Kristina Stark

Junior Growth Manager

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ONINO provides infrastructure for digital & tokenized financing across the EU and Switzerland.

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Key Takeaways

An ECSP licence is a planning problem rather than a regulatory gamble. 229 platforms held one at the end of 2024, and all of them passed the same gate. This post walks through that gate: who needs the licence, what goes in the application, how much capital you hold, how the process runs, what it costs, and what approval unlocks. The application is a fixed list of 18 items on one standard EU form. Capital is a formula, the higher of EUR 25,000 or a quarter of last year's fixed overheads. The deadlines are fixed as well, 25 working days for completeness and 3 months for the decision, but the clock stops with every regulator question, so plan 6 to 12 months. Only the fees change by country, from EUR 2,550 a year in France to EUR 75,000 capped in the Netherlands. One licence then covers the whole EU.

229 crowdfunding platforms held an ECSP licence at the end of 2024, and every one of them passed through the same gate. ECSP stands for European Crowdfunding Service Provider, and it is the licence a platform operator needs under the EU Crowdfunding Regulation (ECSPR) before it may match investors with business project owners anywhere in the EU. The transition from national regimes is long over, so there is no national permission left to fall back on.

The requirements are unusually plannable, which is the part most founders miss. The application is listed item by item, the capital is a formula rather than a flat number, the decision deadlines are fixed, and only the fees are left to national law. This post works through all of it: who needs the licence, what goes in the application, how much capital you have to hold, how the process runs, how long it really takes, what it costs, and what approval unlocks.

Who needs an ECSP licence?

Before going deeper into what the licence costs and how long it takes, it is worth being clear about who it is for and who actually needs one. Any company based in the EU that runs a platform matching investors with business project owners, by arranging loans or placing transferable securities without a firm commitment, needs an ECSP licence before going live. An ECSP (European Crowdfunding Service Provider license) is an official permit that allows websites to run investment/lending crowdfunding businesses. Running that activity without approval is prohibited, and national permissions are no longer an alternative for it. The licence is therefore a precondition of launch rather than a compliance upgrade a platform grows into, which moves it to the front of the business plan.

There is also a hard ceiling: EUR 5,000,000 per project owner in any 12 months. Everything that owner raised in the year before an offer goes live counts towards it, on your platform and on every other one in the EU, and you are the one expected to check the number. Onboarding someone who has already raised elsewhere does not reset it. Above EUR 5 million the raise leaves the regulation, and since 5 June 2026 an offer below EUR 12,000,000 can go ahead without a prospectus, though countries may cut that ceiling to EUR 5,000,000, as Germany and Belgium have. If your project owners routinely raise more, you will outgrow the licence you just paid for.

Two things decide scope: who you are financing, and with what. Consumers are out, which puts consumer credit and person-to-person lending outside all of this. On instruments, the licence reaches transferable securities, admitted instruments and loans the borrower is unconditionally obliged to repay. Subordinated loans and participation rights stay under national law, which is why most German crowdfunding platforms operate as financial investment intermediaries under trade law and need no BaFin permission at all. So when weighing a crowdfunding license in Europe you pick the instruments first and the country second.

The market that licence opens is real, but small. At the end of 2024, 229 platforms held one, up from 159 a year earlier, and 181 of them raised EUR 4.25 billion between them across 21 countries (ESMA's market report, December 2025, the newest available). The counts come from different sources, so the gap is not an official number, but it says something worth knowing before you budget: plenty of licensed platforms raised nothing that year. The licence buys market access, not deal flow. How ECSPR sits alongside the EU's other financing frameworks is mapped in ONINO's EU regulation hub.

What goes in the application?

An ECSP application is a fixed list of 18 items, not an open-ended submission. The regulation names each one, from the plan for what the platform will do and how it is run to proof of capital and signed outsourcing agreements, and they all go on one standard EU application form that every national regulator uses. So every input is knowable before you start, which turns the documentary ECSP licence requirements into a project plan rather than a black box.

Those 18 items sort into 5 buckets:

  1. Identity and legal.

  2. Business model and platform.

  3. Capital and business continuity.

  4. People and governance.

  5. Investor-facing procedures.

The split is really about who has to do the work. The identity and capital items are internal paperwork. The documents on your managers depend on third parties, so they need early lead time. The investor-facing procedures map onto platform workflows your product team is building anyway. The table below lists every item and what you prepare for it.

The heaviest lift is the paperwork on your managers. Only individual people may be responsible for managing a regulated crowdfunding platform (never another company), and for each of them you have to prove good repute and enough knowledge, skills and experience. In practice: criminal-record extracts, CVs and documented experience for several managers at once. Courts and former employers work to their own timetable, so this is the one item you cannot rush in the final week. Start it first, not last.

Two things about the file catch applicants out. Every offer on your platform carries a key investment information sheet (KIIS), the standard disclosure document investors read before they commit, and you do not file those sheets with the application. You file the process instead: how the platform checks that each sheet is complete, correct and clear before it goes live. And the file stays alive after you send it. If anything in it changes, you have to tell the regulator without undue delay, so work keeps arriving between filing and decision.

Bar chart of the 18 ECSP application items in Article 12(2)(a)-(r): people and governance 5, prudential and continuity 4, identity and legal 3, business model and platform 3, investor-facing procedures 3. Items (k) and (l) need lead time.

How much capital do you need for an ECSP licence?

Capital is a formula, not a flat number. You hold at least the higher of EUR 25,000 or a quarter of last year's fixed overheads, at all times, reviewed once a year, plus three months of loan-servicing costs if you arrange loans. The figure moves every year with your own cost base, so it belongs in the financial model and not in a one-line compliance budget.

Most write-ups quote only the EUR 25,000 floor, which understates it for any platform with real operating costs. Run EUR 400,000 of fixed overheads last year and you hold EUR 100,000 this year, four times the floor. It cuts both ways, though: a pre-revenue applicant with a small cost base really does start at EUR 25,000. The requirement scales with the platform rather than blocking the door.

How you hold it is a real choice: own funds, meaning core equity capital on the balance sheet, or an insurance policy covering the EU countries where you actively market your offers, or a comparable guarantee, or a mix of the two, with your regulator deciding whether the mix is adequate. Early on that is a cash-flow decision: equity tied up on the balance sheet against a premium paid out of the operating budget.

Proof goes into the application. One of the 18 items is evidence that you meet the requirement: an audited account statement, or an auditor's certification if your annual accounts are not audited. And it is not an entry ticket. It applies at all times, and the annual review lifts the figure as your cost base grows.

How does the authorisation process with the regulator work?

The process is procedural, not discretionary theatre. You file with the regulator in the EU country where your company is established, your home country. It confirms receipt within 10 working days, checks whether the file is complete within 25 working days, and then gives a fully reasoned decision within 3 months of a complete application. Those steps are fixed, so what separates a fast file from a slow one is the quality of what you send, not regulator goodwill.

France shows what pre-filing quality looks like in practice. The AMF asks you to present the project before you file, runs the application, and will not grant a loan-arranging licence without a favourable opinion from the ACPR, the French banking supervisor. That is local practice, not the European rule: the same deadlines apply to the AFM in the Netherlands, the CSSF in Luxembourg and BaFin in Germany, because the deadlines come from the regulation and only the local process around them differs. So in short, each country will have their own processes you will have to adhere to. Likely needing to locate a lawyer capable of understanding that countries specific pre-filings.

In ONINO's work with platform operators and law-firm partners, the three-month assessment is rarely what delays an application. The time goes into three things: back-and-forth over a file that is not yet complete, outsourcing arrangements still sitting as term sheets when the file needs signed agreements, and the proof that each manager is qualified and has a clean record. All three are fixable before you file, and fixing them is what makes the official deadlines mean anything for your launch date.

Practitioners describe the same pattern. Tanja Aschenbeck, a partner at Osborne Clarke in Cologne who has taken platforms through the German procedure, writes that the fit-and-proper element "is not a mere formality. Rather, BaFin has quite high expectations of both reliability and professional suitability."

How long does ECSP authorisation take, really?

In ONINO's experience, plan 6 to 12 months end to end including preparation. That range is our observation, not a figure from the regulation.
Official time is not calendar time, and the gap between them is where launch dates go missing. The clock is 25 working days for the completeness check plus 3 months for the assessment, and it only starts once a complete application arrives. It also pauses between the day the regulator asks for something missing and the day it gets it. Every round of questions stops the clock, which is why real timelines run past the official ones.

The transition period showed how far that can drift. More than a year after the rules started to apply, BaFin had granted no licence at all: four applications received, one withdrawn, three pending, according to an answer of the German Federal Government. That was the transition period, not current German practice. What carries forward is the mechanics behind it: a clock that stops every time the regulator asks a question.

As shown in the graphic below, the path has five milestones: preparing the file, filing it and passing the completeness check, the pauses while the regulator asks for more, the 3-month assessment, and the register entry that lets you passport across the EU. Two of them decide your launch date. Preparing the file is the longest stage you control, and the pauses are the one most founders never budget for. Both sit on your side of the line, not the regulator's. The timeline below puts the official deadlines next to a realistic planning range.

Timeline of the ECSP authorisation critical path: five stages from pre-filing preparation to register entry, with the statutory clock of 25 working days plus 3 months set against a realistic 6–12 month planning range on a month scale.

What does an ECSP licence cost?

There is no single EU fee. Each national regulator sets its own, and they are not comparable line for line: France charges EUR 2,550 a year and nothing for reviewing the file, the Netherlands bills EUR 200 an hour up to a cap of EUR 75,000, and Luxembourg takes a one-off examination fee of EUR 30,000 plus annual fees. Germany charges a fee too, but the amount is still pending verification, so it sits in the table below without a number rather than with a guess.

The fine print matters more than the headline number. The Dutch fee is billed by the hour, so the real invoice depends on the case and annual supervision levies come on top. In Luxembourg the annual charge is a growth cost rather than an entry cost: EUR 10,000 flat plus a variable part that only starts once you finance more than EUR 1 million a year and tops out at EUR 30,000 once you pass EUR 55 million.

The French contribution of EUR 2,550 is only due once the licence is granted, so if you file in one year and launch in the next you pay nothing in between. One regulator prices an hourly cap, another an annual contribution, so cost the home country on this level of detail rather than on the biggest headline number.

Two things keep the budget honest. Fees are spent; capital is only held. Your reserve capital sits on the balance sheet rather than leaving it, so adding it to a EUR 30,000 examination fee counts capital as a cost and overstates what entry really costs. And a licence needs a platform to run on: advisory work, legal work and the build itself, whether in house or on white-label financing infrastructure, are all larger and far more variable lines than the official fee. That makes the regulator's invoice the least useful number to optimise.

What happens after approval?

Approval puts you in a public register. ESMA's register of crowdfunding service providers shows who you are, the platform's name and website address, the regulator that granted the licence, the services it covers, the countries you have notified for cross-border work and any penalties against you or your managers. Withdrawn licences stay published for five years. So the licence is something investors and counterparties can verify in seconds, and so is its loss.

One ECSP licence then covers the whole EU. To operate in another EU country you notify a single contact point at your home regulator, which passes it on to the regulators there and to ESMA within 10 working days. You can start once your home regulator confirms the file has gone out, and at the latest 15 calendar days after you sent the notification. No second application, no separate approval in the host country. What the licence does not remove is the local layer: your marketing has to follow the host country's own rules, which each regulator publishes, and the key investment information sheet has to be available in an official language of that country or one its authorities accept.

The obligations start on day one: checking the information sheet for every offer you publish, and running the protections for less experienced investors. Both are product workflows, not policy documents.

An ECSP licence is a planning problem, not a regulatory gamble. The application is a checklist, the capital is a formula, the deadlines are fixed, and only the fees change by country. Of those four, the timeline is what decides launch dates, and it is the only one you can pull forward yourself. So the next move is yours, and it is the paperwork on your managers and the outsourcing agreements, not the application form.

The build does not have to wait for the decision. Authorisation and platform development can run in parallel: ONINO provides the white-label financing infrastructure a licensed operation runs on, with the licensed partner roles already connected, while the application itself stays with you and your legal advisers.


The software never needs the licence; the activity does, and that permission always sits with you as the operator. Talk to us to map your ECSP authorisation critical path with our team.

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