national level could improve financial literacy of consumers, for example, by enhancing their understanding of opportunities, challenges and potential risks linked to financial innovation, in particular regarding the use of ‘seamless’ online financial services, including via multi-purpose platforms, and cybersecurity issues,” the report says. 

“Raising awareness of the risks that consumers may face when choosing online or mobile banking services should be further encouraged on a regular basis.”

Operational and compliance challenges for firms

The EBA cautioned that white labelling can heighten business model, operational and reputational risks. 

For example, providers may become overly dependent on key partners, while partners risk disruption if providers withdraw services or lose their licence.

The fragmentation of responsibilities and data flows also raises anti-money laundering and counter-terrorism financing (AML/CTF) and compliance challenges, particularly in cross-border contexts. This means providers must ensure that any reliance on partners for customer onboarding or monitoring still satisfies regulatory requirements.

Where CDD data is held by partners, providers may face difficulties accessing it, a significant compliance gap. However, the EBA said that harmonisation under the new Anti-Money Laundering Regulation (AMLR) should help, although clear data-sharing arrangements and oversight remain essential.

Supervisors also face growing difficulties. Many white labelling agreements go unreported, as they do not always trigger formal notification requirements unless the partner qualifies as an agent or material outsourcing arrangement. 

This opacity, especially in cross-border cases, can leave national authorities unaware that regulated products are being distributed in their jurisdictions.

The EBA called for greater supervisory convergence and said it had developed a voluntary common template to help national authorities identify and assess white-labelling arrangements. 

AML/CTF authorities in around half of the EU member states already treat white labelling as a medium or high money-laundering risk, according to survey responses.

Next steps

The EBA has not proposed legislative changes, but has said that it sees a need for stronger and more consistent supervision.

In 2026, it plans to:

• Integrate white labelling into the Union Strategic Supervisory Priorities, under the theme of technology integration and resilience.
• Facilitate dialogue among national authorities to share case studies and best practices.
• Strengthen consumer-facing disclosures, particularly around the identity of the product provider and complaint-handling channels.

“White labelling can benefit partners and providers, by improving cost efficiency, broadening the offer of financial products and services, and supporting the creation of new revenue streams,” the EBA said. 

“In turn, this can benefit consumers who may enjoy access to a wider range of products and services at potentially lower costs. However, the involvement of multiple entities implies a fragmentation of the value chain and may create complex business models, which in turn can increase challenges and risks for consumers, providers, partners, and supervisors.” 

Going forward, banking and payment professionals operating in the EU can expect 2026 to mark the start of systematic supervisory mapping of white labelling across the EU.

Banks, e-money firms and payment institutions will face closer scrutiny of governance, AML/CTF delegation and consumer disclosure.

In addition, FiDA is expected to expand the white-labelling ecosystem by making data sharing easier, but also to tighten oversight by defining clearer obligations for intermediaries and data users.