“Can a spend management platform become its own regulated bank by stacking EMI licenses and Visa Principal Membership, eliminating BaaS middlemen?”
Payhawk launched as a spend management platform unifying corporate cards, expenses, and accounts payable. The strategic pivot has been vertical integration of the financial stack: securing its own EMI licenses in Lithuania (2023) and the UK (2024), becoming a Visa Principal Member to issue cards directly without a BIN sponsor, and building in-house credit lines. This moves Payhawk from being a software layer on top of third-party BaaS to operating as its own regulated e-money institution.