EBA examines white labelling – a new report from the banking supervisor

EBA analyses white labelling model – the growing role of e-commerce platforms in the provision of financial services

The European Banking Authority (EBA) has published a report on white labelling – a model in which a financial institution provides services under a partner’s brand. Although traditionally used between regulated entities, this approach increasingly involves cooperation with non-financial companies such as e-commerce platforms and online marketplaces.

According to EBA data, more than 35% of banks participating in the 2025 RAQ spring survey already use this model. Its rapid growth is driven by digitalisation and the rise of platform-based distribution channels, which have become an important gateway for customers to access financial services.

Benefits and Risks for Consumers and Institutions

The report highlights both the benefits and risks of white labelling. Key advantages include: lower prices resulting from increased market competition; broader access to financial services through mobile apps and online stores that consumers are already familiar with; and overall wider availability of financial products.

For consumers, the most significant risk is reduced transparency – customers may struggle to understand who is actually responsible for the product and where to lodge complaints, which increases their exposure to misconduct.Other risks include impersonation fraud targeting financial institutions’ partners, and improper processing or storage of personal data. Supervisory authorities also face the challenge of exercising oversight over partners falling outside the regulated financial sector.

Seven Key Differences in White Labelling Agreements

The EBA additionally outlines seven major differences between white-labelling arrangements:

• the regulatory status of the parties (financial vs. non-financial),
• allocation of operational roles,
• whether the model is strategic or ancillary,
• the type of product or service offered,
• the customer segment (retail or corporate),
• the geographical scope (domestic or cross-border),
• fee structure (flat-fee or usage-based).

What next?

The EBA announced supervisory actions for 2026 aimed at harmonising the approach to white labelling, including:

• enhancing supervisory awareness-white labelling has already been included in the 2026 supervisory priorities; and
• strengthening disclosure obligations to ensure consumers clearly understand who they are in a relationship with and how they can submit complaints.

Balancing Benefits and Risks

White labelling boosts competition and lowers the cost of accessing financial services, but it simultaneously heightens consumer risks, particularly regarding transparency. The EBA rightly emphasises the need for a consistent supervisory framework to reduce regulatory fragmentation and ensure a clear division of responsibilities between partners.

Do you require legal assistance?

The European Banking Authority has published a report on white labeling, highlighting both its benefits and risks for consumers and institutions. This model is growing alongside digitalization and e-commerce platforms, but it requires clear responsibility and transparency.

Want to safeguard your processes and make the most of white labeling? Contact us – we’ll help you design a secure and regulation-compliant business model.