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← Embedded Finance Index 2026/Bank charters
Charter queue · 2025-26 · updated 2026-10-06
147-day median OCC review · peaked at 9/quarter ↓

Who is applying to become a bank

38 applications tracked since the OCC reopened de novo chartering. Most are national trust banks — custody and stablecoin settlement under one federal supervisor instead of fifty state licences — not deposit-taking banks. Each row is a sponsor-bank relationship that ends the day the charter opens.

8
Application filed
26
Conditional approval
2
Approved
2
Denied
Showing 2 of 38 — show all
CompanyProposed bankCharterStatusFiledDecisionWhat it is for
bunqbunq US Bank, National Association
New York, NY
National bank
OCC
Denied2026-012026-08-04
Corporate Decision 1384 (denial)
Second attempt after withdrawing a 2023 application; US deposits for European nomads resident in the US. The OCC denied the application after its field investigation, noting the proposed holding company would be majority-owned by a single individual who also controls bunq B.V.
WiseWise National Trust
Austin, TX
National trust bank
OCC
Denied2025-06-162026-07-21
Corporate Decision 1381 (denial)
Trust charter that would have given Wise direct access to US payment rails without a sponsor bank. The OCC denied the application after its field investigation; the letter says a subsequent application would need to address the reasons for the denial.
Sources: the OCC’s Interpretations & Decisions table for every decided row (letter number and date verbatim), the applicant’s own announcement for filings the OCC has not yet decided. The list is diffed against the OCC table weekly. Charters already operating before 2025 are not in the queue — they appear on the vendor pages as held charters.

How fast is this moving

Filings by quarter

5
Q2 '25
6
Q3 '25
9
Q4 '25
9
Q1 '26
4
Q2 '26
3
Q3 '26
2
Q4 '26

Peaked at 9 a quarter in Q4 2025–Q1 2026; the dashed bars are still filling in, not a drop-off.

Filing to first decision

147
Median days
118
Fastest
184
Slowest approval

118–184 days across 19 measured approvals (UKG fastest, Fidelity Digital Assets slowest); Wise's denial took 400 — over 2x the slowest approval.

A filing only enters this queue once announced or decided, so a quarter younger than ~6 months hasn’t had its quieter filings surface yet. Of the OCC applications still pending, Kraken has waited longest so far (169 days) — still inside the approval range above. Affirm, PayPal and Klarna are also pending, but on a separate FDIC-and-state industrial-bank track, not the OCC ladder these figures measure.

Outside the US

14 bank and bank-branch licence applications (filed, approved or announced) tracked in the UK, EU, Switzerland, the Nordics, Latin America and the Middle East. There is no regulator feed to diff these against the way the OCC’s table backs the US queue, so every row needs the company’s or regulator’s own document, or two independent outlets. Single-source bids are left out until a second source appears.

CompanyJurisdictionLicenceStatusDateWhat it is for
RevolutColombia
Superintendencia Financiera de Colombia
Bank (credit institution)Approved2026-09Licence to operate as a bank in Colombia, part of Revolut's push to hold its own banking licence in each major market.
RevolutSwitzerland
FINMA
Bank (credit institution)Application filedfiled 2026-09Standalone Swiss bank for franc salary accounts, Swiss IBANs and deposit protection; Swiss customers are served today by the Lithuanian entity.
Allica BankSweden
Finansinspektionen
Bank (credit institution)Application filedfiled 2026-08First market outside the UK for the digital SME bank; Swedish entity and executive team already set up, with EU passporting as the longer-term aim.
RevolutFinland
Bank of Lithuania + ECB (home) / Finland (host)
Bank branchApplication filedfiled 2026-08Local Finnish account details for the 250,000+ customers served through the Lithuanian bank today.
A branch of Revolut Bank UAB, not a new bank. No timetable disclosed. One source also mentions a Greek application; nothing else confirms it, so it is not recorded.
RevolutFrance
ACPR + ECB
Bank (credit institution)Approved2026-08-10Second full EU bank licence, making Paris the Western European hub alongside Lithuania.
The ECB's product-launch restrictions on the Lithuanian arm (July 2025) are reported by Bloomberg to extend to the French entity; Revolut's announcement did not mention them.
RevolutAustralia
APRA
Bank (credit institution)Approved2026-07Full authorised deposit-taking institution (ADI) licence; banking operations activated in July 2026.
DefactoFrance
ACPR + ECB
Bank (credit institution)Application filedfiled 2026-06Move an SME working-capital lender (today a société de financement) to a full EU credit institution ahead of expansion into Germany and Belgium from 2027.
MalUnited Arab Emirates
Central Bank of the UAE (CBUAE)
Bank (credit institution)Authorised, not yet fully operating2026-05-20Abu Dhabi-based AI-native, Shariah-compliant digital bank spanning banking, wealth, payments and embedded finance, targeting the $7tn Islamic finance market — reportedly the first in-principle approval anywhere for an AI-native digital banking platform.
In-principle approval only — Mal has not yet become a fully licensed bank, and still needs final regulatory clearances before commencing operations. Reported alongside its $230M seed round (largest fintech seed round in MEA history), led by BlueFive Capital.
RevolutUnited Kingdom
PRA + FCA
Bank (credit institution)Approved2026-03-11Full UK bank: FSCS-protected deposits and, over time, lending; ends the e-money-institution setup that served 13 million UK customers.
Authorised with restrictions (mobilisation) on 2024-07-25; the PRA lifted them in March 2026, about 20 months later, longer than the usual 12.
MintosLatvia
ECB
Bank (credit institution)Intent announcedannounced 2026-02Investment platform seeking an ECB banking licence for deposit funding and direct lending.
The release says Mintos is initiating the process and expects 12-18 months; it does not confirm a filing.
NubankBrazil
Banco Central do Brasil
Bank (credit institution)Intent announcedannounced 2026-01Stated intention to obtain a full banking licence in Brazil in 2026, alongside the US national bank charter.
The release states the intention and the country, not the regulator or a filing date.
MonzoIreland
ECB (Central Bank of Ireland)
Bank (credit institution)Approved2025-12EU banking licence to serve the EU without partner banks; Ireland first, Spain launched since.
The sources say Ireland; the ECB / Central Bank of Ireland split is the standard route for a euro-area licence, not something either source spells out.
QontoFrance
ACPR + ECB
Bank (credit institution)Application filedfiled 2025-07Move from a French payment-institution licence to full credit-institution status: longer-term lending, savings and investment, and independence from partner banks for Pay Later.
Announced 2025-07-02. A January 2026 interview (JDN) says Qonto filed in 2024, and its CEO hoped for the licence in 2026. No decision found as of 2026-09-25. EU rules give the ECB six months from a complete application, twelve at most, so the announced date and the missing decision do not fit together: either the file was completed later, or a decision exists that was not found. Check before writing a status.
NubankMexico
CNBV
Bank (credit institution)Authorised, not yet fully operating2025-04CNBV authorisation for Nu México to organise as a banking institution.
Authorisation to organise as a bank; final operational approval was still pending as of the 2026-01-27 release. Recheck.
Payment and e-money licences are not bank licences and are not listed. Each row’s date is its latest status event: a decision, a filing or an intent announcement. Filing and intent dates come from the announcement itself (the company’s own release or press coverage of it), so they are recorded at month precision unless the company or regulator gave a day.

How to read the queue

What the queue says. A bank charter has become an ownership strategy, and the queue splits by what the applicant wants to own. 21 of the 38 applications are for national trust banks: crypto and stablecoin firms (Coinbase, Circle, Ripple, Bridge) that want to hold custody, reserves and settlement under one federal supervisor rather than outsource them to a partner bank and fifty state licences. 10 are for full national banks: fintechs (Revolut, Mercury, Nubank, Upstart) that want deposits, lending and the balance sheet themselves. 4 are existing state-chartered institutions converting to a national charter, today all crypto custodians (Paxos, Fidelity Digital Assets, BitGo) moving their trust companies under the OCC. 3 sit outside the OCC ladder (industrial-bank or state-trust applications). The stablecoin rows are the newest pattern: under the GENIUS Act, issuers are applying to own issuance, reserves, custody and dollar conversion end to end, which is why the trust-bank column now outnumbers the deposit-taking one.

National bank vs national trust bank
A national bank takes deposits and lends, carries FDIC insurance and the Community Reinvestment Act, and can replace a fintech’s sponsor bank outright (Revolut, Mercury, Nubank, bunq, Upstart). A national trust bank is uninsured and non-depository: it custodies assets and settles transfers under fiduciary powers, which is why the stablecoin and custody names — Circle, Coinbase, Ripple, Paxos, BitGo, Bridge, Block’s Builders Bank — file for one. It replaces fifty state money-transmitter and virtual-currency licences with one federal supervisor; it does not replace the sponsor bank behind a deposit product.
The OCC ladder
Application filed is the applicant’s announcement; the OCC posts receipts to its Corporate Applications Search with a delay. Conditional approval is the OCC’s preliminary conditional approval letter, published as a Corporate Decision or Conditional Approval — the bank must then raise capital, pass a pre-opening examination and, for a depository bank, obtain FDIC insurance, typically within eighteen months. Approved is final approval to commence business; Opened is a bank in operation. Conversions (Paxos, BitGo, Fidelity Digital Assets) move an existing state trust company onto a national charter and follow the same letters. A denial is published the same way, as a Corporate Decision with the same “application to charter” title — only the letter text says which way it went. Wise (July 2026) and bunq (August 2026) were denied after the OCC’s field investigation; either can reapply.
Why it matters for the sponsor-bank layer
Every deposit-taking applicant on this list currently runs on a partner bank — Mercury on Choice, Column and Evolve; Chime is buying Stride outright — and the charter is the exit from that relationship. The sponsor-bank leaderboard shows who they leave behind.
Analysis
The network isn't the only rail anymoreMoney-movement railsHow banks sell embedded financeEarly-stage companies to watchConsortiums & alliancesEmbedded finance news
Leaderboards
Sponsor banksBaaSCard issuingKYC / compliance
Regions
USUKEU
By theApideck research team— the unified API platform behind this charter tracker.