The safeguarding account

Frequently asked questions about the safeguarding account

A Safeguarding account (also known as a safeguarding account) is a mandatory bank account for Payment Institutions (PIs) and Electronic Money Institutions (EMIs). In accordance with PSD2 (Articles 10 and 11 of Directive (EU) 2015/2366), transposed into French law under Articles L. 522-17 (PIs) and L. 526-32 (EMIs) of the French Monetary and Financial Code, it separates the institution's own funds from those deposited by its clients. This separation ensures that client funds remain protected, even in the event of a PI or EMI failure.

Yes. PIs and EMIs are legally required under PSD2 (Articles 10 and 11) to safeguard their clients' funds with a licensed credit institution no later than the business day following their receipt (D+1). In France, this obligation is transposed under Articles L. 522-17 and L. 526-32 of the French Monetary and Financial Code. Entities benefiting from a partial exemption from the ACPR (position P-2022-01) may, under strict volume and scope conditions, benefit from a safeguarding waiver. This waiver ceases to apply as soon as volume thresholds are crossed or the activity extends beyond the declared scope, which requires continuous monitoring.

Ring-fencing must take place no later than the business day following the receipt of funds — this is known as D+1 compliance. Failure to comply exposes the company to sanctions by the ACPR, which can go as far as the withdrawal of its licence.

Managing flows via API in real time enables full automation of the transfer from the settlement account to the ring-fenced account, with complete timestamping and traceability for your ACPR audits.

Yes. Deposits in the safeguarding account earn interest at 25% of the €STR by default. Interest is calculated daily and paid monthly into the main current account. Excess liquidity can also be invested in treasury investment funds (Amundi STAR funds, money market funds), with D+1 availability, provided this has been included in your ACPR authorisation application.

Only a credit institution licensed by the ECB or an equivalent national authority. Payment institutions do not hold this status. Memo Bank is licensed by the ECB and regulated by the ACPR.

The FGDR applies a specific mechanism to third-party funds: the guarantee (up to €100,000) is calculated at the level of each beneficiary — meaning each end client whose funds are deposited in this account. Each client thus benefits individually from FGDR protection, up to the amount of their claim, without the cap being shared among all of the payment institution's clients (Article L. 312-4-1 of the French Monetary and Financial Code).

Consultation and operational rights on the safeguarding account are configured within the account agreement and managed from the Memo Bank platform.

Internal access: administrators have full rights by default, and team members can be invited with restricted permissions.

Third-party access: in arrangements involving multiple stakeholders (auditor, custodian bank, etc.), read-only access can be granted to external entities, directly from the Memo Bank platform or via standard banking exchange protocols (SWIFT MT940, EBICS). Incoming and outgoing flows can also be managed separately with differentiated rights — for example, granting the PI/EMI's agents management of incoming flows whilst allowing the PI/EMI itself to authorise debits.

The safeguarding account is the regulatory account that legally protects client funds. The settlement account is the operational account that orchestrates flows: collection, controls, company charges, and balancing before ring-fencing. Both can be opened simultaneously under a single account agreement.