Safeguarding
The legal requirement for EMIs and PIs to protect customer funds by segregating them at a credit institution (or insuring them) - distinct from deposit protection.
E-money balances are not bank deposits: they are covered by safeguarding, not by the 100k EUR deposit guarantee. The institution must hold customer funds segregated at a bank (or insure them) so they survive its insolvency.
Where those safeguarding accounts sit is a real sovereignty question - an EEA EMI safeguarding at an EEA bank keeps the chain inside EU jurisdiction. Provider failures (Wirecard) are exactly why the catalogue tracks status and risk alongside the licence.
Primary source: Directive (EU) 2015/2366 (PSD2) · Directive 2009/110/EC (E-Money Directive)
In the verified data
- Among the 78 live IBAN sponsors and BaaS providers in the catalogue, 11 hold client money as bank deposits (guaranteed up to EUR 100,000 per depositor) and 51 as e-money or payment-institution funds that are safeguarded, not guaranteed - each profile states which.
- 10 providers in the catalogue are recorded as no longer operating; the Radar lists them next to the live risk and watch flags.
Recomputed from the catalogue and the official EBA, ESMA and FCA registers on every build — how we verify.
Questions to ask a provider
- Do you safeguard by segregation or by insurance or guarantee, and at which credit institutions?
- How often are safeguarded balances reconciled, and does an external auditor review it?
- What is the documented process for returning client funds if you become insolvent?