Do You Need a Payment Licence to Run Your Platform?

Imagine you’ve built a platform where a customer pays, but the money is then owed to someone else – a seller, a service provider, a partner – not to your platform. That money has to reach the right place, whether there’s one recipient or several. And it’s exactly this moment that catches most platform builders off guard.

The moment a platform starts to look like a bank

Here’s the rule that surprises almost every platform builder: the moment your platform holds, pools, or moves money that belongs to someone else – even for a couple of hours – you start to resemble a payment institution in the eyes of the regulator.

That’s not a technicality. It’s the core test regulators use across the EU. If a platform receives a customer’s payment and is responsible for getting it to a third party – a seller, a service provider, a contractor – the platform is performing a payment service. And payment services are a licensed activity, with real obligations attached:

• Minimum capital requirements – a set amount of money that has to sit in reserve just to be allowed to operate.
• An anti-money-laundering (AML) programme – ongoing monitoring and reporting.
• A relationship with a financial supervisor – regular audits and reports.
• Safeguarding of client funds – third-party money has to be kept separate from the platform’s own balance sheet.

None of this is quick or cheap, and none of it is required if the platform never touches the money at all. The problem is that without a workaround, “we’ll just collect the money and pay people out later” is exactly the activity that triggers the licence requirement.

The usual fallback – bolting a standard payment processor onto a homemade ledger – doesn’t solve the problem, it just hides it. Keeping track of who’s owed what, and reconciling refunds by hand, is a job most teams seriously underestimate.

There’s a cleaner way: don’t let the platform touch the money at all. Route it through a partner who’s already licensed to do exactly this.

How the money actually flows

That’s the idea behind MakeCommerce Marketplace & Platform Payments. Instead of the platform receiving and passing on funds, MakeCommerce sits in the middle as the regulated party, and the money never passes through the platform’s own accounts.

In practice, it works in three steps:

1. The transaction is created. The platform sends MakeCommerce the details of the seller who needs to get paid – name, IBAN, and amount. MakeCommerce returns a transaction ID and a seller ID for the payout.

2. The customer pays, once. The customer checks out through the standard MakeCommerce checkout – Baltic bank links, Apple Pay, Google Pay, cards. The platform is notified once the transaction reaches “completed”.

3. The seller gets paid – automatically, or on your terms. The platform can let the payout release automatically, about five minutes after the transaction completes. Or it can hold the funds and trigger the payout itself, whenever the business logic calls for it – when the order ships, the booking date passes, or the service is delivered. The seller then receives a same- or next-working-day SEPA payout, with the platform’s own reference visible on their bank statement.

Refunds, partial refunds, and payout cancellations before release all work the same way – through the API, against the original transaction – so there’s no separate reconciliation process to maintain.

The platform never holds anyone else’s money at any point in that flow. It collects a clean platform fee, while the regulatory exposure for holding third-party funds stays with MakeCommerce, where it’s already accounted for.

MakeCommerce Marketplace & Platform Payments – built for exactly this

The service is built for any platform where a customer pays but the money is then owed to a seller or partner, not the platform itself.

• MakeCommerce holds and manages the money – not your platform. The regulatory responsibility for third-party funds stays with us, not with you.
• Automatic or manual payout release – your call. Fully hands-off within a few minutes, or triggered exactly when your business model calls for it.
• Fast, traceable settlement. SEPA payouts run same or next working day, and the seller sees a clean statement line with your reference on it.
• Refunds and cancellations, built in. Full and partial refunds, payout cancellations before release, and status webhooks at every step – all through the API.
• The checkout your customers already trust. No second integration needed – customers pay through the same MakeCommerce checkout already used by 7,000+ merchants across the Baltics.
• Regulated infrastructure, already in place. The service runs on Maksekeskus AS, a licensed Payment Institution supervised by the Estonian Financial Supervision Authority (Finantsinspektsioon), and is PCI DSS v4.0 compliant.
• If you need it – split a single transaction across multiple recipients. When your model calls for it, the same solution supports paying out to several sellers from one transaction, with no extra integration.

It fits a wide range of platforms – marketplaces, booking and ticketing platforms, service marketplaces, rental platforms, creator communities, as well as sports clubs and associations that pay out entry fees or sponsorship money. The common thread isn’t the industry – it’s the shape of the money flow: the customer pays, but the money is owed to someone else.

If your business is not a marketplace or platform, and you’re simply selling your own products or services through your own online store, this probably is not the solution you need. In that case, standard MakeCommerce payment solutions are a better fit – for example, bank payments and card payments, which you can add to your store without marketplace payout logic.

Worth being upfront about: this doesn’t remove every compliance responsibility from the platform. AML and KYC on your sellers stays with you – MakeCommerce verifies the platform, and the platform verifies the people selling on it. That’s the standard division of responsibility for platform facilitators across the EU, and it’s a much smaller lift than a payment institution licence.

If you’re building a platform and thinking about how to handle payouts, it’s worth talking it through early – usually a single conversation is enough to map the solution onto your model. Learn more about Marketplace & Platform Payments and fill in the contact form – we’ll be in touch!