The EBA report examines the use of the 'white labelling' model for the distribution of banking and payment services in the EU. This model, which allows financial institutions to offer products under a partner's brand, is adopted by 35% of the surveyed banks. While it provides benefits in terms of efficiency and financial inclusion, it also poses risks such as fraud and a lack of transparency for consumers.
This report entitled "Report on white labelling" was published in 2025 by the European Banking Authority (EBA). It addresses the distribution model of financial products and services called "white labelling" in the European Union. The scope covers banking and payment services, including consumers, SMEs, and financial and non-financial actors, over a recent period up to 2025 (p. 1-2, 5-6).
The subject addressed is the evolution of the "white labelling" distribution model in banking and payment services in Europe. This model consists of the provision by a financial institution (the provider) of products and services distributed under the brand of a partner, who may or may not be regulated (p. 5). This subject is important because 35% of banks surveyed in 2025 use this model, which applies to a wide range of products (accounts, BNPL credits, open banking services) and mainly targets consumers and SMEs (p. 5-6, 10-11, 13-14). The main findings are that white labelling offers benefits in terms of cost efficiency, offer expansion, financial inclusion, and competitiveness, but also presents risks: lack of transparency for clients, fraud risks, supervisory difficulties, operational and reputational risks for actors (p. 5-6, 14-22). The EBA does not identify a need to amend European legislation but emphasizes the need for convergence of supervisory practices, notably on the regulatory qualification of relationships between providers and partners, and on consumer awareness (p. 6, 23-25, 26-28). It plans actions in 2026 to strengthen supervision and consumer protection, as well as continuous monitoring via its risk questionnaires (p. 6, 27-28).
The EBA's mission is to monitor developments in the financial market, notably technological innovations and new distribution models. In this context, white labelling has been identified as a key topic in the 2024-2025 priorities related to innovative applications (p. 7). The report aims to better understand this model, to provide a state of play in the EU, to analyze opportunities and risks for stakeholders (consumers, providers, partners, supervisors), and to propose measures to improve supervision and consumer protection (p. 7). The methodology is based on a survey of national supervisory authorities (23 NCAs), a workshop with market actors and consumer associations, risk questionnaires to banks, and a documentary review (p. 8). Limitations concern the qualitative nature of the analysis, due to lack of systematic data and diversity of arrangements (p. 8).
Definition and landscape of white labelling: White labelling is a model where a financial provider offers products distributed under the brand of a partner, who may be regulated or not. This model is widespread, used by 35% of banks surveyed, and extends to a wide range of products (accounts, payments, BNPL credits, open banking) with a growing cross-border dimension (p. 6-10, 13-14).
Key characteristics: Seven characteristics determine the arrangements: the regulatory status of parties (provider often a financial institution, partner sometimes non-financial), the nature of white labelling (main or ancillary activity), the products distributed, the targeted clientele (consumers, SMEs, companies), the geographic scope (domestic or cross-border), task allocation (the provider assumes regulatory compliance and back-office functions, the partner often manages client relationship and marketing), and the pricing model (fixed and variable fees) (p. 10-16, 22).
Opportunities: White labelling allows better cost efficiency, a broadened offer, more precise client targeting, increased customer base, and facilitates providers’ digital transformation. It can also promote financial inclusion by serving excluded populations and stimulate competition by lowering entry barriers for partners (p. 16-18).
Risks and challenges for consumers: Lack of transparency on roles and responsibilities, complexity of information, risks of misinformation and inappropriate sales, increased fraud risks linked to opacity and weak KYC controls, difficulties for consumers to file claims, risks related to personal data protection, and potential financial exclusion of populations less familiar with digital technology (p. 18-21).
Risks for providers and partners: Risks related to the business model (mutual dependence), operational risks (complexity, management of technical interfaces), reputational risks (impact of failures by the other party), loss of direct client relationship, and challenges in regulatory compliance, notably AML/CFT, with data and procedure fragmentation, and increased complexity in cross-border activity (p. 21-23).
Risks and challenges for supervisors: Difficulties in identifying and qualifying white labelling arrangements, opacity of relationships between parties, unreliable cross-border notifications, absence of direct supervision over some non-regulated partners, and fragmentation of responsibilities among national authorities, complicating risk monitoring and systemic risk management (p. 23-25).
AML/CFT aspects: The report details the application modalities of AML/CFT obligations depending on whether the arrangement is outsourcing or a trusted third party, with clear responsibilities for the provider, and highlights challenges related to access to KYC data and monitoring ML/TF risks (p. 27-30).
Summary of opportunities and risks by actor type: The report summarizes benefits (efficiency, offer, inclusion, revenues, innovation) and risks (misinformation, fraud, exclusion, operational and reputational risks, compliance) for consumers, providers, and partners (p. 31).
Established facts: White labelling is a widespread model in the EU, used by 35% of banks surveyed, covering a wide range of financial products distributed to consumers and SMEs, with a growing cross-border dimension. Partners can be financial or non-financial entities, including digital platforms and BigTechs (p. 6-11, 13-14).
Assumptions: The report assumes that white labelling will continue to develop, notably with the integration of crypto-asset related services and the future implementation of the FIDAR framework for access to financial data (p. 9, 17).
Interpretations: White labelling presents economic and inclusion advantages, but the increased complexity of the model generates risks for consumers (transparency, fraud), for actors (business model, compliance), and for supervisors (opacity, fragmentation). National differences in regulatory qualification complicate supervision and may generate systemic risks (p. 14-25, 41-47).
Uncertainties: The diversity of arrangements, lack of systematic quantitative data, and ongoing regulatory developments (notably FIDAR and AMLR) make precise risk assessment difficult. The impact of BigTechs and new non-financial actors remains to be monitored (p. 8, 10, 17, 23-25).
The EBA concludes that white labelling is a widely used and evolving model, bringing benefits but also significant risks for consumers, actors, and supervision (p. 41-43). It does not identify legislative gaps requiring amendment of European law but stresses the need for convergence of supervisory practices, notably on the regulatory qualification of relationships between providers and partners, and on transparency towards consumers (p. 47-48).
The EBA plans actions in 2026 aimed at facilitating dialogue between national authorities, promoting better understanding of arrangements and risks, and integrating white labelling into strategic supervisory priorities (p. 48-49). It provides a common questionnaire to assist supervisors in their controls (p. 49).
On consumer protection, the EBA wishes to strengthen information and awareness measures so that clients clearly understand with whom they contract and how to exercise their rights (p. 49-50). Finally, the EBA will continue to monitor the model’s evolution through its regular surveys (p. 50).
Synthesis note written from the full document by DataSAI Academy. This note comes from the scientific library of the DataSAI Academy, open to all.