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Swiss Chinese Law Association — Geneva

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Legal Observatory / Finance and Payments

Legal Update European Union Regulatory guidance

European Banking Authority Releases Consumer Factsheet on White-Labelled Financial Services

The European Banking Authority published a consumer factsheet to help individuals recognize white-labelled financial products and understand the roles of companies involved.

What Changed

  • The EBA published a consumer factsheet addressing white-labelled banking and payment services offered through non-financial brands and digital platforms.
  • The factsheet was produced pursuant to Article 9(1)(b) of the EBA Founding Regulation following findings in the EBA's 2025 Report on white labelling.
  • The EBA confirmed that examining white labelling arrangements in financial value chains will form part of its 2026 priorities under Article 9(2).

Consumers accessing banking and payment services through online platforms, retailers, and non-financial brands in the European Union face growing ambiguity over which company provides and takes legal responsibility for financial products. To address this, the European Banking Authority (EBA) has published a consumer factsheet focused on white-labelled financial products and services—defined as products marketed under one brand but provided by another company.

The factsheet provides practical examples and guidance to help consumers distinguish between the front-end brand and the underlying financial provider. It encourages consumers to look beyond branding by asking key questions prior to purchasing a financial product or service:

1. Who is actually providing the product or service?

2. Is the product or service tailored to the consumer’s needs?

3. Which company will be responsible for handling complaints?

4. What is the procedure to terminate the agreement?

By raising consumer awareness, the EBA aims to support transparent decision-making in an increasingly digital financial environment and clarify the respective roles of the companies involved.

This publication follows the EBA’s 2025 Report on white labelling, which highlighted both opportunities and potential consumer risks inherent in this business model. The EBA developed the factsheet pursuant to Article 9(1)(b) of its Founding Regulation, which requires the Authority to take a leading role in promoting transparency, simplicity, and fairness in the market for consumer financial products or services across the internal market, including coordinating financial literacy initiatives by competent authorities. Additionally, under Article 9(2) of the Founding Regulation, the EBA monitors market developments and technological innovations. The EBA has confirmed that examining white-labelling arrangements as part of broader financial services value chains is included in its 2026 priorities.

The press release does not state an exact publication date, entry-into-force date, or application date for the factsheet. Entities operating white-labelling business models or distributing financial services through non-financial platforms within the EU market should note the EBA's ongoing regulatory focus on consumer clarity and value-chain oversight.

Who May Be Affected

Consumers using banking and payment services via online platforms or non-financial brands, as well as financial institutions and non-financial companies engaging in white-labelled financial product distribution in the EU.

Cross-Border Context

Applies at the EU level across the internal market where domestic or international non-financial entities partner with authorized financial providers to market white-labelled banking and payment services.

What to check next

  • Consult the EBA consumer factsheet directly on the official EBA portal.
  • Review the EBA 2025 Report on white labelling for findings on opportunities and consumer risks.
  • Track the EBA 2026 work priorities regarding financial services value chains.

This article provides general information and does not constitute legal advice. Consult the official text and obtain advice appropriate to your circumstances where needed.

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