Czech Republic

Licensing, Authorisation & Market Access

The Czech National Bank has completed its transition to Markets in Crypto-Assets Regulation licensing, authorising eleven entities as Crypto-Asset Service Providers after assessing 251 applications by the 1 July 2026 deadline.

The Small Payment Institution route remains an active domestic-only registration option under CNB supervision, distinct from full payment institution or e-money institution authorisation, and continues to be taxed at the 21% corporate income rate, with the incoming PSD3/PSR framework expected to tighten standards applicable to this route.

Conduct, Safeguarding & Financial Promotions

Czech payment institutions operate under a narrower safeguarding mandate than electronic money institutions. PI funds may be held only in dedicated payment accounts for defined transaction execution, not for indefinite storage, a function reserved for EMIs, which carry broader stored-value safeguarding obligations under the segregation model. This bank/nonbank-adjacent distinction -- PI as a transaction-execution vehicle, EMI as a stored-value vehicle -- remains the structural spine of Czech conduct regulation for nonbank payment firms.

Stablecoins & Digital Money

The Czech Republic applies MiCA directly as EU law, operationalised nationally through Act No. 31/2025 Coll., the Digital Finance Act, in force since 15 February 2025, with a full 18-month CASP transitional period running to 1 July 2026. That transitional window is longer than those chosen by some neighbouring markets, extending the runway for existing crypto-asset firms to keep operating without full CASP authorisation. Under the regime, MiCA e-money tokens may be issued only by a credit institution or a Payments-Act-authorised electronic money institution, keeping EMT issuance tied to the existing bank/EMI licensing perimeter rather than opening it to unlicensed issuers. Stable Europe s.r.o. has already become the first authorised domestic issuer under the new regime, holding MiCA authorisation to issue CZKI, a koruna-referenced e-money token. The CNB received 248 CASP applications in total, one of the highest volumes recorded anywhere in the EU, before issuing its first six authorisations on 11 February 2026.

Operational Resilience & Critical Infrastructure

DORA, the EU's Digital Operational Resilience Act, became fully applicable in the Czech Republic on 17 January 2025, transposed via Act No. 31/2025 Coll., with the CNB acting as supervisory and sanctioning authority. Breaches can draw fines of up to CZK 50,000,000, roughly EUR 2,000,000, under the Act on Digitalisation of the Financial Market. A national Critical Infrastructure Resilience Act, transposing the EU Critical Entities Resilience Directive, took effect in November 2025, adding enhanced incident-reporting obligations for covered financial institutions on top of the DORA baseline. Observers note overlapping supervisory scope between the CNB's DORA remit and NUKIB, the national cybersecurity authority, as a coordination point to watch.

Scheme & Network Compliance

The EU Interchange Fee Regulation directly caps consumer card interchange in the Czech Republic at 0.3% for credit and 0.2% for debit transactions; corporate and commercial cards fall outside those caps and can carry interchange of 1.5% or more. Before the EU regulation took effect, Czech domestic card interchange ran at approximately 1% under Visa/Mastercard rules, making the IFR caps a material reduction from the pre-regulation baseline. PCI DSS applies to all entities in the Czech card payment chain -- merchants, processors, acquirers, issuers and service providers -- through contractual incorporation by the card schemes rather than through domestic statute. No scheme rule changes specific to the Czech Republic were identified this cycle beyond this standing IFR/PCI-DSS framework.

Payment Corridor Dynamics

CERTIS, the CNB's instant-payments rail, sets a per-transaction ceiling of CZK 2,500,000 (minimum CZK 0.01), with a median inter-bank processing time of 0.5 seconds. Domestic usage is accelerating fast: CERTIS processed 40.8 million instant transactions in April 2026, up roughly 50% year-on-year. The CNB is also developing a bulk koruna instant-payments capability, for uses such as salary payments, targeted for 2026. On the cross-border corridor, non-eurozone banks including Czech banks face two distinct obligations under EU Instant Payments Regulation 2024/886 -- the ability to receive instant euro payments by 9 January 2027, and a separate, later obligation to send instant euro payments, including cross-border, by 9 July 2027. That two-stage structure is often compressed in market commentary into a single 'July 2027' deadline, a simplification operators should not rely on for compliance planning.

Industry Structure & Commercial Dynamics

The Czech banking sector remains concentrated: the top four banks hold more than 60% of total sector assets of CZK 11,440 billion across 43 licensed credit institutions, as of September 2025. Alongside that concentrated core, a growing nonbank layer has emerged, comprising 23 neobank or mobile-payment entities as of November 2025 and an estimated 180-220 fintech firms overall. Financing-market structure is also evolving: PPF Group financed its takeover bid for Moneta Money Bank shares via a EUR 1.1 billion ING-led certain-funds facility, the first Czech certain-funds structured loan used for a voluntary takeover bid, though full deal parameters and status were not confirmed in available sourcing.

Legal & Litigation

Enforcement activity intensified this cycle across both bank and nonbank payment firms. The CNB fined Fio banka CZK 3 million in 2023 for anti-money-laundering violations and fined Expobank CZ CZK 20 million for lacking an effective managing and control system. On the nonbank side, GOPAY s.r.o. had its electronic money institution authorisation revoked on 16 April 2025, a licence originally granted on 23 November 2012 -- a finding independently confirmed through adversarial verification against the same registry source. The CNB must publish its final decisions on fines, administrative penalties and remedial measures without undue delay, including those issued under MiCA, DORA and Act No. 31/2025 Coll., giving the market a running public record of enforcement outcomes.

Merchant Acquiring & Risk

GoPay and Comgate operate as CNB-authorised nonbank payment-institution and e-money-institution merchant acquiring gateways, serving Czech and wider Central European e-commerce merchants. Card scheme rules from Visa and Mastercard are incorporated by reference into Czech acquirer-merchant agreements, binding merchants automatically when schemes change chargeback windows, SCA/3DS requirements or merchant-category-code restrictions, without requiring a separate domestic rulemaking step.

Product Innovation & Market Development

CNB's CERTIS instant-payments system now processes an average of 1.65 million instant koruna transactions per day and is accessible to 99% of bank clients.

CNB is developing a bulk instant payments capability, such as salary payments, targeted for 2026, with domestic banks required to offer euro instant payments including cross-border transfers from July 2027, and euro payments from koruna accounts becoming available from June 2028.

Consumer Protection & APP Fraud

The Czech Republic has no standalone domestic regime mandating reimbursement for authorised-push-payment fraud victims. That gap is expected to narrow only once the EU-level PSD3/Payment Services Regulation package, politically agreed in November 2025 to introduce harmonised online-fraud protections and platform liability, is formally adopted -- a date not yet confirmed in available sourcing. In the meantime, the Ministry of Industry and Trade routes consumer complaints about unfair payment-service conduct to the relevant sectoral supervisor, such as the CNB, which may fold the complaint into its own inspection planning.

AML/CFT & Financial Crime (Sentinel.gi-fed)

This module's intelligence is sourced from the Sentinel.gi feed; WPM carries it as provenance and cross-reference rather than performing original illicit-finance analysis. The Financial Analytical Office coordinates the national ML/TF risk assessment, now in its third round, alongside CNB supervision of the financial-institution segment under Act No. 253/2008 Coll. The Czech Republic approved its first national AML/CFT Strategy for 2025-2027 under Resolution No. 1 of 28 May 2025, and a first proliferation-financing risk-assessment round is also underway. An external evaluation assessed the FAU's and CNB's fines as not sufficiently dissuasive or proportionate and flagged limited AML/CFT supervisory human resources -- a finding this brief routes to FIM for deeper illicit-finance-specific analysis rather than resolving within WPM's payments-market lens.

Correspondent Banking, Settlement & Access

CERTIS admits direct participants including banks, credit unions and cooperatives, foreign bank branches, payment institutions, foreign EU/EEA payment institutions, and electronic money institutions, all settling in central bank money under EU settlement-finality rules. This module's analytical spine is the bank/nonbank access asymmetry: banks reach TARGET2 and EURO1 through their own or parent-group networks, while nonbank access runs through CERTIS itself and now, following the W1a amendment, extends directly to PIs and EMIs. No evidence of jurisdiction-specific correspondent-banking de-risking pressure was identified for the Czech Republic in this sweep; large Czech banks access TARGET2 and EURO1 via parent-group networks, and the koruna remains fully convertible with no foreign-exchange controls -- though this absence of findings is an evidentiary gap rather than a confirmed absence of risk.

Commercial Intelligence (M&A, Investment & Product)

The Prague Payments Summit 2026 programme places PSD3/PSR implementation at the centre of industry discussion for the Czech-Slovak payments market, though no concrete commercial transaction was identified this cycle.

Outlook

No commercial transactions, funding rounds, or product launches were identified for the Czech market this cycle; the module will be revisited as new deal activity emerges.