EBA publishes report on white labelling for banking and payments services in the EU

The European Banking Authority (EBA) has published a report on white labelling, accompanied by a fact sheet. In the report, the EBA considers the use of white labelling as a business model by the firms that are under its mandate, including credit institutions, e-money institutions, payment institutions, non-bank issuers of asset-referenced tokens and non-bank lenders. The report defines white labelling as a business model in which a financial institution (the provider) enters into an agreement with another entity (the partner, who may or may not be a financial institution) to distribute and offer one or more financial products and services under the partner's own brand only. The EBA finds that white labelling is being widely used, with 35% of surveyed banks employing the model to distribute a broad range of financial products and services, both domestically and cross-border, including account and payment services, credit provisioning and open banking services.

The EBA identifies several benefits of white labelling such as cost efficiency and enhancing financial inclusion but also flags key risks including potential mis-selling, fraud risk, weaknesses in anti-money laundering and countering the financing of terrorism controls, and a lack of transparency towards consumers as to precisely with whom they are contracting. While the EBA does not propose amendments to EU law, it has identified a need for supervisory convergence actions which the EBA plans to take forward in 2026, in particular as regards the regulatory qualification of the arrangements between the parties and the assessment and identification of emerging risks. Regarding consumer protection, the EBA intends to focus on appropriate measures to facilitate awareness by consumers of the key elements relating to white labelling. In addition, the EBA will continue assessing the evolution of banks' engagement in white labelling via its regular Risk Assessment Questionnaire (RAQ) and wider innovation monitoring.

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