Build — № 01 · Season 01
Payments
Taking money requires authorisation. We don't have it. Here are the four steps that lead there, and what each one costs.
The projectsContents
- The obstacle: an authorisation
- Four steps
- Eight pieces to write
- What we don't know
The real obstacle
Taking money requires authorisation.
Building a tool asks nobody's permission. Taking money does. Payment is a regulated trade: to run it yourself you need a status granted by the French prudential supervisor, the ACPR — and that status cannot be obtained with code.
Which is why everyone goes through a middleman. It holds the licence, it takes its cut, it writes the rules. The dependence isn't technical — it is regulatory, and that is what makes it last.
Every means we want to reclaim is guarded by an authorisation. This one is crossed in four moves.
Build — payments
Four steps,
climbed one at a time.
Each one removes a share of dependence. Each one already earns, which pays for the next. None of them requires waiting until all the money is there before starting.
The share that isn't ours yet
00 — today
Where we stand
00
Under a third party's licence
0 €
No regulatory capital
What isn't ours
Payments run through a payment service provider that already holds a licence. We hold neither the bank details nor the customer identities: everything stays with them.
- What we gain
- The product runs, takes money and funds itself right now. Nothing waits on an authorisation.
- What it costs
- Total dependence. The provider takes its cut, sets its rules, and can shut off the tap.
Next step — 01
The next step
01
Agent of a payment service provider
0 €
Registration, not authorisation
What isn't ours
A licensed institution mandates us and enters us in the ACPR register. We run the payments ourselves, under its licence and its responsibility.
- What we gain
- Genuinely running payments, building volume and compliance expertise in real conditions — without tying up a single penny.
- What it costs
- We have to convince an institution to mandate us: it files the application, not us. Good repute, competence and internal control all have to be demonstrated.
Next step — 02
Later on
02
Simplified payment institution authorisation
Reduced capital
Up to 3 M€/month in volume
What isn't ours
Our own authorisation, granted by the ACPR. A tailored prudential regime: lower initial capital, and no minimum own funds requirement under article L. 522-11-1 of the French monetary and financial code.
- What we gain
- The licence is ours. No principal, no cut taken by a middleman, no rules written by someone else.
- What it costs
- A full authorisation dossier, and that is where the legal work concentrates. The regime is capped and gives no access to the European passport.
Next step — 03
Later on
03
Full payment institution authorisation
125 000 €
Minimum initial capital
What isn't ours
The full regime, with no volume cap. The capital is not an expense: it sits frozen on the balance sheet, required by the regulator, and there it stays.
- What we gain
- No volume limit left, and a complete setup that holds at scale.
- What it costs
- Full internal control, permanent compliance functions, continuous reporting to the regulator.
What reinvestment funds
Lawyers, not capital.
Regulatory capital — the 125 000 € of the final step — is not an expense. It is a sum frozen on the balance sheet, which the regulator demands to see and which stays there. You don't spend it, you place it.
The real spending lies elsewhere, and it is human. An authorisation dossier is a body of written procedures, verifiable and defensible before an authority that can summon the directors and pull the business model apart. It is written with lawyers who specialise in banking law, and maintained by a compliance officer who doesn't leave once the file is submitted.
The dossier
What has to be written.
The contents of an authorisation dossier, as the regulator examines it. This list is what our reinvestment pays for.
№ 01
Programme of operations
A precise description of the services provided, how they work and how they are delivered. It is the piece the regulator reads first.
№ 02
Prudential business plan
Financial projections showing that the prudential requirements will be met over time, not merely on the day the file is submitted.
№ 03
AML-CFT framework
Anti-money laundering and counter-terrorist financing: procedures, controls, and a named officer. It is not a document, it is a permanent function.
№ 04
Internal control
Two levels of control, with the governance that comes with them. The simplified regime lightens it; it does not remove it.
№ 05
Security and sensitive data
Access procedures for payment data, security arrangements, fraud prevention.
№ 06
Business continuity
What happens when it falls over. The regulator wants the plan written before the incident.
№ 07
Safeguarding of funds
How users' funds are protected and ring-fenced. They are never ours.
№ 08
Directors and shareholders
Good repute, competence, experience — assessed person by person. The authority can summon them for a hearing.
Reviewing a complete dossier takes three months. The clock only starts once the file is judged complete — the preparation itself has no regulatory deadline. That is the part we fund.
What we don't know yet
The price isn't public.
Neither the authorities nor the specialist firms publish a rate card for guiding an authorisation dossier. The figure doesn't exist in the open: it comes as a quote, case by case.
So we won't put an amount on this page until we have our own. The only figures shown here are the regulatory capital thresholds, set by the French monetary and financial code. When the quotes arrive, they will be published — like everything else.
And we may never have to climb all four steps. Step 00 already takes money. Each of the following ones gets decided the moment it becomes worth more than the dependence it removes.