Choosing the agent model rather than an approved establishment
Becoming an agent of a payment institution means adopting a strategic intermediary position between :
- The “technical partner” model (simple integration of a PSP via API),
- And the “approved establishment” model (with own funds, regulatory capital and heavy prudential requirements).
The status of Payment Service (PSP) agent allows an entity to operate under the accreditation of an authorized institution, while maintaining control and operational autonomy over key functions, such as the collection, distribution, and remittance of payments. It also requires the implementation of ongoing measures to combat fraudulent activity, as well as rigorous knowledge and supervision of sub-merchants.
In concrete terms, this status:
- engages the regulatory responsibility of the platform,
- assumes a solid and structured internal organization,
- is part of a supervised and demanding relationship with the PSP and the regulator.
The regulatory framework in force in France
This status is based on the transposition into French law of the Payment Services Directive (PSD2), as well as on the provisions of the Monetary and Financial Code (articles L.523-1 et seq.) which stipulate that the agent acts in the name and on behalf of an approved establishment, which remains fully responsible to the regulator.
This status aims to regulate the provision of payment services by non-banking players via approved third-party intermediaries/service providers.
The Prudential Supervision and Resolution Authority (ACPR), attached to the Banque de France, is the only authority competent to register payment service providers. A platform cannot submit an application alone: it must go through an approved institution (EP or EME).
As part of a platform application, the payment institution :
- prepares the registration file in collaboration with the agent and submits it to the ACPR,
- ensures exchanges with the ACPR and responds to requests for clarification,
- informs the platform of the decision.
Requirements to be a PSP agent
Before even talking about registration, the platform must prove its solidity and organizational maturity with regard to prudential regulations.
| Pillars | Main requirements |
| Legal structure and governance | Incorporated company (SAS, SA, SARL, etc.), identified governance, competent and honorable managers |
| Human and technical resources | Ability to monitor flows, anti-money laundering and terrorist financing (AML-CFT) system, secure and traceable infrastructure |
| Contractual commitment | Signing of a PSP agent contract + possible outsourcing contracts if certain critical functions require it |
Our feedback as an approved payment institution shows that the success, but also the speed of ACPR registration often depends on the proper structuring of the agent’s organization.
A full operational and regulatory role
Obtaining registration is not an end in itself. It is above all the entry into a regulated activity which strongly engages the responsibility of the platform, particularly in terms of :
Regulatory vigilance (AML-CFT)
- Identify sub-merchants (KYC/KYB) and check their activity and the consistency of flows,
- Monitor unusual operations and report alerts to the PE,
- Train your teams in procedures.
Transparency towards sub-merchants
- Communicate clearly on the timeframes and conditions for making funds available,
- Allow sub-merchants to access and consult their payment accounts,
- Define the payment terms in agreement with the sub-merchants.
A tripartite relationship: agent, establishment and regulator
The payment service provider agent never acts alone: it is part of a close contractual relationship with the PSP (legally and operationally), under the supervision of the ACPR.
A precise contractual framework
The agent contract defines :
- the scope of delegated services,
- mandatory compliance and safety rules,
- supervision methods (reporting, audits, alerts).
The payment institution continuously monitors the volumes processed by the platform, as well as incidents and anomalies. Audits can be conducted at any time.
Supervised daily governance
Becoming a payment service provider also means adopting a daily compliance organization and culture, with :
- a compliance officer (AML-CFT, reporting, regulatory monitoring),
- a technical contact for security and incident management,
- formalized procedures for KYC/KYB, flow monitoring and anomaly management.
At CentralPay, we have implemented a rigorous policy that governs our agents, from the processing of their file with the ACPR to their ongoing operational supervision, in order to ensure strict compliance with the regulator’s doctrine.
A strictly regulated registration process
In 2024, 3,508 PSP agents were registered in France, a decrease of 20% compared to 2023 and almost 70% compared to 2022¹. This contraction reflects a tightening of the regulator’s requirements for platforms.
This increased requirement is effectively manifested from the registration process, which follows a procedure rigorously supervised by the regulator :
Step 1 : Preparation and presentation of the file
This step is decisive: the file must allow the ACPR to assess the credibility and solidity of the project. It includes in particular :
- the description of the economic model and the services provided,
- the statutes, organizational charts, shareholding,
- recent legal and financial documents,
- information on managers,
- and activity projections (flow, volume of merchants, types of operations).
This phase often involves back and forth between the platform and the PSP to ensure the compliance of the file before its official submission.
Step 2 : Instruction by the ACPR
Once the application has been submitted, the ACPR begins an investigation. It verifies, in particular, the overall coherence of the project, the competence of the management, the robustness of the monitoring system and the technical/operational capacity to manage flows.
Requests for clarification are often addressed by the regulator. The first requests are generally made within 30 days, although the deadline can extend to two months. Please note that all communications are made through the approved institution, the sole point of contact for the ACPR.
Step 3 : Public Registration
If the assessment is positive, the platform is officially registered as a payment service provider. Its name is then published in the
From this validation, the platform can legally exercise its activity as a PSPS Agent, under the supervision of its partner establishment.
We note that the success, but also the speed of ACPR registration often depends on the good structuring of the agent’s organization – Natacha Pedroso
DSP3, a new era of demands for agents
The European Union is preparing the DPS3 and the Payment Services Regulation (PSR), which will replace the DSP2 in the coming years. These texts will :
- restrict exemptions (in particular that of commercial agent),
- strengthen governance and audit requirements,
- harmonize registration conditions across Europe,
- intensify cross-border supervision.
For platforms, this means it will be even more important to choose a strong accredited partner and build a sustainable compliance model.
Become a Payment Service Provider Agent with CentralPay
Becoming a PSP agent means accepting a regulated and demanding role. Our experience has taught us that the most successful projects are those that anticipate this reality from the outset, with clear governance, trained teams, and a strong, trusting relationship with their PSP partner.
It’s a combination of commercial ambition and regulatory rigor.
Learn more ➜
Are you exploring this topic for your platform or marketplace? Are you considering becoming a Payment Service Provider Agent? Our teams will assist you in structuring your application.
¹ACPR, Annual Reports (2022, 2023 and 2024)
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