Europe’s bunq Moves to Become a U.S. Bank
bunq Files for a U.S. Banking License
Building on the trend of FinTechs pursuing banking licenses in the prior year, bunq, Europe’s second largest neobank becomes the first FinTech in 2026 to file a de novo banking license application with the Office of the Comptroller of the Currency (OCC), advancing plans to establish regulated banking operations in the United States. The filing follows earlier regulatory steps taken to support market entry and marks a transition from preparatory licensing to a full national banking application. The move reflects a broader strategy to extend its European digital banking model into the US regulatory framework while maintaining operations across more than 30 European markets.
The application is positioned around serving individuals with cross-border financial needs, particularly those living and working between Europe and the United States. Approval would allow the platform to offer US-based banking services directly, rather than through intermediaries, and to align its product structure with US banking and supervisory requirements.
U.S. Market Entry and Regulatory Progression
Formal submission of a de novo bank application: The OCC filing represents the formal request to establish a new federally regulated bank in the US, following preparatory regulatory engagement that began in 2023.
Sequenced regulatory approach: The banking license application follows approval of a US broker-dealer license, indicating a phased strategy to secure regulatory permissions supporting broader financial services.
Initial geographic rollout strategy: Upon approval, services are expected to begin in US metropolitan areas with significant expatriate populations, reflecting a targeted rather than nationwide launch.
Cross-border banking functionality focus: The proposed US offering includes access to both US and European checking accounts, subject to eligibility, alongside mechanisms to support credit profile building for new US residents.
Integration of existing European operating model: The application outlines plans to extend established digital banking capabilities, including secure payments and fraud prevention systems, into the US market under local regulation.
Expansion within a broader global roadmap: The US filing coincides with continued international expansion efforts, including growth across European markets and parallel pursuit of additional licenses in other jurisdictions.
FinTech Firms Pursuing U.S. Banking and Trust Charters
Mercury: Mercury applied to the Office of the Comptroller of the Currency (OCC) for a national bank charter to become the Bank for builders and separately filed for federal deposit insurance with the Federal Deposit Insurance Corporation (FDIC).
PayPal: PayPal has submitted applications to the Utah Department of Financial Institutions and the Federal Deposit Insurance Corporation to establish a Utah-chartered industrial loan company, proposed as PayPal Bank.
Circle: Circle has received conditional OCC approval to establish a national trust bank to manage reserves backing its U.S. dollar stablecoin under federal oversight.
Ripple: Ripple has secured conditional approval to form a national trust bank, placing its stablecoin reserve management under both federal and state regulatory supervision.
Coinbase: Coinbase has applied to become a national trust company to expand its custody business and support payments and related services under federal regulation
Stripe: Stripe has applied for a limited-purpose merchant acquirer bank charter in Georgia to gain direct card network access, without offering deposits or traditional banking services.
Wise: Wise has filed an application with the OCC to create a national trust bank, aimed at reducing dependence on partner banks and supporting service expansion in the U.S.
Nubank: Nubank has applied for a U.S. national bank charter as part of plans to explore broader market participation, including deposits, credit, and custody services.
Revolut: Revolut has confirmed it is evaluating options to establish a U.S. bank, either through acquisition or by applying for a new banking license.
