FinTech frontier: Mapping compliance challenges and opportunities in CEE

This map evaluates various aspects of FinTech regulation, including jurisdictional variations, licensing requirements, AML legislation, data protection, consumer protection, payment services, cryptocurrency legal status, crowdfunding, digital banking and innovation programmes. Navigating these complexities is vital for stakeholders to make informed decisions and strategically plan their operations. The map is based on our experts' evaluation. Lawyers were asked to scale a jurisdiction, not with words but with a simple number.

• How would you rate the current regulatory framework governing FinTech in your area? Think of 1 as a wild, unregulated frontier and 10 as a fortress of stringent rules.
• How tricky are the licensing requirements for FinTech companies where you are? Rate from 1 (super simple and straightforward) to 10 (a labyrinth of complexity that no one has fully navigated yet).
• How much does anti-money laundering (AML) legislation affect FinTech operations in your jurisdiction? Rate from 1 (barely noticeable) to 10 (a heavy, restrictive influence).
• How tough are the data protection and privacy requirements for FinTech companies in your area? Rate from 1 (lenient and easy to comply with) to 10 (rigorous and challenging).
• How robust is the level of consumer protection in the FinTech ecosystem where you are? Rate from 1 (minimal protection) to 10 (top-notch, comprehensive protection).
• How would you describe the regulatory environment for payment services in your jurisdiction? Rate from 1 (very liberal) to 10 (highly regulated with many barriers to entry).
• How is the legal status of cryptocurrencies and related services in your area? Rate from 1 (completely unregulated or fully legal and easy to operate) to 10 (a grey area or heavily regulated/prohibited).
• How would you rate the regulation of crowdfunding in your jurisdiction? Rate from 1 (least regulated or easiest to undertake) to 10 (most regulated or hardest to navigate).
• How stringent are the local regulations surrounding digital banking where you are? Rate from 1 (minimal regulation) to 10 (extremely tight regulation).
• How available and accessible are innovation programs or regulatory sandboxes in your jurisdiction? Rate from 1 (none available) to 10 (highly supportive with well-established programmes).

This map shows the aggregate points given by our experts to the above questions. Hover over each country to view the points awarded by the lawyers for each individual question.

* A local act on implementation of the MiCAR, currently in the legislative procedure in Slovenia, does not forsee an additional transition period (as forseen by Art 143(3) of the MiCAR) but, rather, requires all CASPs to acquire a license by 30 December 2024 or cease to provide their services in Slovenia. Depending on the final implementation, this may impact the assessment.    

**While Slovenia, as an EU Member State, has comprehensive legislation implementing PSD2 with limited deviations therefrom, the drafting of the implementing act leads to a degree of ambiguity and compliance risk.    

authors: Gábor Pázsitka, Bálint Bodó