Regulatory, ASF and BNR
Financial and payments
authorisations.
Beyond gaming, Romania has three financial-sector regulators. ASF for capital markets and asset management, BNR for banking and payments, ONPCSB for AML. The licences are passportable across the EEA where the underlying directive permits.
We manage the full pipeline. Entity and capital structuring, compliance framework drafting, fit-and-proper documentation, regulatory submission, and the maintenance that follows.
Authorisations
Eight categories.
Three regulators.
Pick the closest match. We confirm the exact category, regulator, and capital schedule for your business model in the scoping memorandum.
ASF
Investment firm (S.S.I.F.)
Romanian investment firms (Societate de Servicii de Investiții Financiare) provide investment services under MiFID II , reception and transmission of orders, execution, dealing on own account, portfolio management, investment advice, and underwriting. Authorised by ASF, passportable across the EU.
- Min. capital
- Tiered: €50K – €730K depending on services and dealing on own account
- Timeline
- 4–6 months
ASF
Alternative Investment Fund Manager (AIFM)
ASF authorises managers of alternative investment funds , private equity, venture capital, real estate, debt, and hedge funds , under Romania's transposition of the AIFMD. Sub-threshold AIFMs benefit from a lighter registration regime.
- Min. capital
- €125,000 (full-scope AIFM); registration only for sub-threshold managers
- Timeline
- 4–6 months
ASF
UCITS management company
Authorisation for management companies of Romanian UCITS retail funds. Includes the depositary arrangement with a Romanian credit institution and the prospectus approval cycle.
- Min. capital
- €125,000 + 0.02% of AUM above €250m
- Timeline
- 5–7 months
BNR
Payment institution (PSD2)
Authorised by Banca Națională a României under Romania's transposition of PSD2. Covers payment initiation, account information, money remittance, card-issuing, and merchant acquiring services. Passportable across the EEA.
- Min. capital
- €20K – €125K depending on services (e.g. €20K money remittance, €50K payment initiation, €125K acquiring)
- Timeline
- 3–5 months
BNR
Electronic Money Institution (EMI)
BNR-authorised issuers of e-money. EMIs may also provide unrelated payment services. Subject to safeguarding requirements and ongoing prudential supervision.
- Min. capital
- €350,000 minimum capital
- Timeline
- 4–6 months
ASF / BNR
Crypto-asset Service Provider (CASP , MiCA)
Under MiCA, CASPs operating in Romania require authorisation for services such as custody, exchange of crypto-assets for fiat or other crypto-assets, execution of orders, placement, transfer services, and portfolio management on crypto-assets. ASF is the lead Romanian competent authority.
- Min. capital
- €50K – €150K depending on the services rendered
- Timeline
- 4–6 months
BNR
Non-banking financial institution (IFN)
BNR-supervised non-bank lenders, leasing companies, factoring firms, and consumer credit providers. Registered or authorised depending on activity scale and class.
- Min. capital
- Varies by IFN class (consumer credit, mortgage, factoring, leasing)
- Timeline
- 3–5 months
ASF
Insurance / reinsurance intermediary
ASF registers insurance brokers, ancillary insurance intermediaries, and reinsurance brokers under the IDD framework. Distinct from full insurance carrier authorisation.
- Min. capital
- Professional indemnity and capital adequacy thresholds (no minimum capital floor)
- Timeline
- 2–3 months
Engagement
Six phases.
One advisor.
The same six-phase process applies across regulators. The depth of each phase , particularly compliance framework drafting and fit-and-proper documentation , varies by category.
- 01
Licence scoping memorandum
We confirm the correct regulator and authorisation category for your activity, map minimum capital and capital-adequacy expectations, identify cross-border passporting options, and provide a written feasibility view before any fees are committed.
- 02
Entity structuring & capital
Most regulators require a Romanian legal entity with the prescribed paid-up share capital deposited at a BNR-supervised credit institution. We coordinate the entity formation, capital deposit, and shareholder fit-and-proper documentation.
- 03
Compliance framework drafting
AML/KYC programme, risk management framework, internal audit charter, complaints procedure, outsourcing policy, business continuity plan. Drafted to the regulator's format expectations , not generic templates.
- 04
Fit-and-proper documentation
Directors and key function holders must demonstrate competence, integrity, and time commitment. We prepare CVs, declarations, criminal-record extracts, and brief candidates on expected interview topics with the regulator.
- 05
Application & regulatory dialogue
Submission to the competent authority (ASF, BNR, or ONPCSB) through the official channel. We manage all correspondence in Romanian, respond to requests for clarification, and coordinate any in-person meetings with the supervisor.
- 06
Ongoing regulatory maintenance
Authorisation triggers ongoing obligations , quarterly returns, annual audited financials, AML reporting, material change notifications. We offer a retained correspondent service to manage this for the life of the licence.
FAQ
Common questions.
Which Romanian regulator authorises which activity?
In broad terms: ASF authorises investment firms, fund managers, capital markets participants, insurance intermediaries, and (as Romanian competent authority) MiCA crypto-asset service providers. BNR authorises credit institutions, payment institutions (PSD2), e-money institutions, and non-banking financial institutions (IFN). ONPCSB supervises AML obligations across reporting entities. We confirm the correct regulator at the scoping stage.
Do these licences passport across the EU?
Most do. Investment firms (under MiFID II), AIFMs and UCITS managers (under their respective directives), payment institutions and EMIs (under PSD2), and CASPs (under MiCA) are passportable across the EEA following authorisation in Romania. Sub-threshold AIFMs and certain Romanian-only IFN categories do not passport. We map the passporting path for your specific activity at scoping.
What is the minimum capital requirement?
It varies sharply by category. A money-remittance-only payment institution requires €20K; a full-scope EMI requires €350K; a UCITS management company starts at €125K and scales with AUM. Investment firm capital depends on which MiFID services are offered and whether you deal on your own account. We confirm the exact figure for your scope in the scoping memorandum.
How long does authorisation take?
Realistic end-to-end timelines for non-gaming financial licences range from 3–6 months for payments and CASP authorisations to 5–7 months for fund-management and complex investment-firm authorisations. The timeline assumes a complete, well-structured submission. Incomplete submissions or substantive policy gaps add months.
Can I outsource compliance functions?
Most Romanian regulators allow outsourcing of operational compliance functions , internal audit, MLRO, IT , subject to a documented outsourcing policy and supervisor notification. The regulated firm retains ultimate responsibility. Material outsourcing of board-reserved functions is restricted. We advise on which functions can be outsourced for your authorisation type.
Do I need Romanian residents on the board?
Most authorisations require at least one director with effective day-to-day responsibility located in Romania. Some categories (e.g. EMIs, credit institutions) require two effective directors based in Romania. Non-resident shareholders are accepted; the residency requirement applies to executive management.
Considering a Romanian regulatory licence?
Send us your business model, target launch date, and intended scope of services. We respond within one business day with a written feasibility view and a fixed-scope proposal.
Book a 30-min scoping call