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KDI 경제교육·정보센터

ENG
  • 경제배움
  • Economic

    Information

    and Education

    Center

최신자료
Neo-conglomerates and EU regulatory perimeter challenges - state of play and evaluation of policy options
ECB
2026.10.12
- This paper examines the implications of the provision, in the European Union, of bank-like services, including payment services, by large non-bank groups (i.e. groups that do not comprise entities with a banking licence), and evaluates policy options to address the emergence of so-called neo-conglomerates by recalibrating the regulatory perimeter.

- Drawing on five EU case studies (a messaging app white-label arrangement, a complex multi-partner “super-app” model, a systemic payment group, a borderless financial technology firm (fintech) and a bank) - this paper illustrates how financial services may be delivered through digital unbundling and re-bundling, embedded distribution and white-label partnerships. It maps the business models, licensing structures, fintech partnership chains and data frictions that may obscure group-wide risks and complicate home-host supervisory cooperation. The cases were included for illustrative purposes only, and implying no judgement at all on the soundness or governance of the firms concerned, nor on the effectiveness or adequacy of the actions taken by the relevant supervisory authorities. The paper also identifies potential “blind spots” in the regulatory frameworks applicable at the time of writing and misalignments in prudential, conduct and operational objectives.

- Building on guidance from standard-setting bodies and international organisations on supervisory approaches to financial innovation, fintech and Big Tech, the paper identifies four priority areas for consideration, with a view to limit regulatory arbitrage and systemic interdependencies, while at the same time preserving innovation. In particular, the paper proposes (i) improving the monitoring of bank-like activities, harmonising definitions and calibrating intervention powers (“perimeter governance”); (ii) enhancing transparency and supervisory reach for complex multi-partner and white-label distribution models by direct licensing, on-site supervisory powers over agents and disclosure; (iii) introducing group-wide oversight for neo-conglomerates, in the form of a European Union financial holding structure for large and complex non-bank groups, with holistic and risk-based prudential requirements, reporting and supervisory colleges; and (iv) improving cooperation, coordination and information-sharing across authorities, supported by EU-level sandboxes and forward-looking risk assessments.
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