London and Paris after Brexit

A fintech gains from maintaining teams or regulated entities in both London and Paris when it has meaningful customers in both the UK and European Economic Area and performs activities that require separate permissions. London can support UK customers, finance-sector hiring and FCA relationships. A Paris operation can provide access to French customers and, where an appropriately authorised French entity qualifies, a route to other EEA markets through passporting.

The structure is not a default badge of European scale. Since UK to EEA passporting ended, separate entities can solve a real market-access problem, but they also create duplicated governance, capital, reporting, safeguarding and management demands. Founders should add the second regulated entity only after mapping the exact service, customer location and contracting entity.

Brexit turned one permission map into two

Before the end of the transition period, many EEA firms could use passporting to provide regulated services in the UK. The FCA states that EEA-based firms can no longer use that route and that the UK's temporary permissions regime ended in 2023. A firm that needs UK authorisation must now satisfy the relevant UK regime rather than assume that an EEA licence carries across.

The EEA still has its own cross-border framework. The European Banking Authority maintains a central register of payment and electronic-money institutions based on information supplied by national authorities. France's ACPR explains that a French-authorised payment or electronic-money institution may exercise relevant passport rights elsewhere in the EU or EEA, subject to the applicable notification process.

This split affects product design as well as legal structure. Customer terms, complaints, safeguarding disclosures, data flows and the name of the payment-service provider must match the entity serving the customer. A single interface can hide much of that complexity from a user, but it cannot remove the regulated responsibilities behind it.

Paris is useful when EEA substance is real

Paris offers more than a registered address. The ACPR requires a payment-institution applicant to show sufficient initial capital and prudential resources, a credible programme of operations, secure technical arrangements, clear governance and effective managers. It also says that the administration centre must be in the same national territory as the registered office.

That makes Paris a rational base when leadership, compliance and payment operations for an EEA business can genuinely sit there. A French entity can then support a French product and, where permitted, an EEA expansion plan. It is less rational if all decisions remain in London and the Paris entity exists only on an organisation chart.

The city also places a team close to French banks, accountants, merchants and employees. These commercial benefits matter when France is a target market in its own right. They should not be confused with automatic access to every European customer. Language, tax, distribution and sector practices still vary across the EEA.

London remains a separate commercial and regulatory base

London's value did not disappear with passporting. It remains a large financial-services customer market with specialist legal, risk, product and enterprise-sales talent. A UK entity also gives customers and regulators a clear accountable counterparty where the product falls within UK rules.

The FCA assesses applicants against their business model, resources, governance, suitability and ability to be supervised. A company must not conduct regulated activity merely because it has applied. The operating plan therefore needs time and money for authorisation, banking and payment partners, safeguarding design, complaints handling and financial-crime controls.

For an EU-founded company, a UK office without local decision-making may be insufficient for some models. For a UK-founded company, a French subsidiary that depends entirely on UK staff may face the mirror problem. Management should document which board approves risk, which entity owns customer contracts and data, and which team can stop a product when controls fail.

Product localisation is more than translation

A dual-city model is commercially useful when the teams own different local requirements while sharing a common platform. UK and French finance teams may use different accounting packages, tax workflows, payment methods and documentation. The core ledger or approval engine can be shared, but configuration, integrations, customer support and regulatory notices may need market-specific ownership.

This division should be visible in product planning. A central platform team can maintain common security, identity and audit capabilities. Local product and compliance owners should define mandatory variations and be able to reject a release that does not meet their market's rules. Otherwise the second city becomes a sales outpost that carries regulated responsibility without the authority to manage it.

Founders should also plan for failure. If one entity loses a partner or permission, customer funds, records and contracts cannot simply be shifted to the other. Exit and continuity plans should be designed before launch, not after a disruption.

Decide with a market-access ledger

A useful decision document lists, for each target country, the regulated service, legal entity, regulator, customer type, revenue opportunity, required senior roles, capital, partners, data location and launch dependencies. It should also state which activities are unregulated software services and which involve payments, e-money, credit or investment activity.

If the UK business is only a small set of unregulated enterprise-software customers, a separate regulated entity may not be justified. The same applies to a Paris entity if EEA demand is speculative. Partnerships can sometimes provide payment rails while the technology company remains a software supplier, but contracts and actual conduct must support that distinction.

The second city is earned when expected, repeatable gross margin and strategic customer access outweigh the ongoing entity cost. Founders should include duplicated audits, boards, regulatory reporting, tax, treasury and compliance tooling in that calculation, not only office and salary costs.

Limitations of this comparison

This article uses UK-wide and EEA-wide regulatory evidence to inform a comparison between two cities. It does not claim that every FCA or ACPR permission has the same scope, or that a French authorisation automatically permits every product across the EEA. The legal analysis depends on the service, customer and contracting chain.

No private authorisation timelines, entity budgets or customer-acquisition results are available here. Before publication, the structure and permissions of named companies should be checked in the FCA, ACPR and EBA registers, and operators should be interviewed about duplicated cost and actual customer demand.