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Banking-as-a-Service Strategic Proposal

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© 2026 Talar Innovation Group | Confidential

Strategic Proposal

Banking-as-a-Service for Rapid Market Entry

Our Recommended Path to Launch Your Digital Banking Platform in 3 Months

Prepared by Talar Innovation Group

3 Months

To Market Launch

€30K-70K

Total Investment

95%+

Cost Savings

CONFIDENTIAL

May 2026 | Proposal v2.0

Executive Recommendation

Our Strategic Recommendation

We Recommend: Banking-as-a-Service Partnership

To enter the digital banking market in the fastest, most capital-efficient manner possible, we strongly recommend partnering with a Banking-as-a-Service (BaaS) provider rather than pursuing independent licensing.

Through Banking-as-a-Service, you gain immediate access to regulated banking infrastructure—payment processing, account management, card issuance, and full compliance frameworks—without the prohibitive cost, time investment, or regulatory burden of obtaining your own banking license.

❌ Independent Licensing (Not Recommended)

  • €1.1M-€1.9M first-year investment
  • 18-24 months before serving first customer
  • • High regulatory and application rejection risk
  • • Requires dedicated compliance team from day one
  • • Capital burned before validating market fit

✅ BaaS Partnership (Recommended)

  • €30K-€70K to fully launch
  • 2-3 months to serving customers
  • • Inherited compliance and regulatory coverage
  • • Focus 100% on product and customer acquisition
  • • Capital preserved for growth and iteration

Key Definitions

Understanding the fundamental concepts and terminology

Banking-as-a-Service (BaaS)

A regulatory and technological framework where licensed financial institutions provide banking infrastructure (accounts, payments, cards, compliance) as a service via APIs to third-party companies.

EMI (Electronic Money Institution)

A regulated entity under EU E-Money Directive 2009/110/EC authorized to issue electronic money, process payments, and operate payment accounts. Does not permit deposit-taking or lending without additional licensing.

API (Application Programming Interface)

Software interfaces enabling different applications to communicate. In BaaS, APIs allow companies to integrate banking services (account creation, payments, KYC) into their own products without building the underlying infrastructure.

KYC/AML (Know Your Customer / Anti-Money Laundering)

Regulatory compliance processes requiring financial institutions to verify customer identities and monitor transactions to prevent money laundering, terrorist financing, and financial crime.

PSD2 (Payment Services Directive 2)

EU regulation governing payment services, enabling open banking and requiring Strong Customer Authentication (SCA) for electronic payments. Critical compliance requirement for European financial services.

SEPA (Single Euro Payments Area)

Payment integration initiative across EU/EEA countries enabling euro transfers, direct debits, and card payments under unified rules. Essential for European banking operations.

Market Context & Transformation

The global BaaS market has experienced exponential growth, projected to reach $74 billion by 2030 (compound annual growth rate of 17.1%). This growth is driven by three converging forces:

1

Consumer Expectation Evolution

Modern consumers expect financial services embedded seamlessly within their digital experiences—from paying within apps to receiving instant payouts from gig platforms.

2

Regulatory Modernization

Open Banking directives (PSD2 in Europe), real-time payment infrastructure (FedNow, Faster Payments), and updated licensing frameworks have created the regulatory foundation enabling BaaS proliferation.

3

Technological Maturation

Cloud computing, API-first architectures, advanced identity verification, and sophisticated fraud detection have made it technically feasible to unbundle and deliver banking services as modular components.

90-95%

Lower Initial Investment vs. Independent Licensing

2-3

Months Typical Time to Market with BaaS

18-24

Months Required for EMI License Application

The Capital Efficiency Advantage

Deploying the "Saved Capital" for Competitive Advantage

The independent licensing route requires burning €1.1M - €1.9M on legal fees, regulatory capital requirements, and idle compliance teams before you ever test your product in the market.

By choosing the BaaS route with Talar Innovation Group, you effectively preserve over €1.5M in runway. This is not merely a cost-saving measure; it is a strategic growth advantage.

How to Deploy Your Preserved Capital

€500K-800K

User Acquisition

  • • Performance marketing campaigns
  • • Referral bonus programs
  • • Strategic partnership deals
  • • Launch incentives & promotions

€300K-500K

Product Iteration

  • • A/B testing infrastructure
  • • Enhanced UX/UI development
  • • Feature expansion based on feedback
  • • Mobile app optimization

€200K-400K

Team Expansion

  • • Customer success managers
  • • Growth marketing specialists
  • • Additional engineering capacity
  • • Data analytics team

Our approach allows you to capture market share, build brand loyalty, and generate revenue while your competitors are still waiting for regulatory paperwork to clear.

Real-World Success: The BaaS Playbook

This approach has been validated by every major fintech success story

Companies That Launched via BaaS First

Revolut, N26, Chime

All launched via BaaS partnerships before eventually securing their own licenses

Stripe Treasury, Shopify Balance

Billion-dollar financial products built entirely on BaaS infrastructure

Square, Uber, Lyft

Embedded financial services via BaaS infrastructure

The Proven Strategy

These companies achieved scale and market validation first, then made licensing decisions from a position of strength—not desperation.

Phase 1

Launch via BaaS & validate market

Phase 2

Scale to millions of users

Phase 3

Obtain own license from position of strength

Strategic Justification

Comprehensive comparison: Independent Licensing vs. BaaS Partnership

Path A: Independent EMI Licensing

Electronic Money Institution (EMI) License

Regulated under EU E-Money Directive 2009/110/EC

Cost Component Investment
Regulatory Capital€350,000
Legal & Consulting€150K-€250K
Compliance Systems€100K-€200K
Core Banking Platform€200K-€500K
Personnel (12 months)€300K-€600K
First-Year Total €1.1M-€1.9M

Timeline: 18-24 Months

High regulatory risk, no market validation, capital burned before first customer

Path B: BaaS Partnership ✅

Leverage Existing Infrastructure

API integration with licensed financial institutions

Cost Component Investment
Setup & Integration€10K-€50K
Monthly Platform Fee€1K-€5K/mo
Transaction Fees0.5%-2.0%
Development (3 months)€20,000
Total to Launch €30K-€70K

Timeline: 2-3 Months

95%+ cost savings, inherited compliance, immediate market entry

BaaS Limitations & Considerations

Important constraints and restrictions you should understand

⚠️ Full Transparency

While BaaS enables rapid launch and massive cost savings, it comes with operational limitations. Understanding these constraints upfront ensures you can design your product within these boundaries.

💰

Account Balance Limits

Per-account maximum balances

Typical Limits by Provider:

  • Basic KYC: €10,000 - €15,000 per account
  • Enhanced KYC: €50,000 - €100,000 per account
  • Business Accounts: €150,000 - €250,000

Impact: Not suitable for high-net-worth individuals or large business treasury management without multiple account structures. Corporate clients may need multi-account architectures.

📊

Transaction Limits

Daily and monthly caps

Common Restrictions:

  • Daily limits: €5,000 - €20,000 per day
  • Monthly limits: €50,000 - €100,000 per month
  • Single transaction: €2,000 - €10,000 max

Impact: May require higher-tier KYC verification for power users or business customers who process large volumes daily.

🚫

Product Restrictions

Features you cannot offer

Typically NOT Available via BaaS:

  • • Lending products (loans, credit lines)
  • • Investment accounts (stocks, bonds, crypto custody)
  • • Interest-bearing savings accounts (in some jurisdictions)
  • • Direct debit initiation (varies by provider)

Impact: If your business model requires lending or investment features, you'll need additional licensing or partner integrations beyond base BaaS.

🌍

Geographic Coverage

Licensed regions only

Coverage Constraints:

  • US providers: US-only operations (no EU/UK)
  • EU providers: EEA passporting only
  • Cross-border: Requires multi-provider strategy
  • Emerging markets: Limited or no BaaS availability

Impact: Multi-region expansion requires integrating multiple BaaS providers (Unit for US, Swan for EU, etc.) with added complexity.

⚙️

Provider Dependency Risk

Third-party infrastructure reliance

Risks to Consider:

  • • Provider downtime affects your platform
  • • Pricing changes (you don't control fee structure)
  • • Feature roadmap dependency
  • • Provider exits market (rare but possible)

Mitigation: TIG designs your system with provider abstraction layers, enabling you to switch providers with minimal disruption (see Slide 15: Risk Mitigation).

⚖️

You Still Own Compliance

Shared responsibility model

Your Responsibilities:

  • • Tier-1 KYC collection and verification
  • • Customer due diligence (CDD)
  • • Suspicious activity reporting to provider
  • • Marketing compliance (no misleading claims)

Impact: You cannot be careless about compliance. Provider handles Tier-2 regulatory reporting, but you're responsible for customer-facing compliance processes.

How TIG Helps Navigate These Limitations

✓ Provider Selection Guidance

We match your use case to providers with the right limits and features for your target customers.

✓ Multi-Account Architectures

For high-value customers, we design compliant multi-account structures that work within balance limits.

✓ Provider Abstraction Layer

Our architecture allows you to switch providers or add redundancy without rebuilding your app.

✓ Compliance UX Design

We build intuitive KYC flows that meet requirements while maintaining great user experience.

Bottom Line: These limitations are manageable and expected trade-offs for the 95% cost savings and 3-month launch timeline. For most early-stage fintechs, these constraints are not deal-breakers—they're simply design parameters to work within.

Revenue Modeling & Unit Economics

Three scalable revenue streams from day one

1. Interchange Revenue

Earn percentage of merchant fees every time customers use your branded card.

Your Share

0.3% - 0.8%

After BaaS provider cut

Example: 10K cards × €500/mo spend × 0.5% = €25K/month

2. Subscription Tiers

Freemium or premium account models with differentiated features.

Free: €0/mo

Premium: €9.99/mo

Business: €29.99/mo

80-90% gross margins

3. Transaction Fees

Value-added services: FX, cross-border, instant withdrawals.

FX Markup1.5-3.0%
Instant Withdrawal€0.50-€2
ATM Fee€1.50-€3.50
Cross-border0.5-1.5%

Path to Profitability

Metric Month 3 Month 12 Month 24
Active Users2,50015,00050,000
Premium Conversion8%15%20%
Total Monthly Revenue €8,500 €83,250 €360,000
Operating Costs€25,000€45,000€120,000
Net Profit/Loss -€16,500 +€38,250 +€240,000

Why Partner with Talar Innovation Group?

Navigating the BaaS ecosystem requires specialized technical and strategic expertise. Talar Innovation Group serves as your dedicated integration partner and technical project manager, bridging the gap between your business vision and the complex API frameworks of global banking providers.

What We Do Differently

  • We sit on your side of the table. Unlike consultants who introduce you to providers and disappear, we actively negotiate contracts and ensure terms favor your long-term interests.
  • We manage the technical build-out end-to-end. From API architecture to webhook handling, we handle the complex integration work.
  • We ensure flawless execution within the 3-month timeline. Proven methodology with daily sprint management and parallel workstream coordination.

Core Value Proposition

Provider Selection Expertise

We've evaluated dozens of BaaS providers. We know which overpromise, which have hidden fees, and which deliver.

Technical Integration Mastery

Built banking integrations across Unit, Swan, Marqeta, Solaris. We understand their API quirks intimately.

Future-Proof Architecture

Provider abstraction ensures you're never locked into a single vendor. Switching providers is seamless.

The TIG Advantage in Numbers

12+

BaaS Platforms Evaluated

30+

Successful Integrations

3 Mo

Average Time to Launch

Zero

Failed Launches

Recommended BaaS Providers

Six leading platforms evaluated across geography, features, and time-to-market

🇺🇸 Unit

US Market Leader

Industry-leading BaaS platform for US markets with best-in-class developer experience and fastest time-to-market.

Strengths:

  • • Best-in-class developer experience
  • • Comprehensive features: deposits, cards, credit, ACH, wires
  • • Proven scale: billions in monthly volume
  • • 6-8 weeks to production

Optimal For: US fintechs, vertical SaaS, gig economy platforms

🇪🇺 Swan

EU Compliant-by-Default

French EMI-licensed platform specializing in European embedded finance with automatic compliance handling.

Strengths:

  • • EU compliance automation: SEPA, PSD2, GDPR
  • • Modern GraphQL API with real-time webhooks
  • • Transparent pricing, startup-friendly
  • • 4-8 weeks to launch

Optimal For: European startups, B2B SaaS, marketplace platforms

🌍 Gemba

Embedded Banking

Next-generation "BaaS 2.0" platform with AI-powered compliance and developer-centric design.

Strengths:

  • • 48-hour integration for basic use cases
  • • AI compliance: automated KYC/AML decisioning
  • • Comprehensive SDKs and documentation
  • • Transparent pricing structure

Optimal For: Marketplaces, SaaS platforms, early-stage fintechs

💳 Marqeta

Card Specialist

Undisputed leader in modern card issuing infrastructure with real-time authorization and granular control.

Strengths:

  • • Real-time decisioning with custom logic
  • • Granular controls: per-card limits, MCC restrictions
  • • Virtual card mastery for e-commerce/gig economy
  • • Proven at massive scale (billions in transactions)

Optimal For: Card-first products, expense management, gig platforms

🇩🇪 Solaris

EU Full-Stack Bank

German-licensed full-stack bank pioneering European BaaS. Unlike middleware providers, Solaris's banking license enables deep financial services including lending and asset management.

Strengths:

  • • Full bank license: deposit insurance, credit, custody services
  • • EU regulatory mastery: Deep GDPR, PSD2, cross-border expertise
  • • Lending capabilities: credit cards, BNPL, personal loans
  • • Complete white-label: Fully branded experience
  • • Proven track record: Powers major European fintechs

Optimal For: European neobanks, investment platforms, lending fintechs requiring full banking capabilities

🏦 Treasury Prime

Multi-Bank Network

Unique multi-bank network model providing optionality and redundancy. Treasury Prime connects to multiple banks, offering failover capability and best-of-breed selection.

Strengths:

  • • Multi-bank redundancy: Failover protection from bank downtime
  • • Best-of-breed: Select optimal banks for specific products
  • • Negotiating leverage: Multiple options improve pricing power
  • • Unified API: Single integration despite multiple banks
  • • Comprehensive services: Accounts, cards, ACH, wires, checks

Optimal For: Enterprise fintechs requiring redundancy, multi-product platforms, risk-conscious organizations

All providers offer robust APIs, compliance coverage, and proven scale. Selection depends on your target geography, product requirements, and timeline priorities.

Shared Responsibility Matrix

Clear ownership across three pillars: Provider, Your Company, and TIG

1

BaaS Provider

Infrastructure & Regulation

  • • Core Banking Ledger

    Full custody of funds, balances, transaction records

  • • Regulatory Umbrella

    EMI/Payment Institution license

  • • Tier-2 Compliance

    Transaction monitoring, regulatory reporting

  • • Payment Networks

    Visa/Mastercard, SEPA, ACH relationships

  • • Card Issuance

    Physical/virtual card production, BIN sponsorship

  • • Safeguarding & Audits

    Customer fund protection and segregation

2

Your Company

Brand & Customer Ownership

  • • Brand & UX

    Full ownership of app design and customer experience

  • • Customer Relationships

    Direct relationship ownership (your users, not provider's)

  • • Tier-1 Support

    Front-line customer service via your channels

  • • Marketing & Acquisition

    All growth campaigns and user acquisition

  • • Initial KYC Collection

    Collect documents via app flow for provider approval

  • • Product Roadmap

    Feature planning and differentiation strategy

  • • Data Ownership

    Customer contact info and behavioral data

3

TIG

Integration & Advisory

  • • API Architecture

    Bridge connecting your app to BaaS provider

  • • Vendor Selection

    RFP management and contract negotiation

  • • Integration Roadmap

    Sprint planning to hit 3-month go-live

  • • Workflow Automation

    Secure data pipelines between app and provider

  • • Webhook Handling

    Real-time event synchronization

  • • Security Architecture

    GDPR, PSD2, PCI DSS compliance

  • • Provider Abstraction

    Switch providers without rebuilding app

  • • Post-Launch Support

    Ongoing troubleshooting and optimization

This clear division enables the 3-month launch timeline while ensuring you own the customer relationship and brand equity.

3-Month Implementation Roadmap

Aggressive, phased approach maximizing speed without compromising quality

Month 1: Selection & Planning

Phase 1

Key Milestones

  • • Provider RFP evaluation (3-5 candidates)
  • • Contract negotiation and MSA finalization
  • • KYB compliance review completion
  • • Sandbox environment access secured
  • • Technical architecture design
  • • UI/UX wireframes completed

Team Requirements

CEO (contract approval), CFO (pricing), CTO (technical evaluation), Legal, Product Manager, Designer

Critical Success Factor

Move fast on decision-making; delays cascade through entire timeline

Month 2: Technical Integration

Phase 2

Engineering Deliverables

  • • Authentication & session management
  • • KYC/identity verification integration
  • • Account creation & funding flows
  • • Payment initiation (ACH/SEPA/cards)
  • • Card issuance (physical/virtual)
  • • Transaction history & statements
  • • Webhook event handling
  • • Admin dashboard & support tools

Velocity Focus

  • • Use provider SDKs to accelerate integration
  • • Build MVP feature set first
  • • Daily standups to unblock issues fast
  • • Test continuously in sandbox

Team

Frontend (×2), Backend (×2-3), Product Manager, Designer in parallel sprints

Month 3: Testing & Launch

Phase 3

QA & Security

  • • End-to-end regression testing
  • • Security audit & penetration testing
  • • Load testing (10× expected traffic)
  • • Provider compliance review
  • • AML/KYC validation
  • • Disaster recovery planning

Launch Sequence

  • Week 1: Internal beta (20-50 users)
  • Week 2: External beta (100-500 users)
  • Week 3: App store submission
  • Week 4: Public launch & 24/7 monitoring

Critical Note

Compressed timeline requires parallel workstreams. Do not skip security steps.

Phase 2: Long-Term Scale Strategy

Planning for sustainable growth and eventual licensing optionality

BaaS is your launch strategy, not your forever strategy. As you scale over 24-36 months, there comes a point where the transaction-based fees paid to your BaaS provider may exceed the cost of operating your own EMI license.

This analysis shows the realistic growth trajectory of a fintech startup starting from zero and when own-license economics become favorable.

Realistic Growth Trajectory: When Does Own License Make Sense?

Based on typical fintech startup growth rates starting from zero customers:

Timeline Monthly Volume BaaS Fees (1.5%) Own License Cost Verdict
Months 3-12€0.5M-€2M€7.5K-€30K/mo€200K/mo✓ Stay on BaaS
Year 2€5M-€10M€75K-€150K/mo€200K/mo✓ Stay on BaaS
Year 3€15M-€25M€225K-€375K/mo€220K/mo⚠ Evaluate License
Year 4+€30M+€450K+/mo€240K/mo✓ Own License Favorable

Note: "Own License Cost" includes compliance staff, systems, audits, and regulatory capital. Most startups reach breakeven volumes in years 3-4, not months.

Why Wait Until Year 3-4?

At earlier stages, BaaS fees are dramatically cheaper than maintaining your own compliance team, regulatory capital, and banking infrastructure. Focus capital on growth, not overhead.

Product Flexibility Benefits

Once you have your own license: launch lending products, investment accounts, direct SEPA membership, custom fraud rules—features some BaaS providers restrict.

Valuation Premium

Investors and acquirers value companies with their own banking license 2-3× higher due to reduced vendor dependency and full infrastructure control.

TIG's Role in Phase 2 (Technical Migration Only)

Important Clarification: Talar Innovation Group is a software development and technical consulting partner. We do NOT handle regulatory licensing applications, legal submissions, or compliance advisory—that requires specialized financial regulatory consultants.

Phase 1:

License Application (You + Regulatory Consultants)

You engage specialized regulatory/legal consultants to handle EMI application, capital requirements, and regulatory interviews. TIG is NOT involved in this phase—this is outside our scope as a software company.

Phase 2:

Parallel Infrastructure Build (TIG's Role)

TIG builds your own core banking ledger, payment network integrations, and migration architecture in parallel with your BaaS operations. Zero customer downtime during this technical buildout.

Phase 3:

Seamless Technical Migration (TIG's Role)

TIG executes the technical migration: accounts, balances, transaction history transfer from BaaS provider's ledger to your own infrastructure. Customers see no change to their app experience.

Bottom Line: TIG handles the technical aspects of migration. Regulatory/licensing work must be handled by certified financial services legal and compliance advisors.

Provider Risk Mitigation & Data Ownership

Three-layer strategy designed for provider independence

Layer 1: You Own the Customer

We ensure that you own your front-end application, the customer data, and the user interface. Your BaaS provider handles backend ledger operations, but they never touch your customer relationships.

Customer Contact Data

Email, phone, address lives in your database, not the provider's.

Marketing Consent

Behavioral data yours to use for retention campaigns and improvements.

Brand Loyalty

If you switch providers, customers never know—they only see your brand.

Layer 2: API Abstraction Layer

We design your system with an "abstraction layer" that sits between your application logic and the BaaS provider's APIs. This architectural pattern means:

  • Provider-agnostic code: Your front-end calls generic functions like createAccount() or initiatePayment(), which TIG's abstraction layer translates into the specific API calls required.
  • Plug-and-play providers: If your BaaS provider changes pricing or faces issues, TIG can detach their APIs and plug in a new provider (Unit, Swan, Gemba, etc.) in the background.
  • Zero customer impact: Your customers experience no change to their app interface, login flows, or account access during a provider switch.

Technical Detail: We use a microservices architecture where the "Banking Service Layer" is completely decoupled from your "Application Layer." This future-proofs your platform against vendor lock-in.

Layer 3: Multi-Provider Redundancy (Optional)

For enterprise clients, we can architect a multi-provider setup where your platform integrates with two BaaS providers simultaneously (e.g., Unit for US, Swan for EU).

Geographic Failover

If one provider experiences downtime, auto-route through secondary provider.

Negotiating Leverage

Renegotiate pricing and terms from a position of strength.

Best-of-Breed

Use Provider A for cards, Provider B for SEPA—whichever excels at each function.

Note: Multi-provider setups increase complexity. We recommend this only for platforms processing €20M+ monthly volume.

Your brand equity remains completely protected. You are never hostage to a single vendor.

Recommended Next Steps

Your action plan to launch within 3 months

1

Provider Shortlist (Weeks 1-2)

Prepare RFP for 3-4 BaaS providers based on target markets. TIG can facilitate introductions and negotiation support.

Recommended: Unit (US), Swan (EU), Gemba (multi-region), Marqeta (cards)

2

Contract Negotiation (Weeks 3-4)

Evaluate technical documentation, conduct sandbox testing, negotiate commercial terms. Focus on 3-year TCO.

Key points: Volume-based pricing, SLAs, geographic expansion, exit provisions

3

Team Assembly & Planning (Month 2)

Secure development resources and complete provider onboarding. Begin technical integration.

Required: 2-3 Backend Engineers, 2 Frontend Developers, Product Manager, Designer

4

Development & Testing (Months 2-3)

TIG executes technical integration, conducts security audits, obtains provider compliance sign-off.

5

Beta Launch & Go-Live (Month 3)

Compressed rollout from internal beta to public launch with intensive monitoring and optimization.

Investment Required

Setup & Platform

€10K-50K

Development Team

€20K

Total to Launch

€30K-70K

Ready to Begin?

Talar Innovation Group is prepared to move immediately on provider introductions, RFP preparation, and technical integration to hit your 3-month launch deadline.

Your success will be determined by deeply understanding customer needs, building a product they love, and executing with precision.

95%+

Cost Savings

3 Months

To Market Launch

Zero

Regulatory Risk

Legal Disclaimer

This report is provided for educational and informational purposes only and does not constitute legal, financial, or regulatory advice. Before making decisions about pursuing a banking license, selecting a BaaS provider, or launching financial products, consult qualified legal counsel specializing in financial regulation in your target jurisdiction(s).

Digital Banking Platform: Strategic Proposal

BaaS Partnership for Rapid Market Entry | Confidential

Talar Innovation Group | May 2026 | Proposal v2.0