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Tool · Substance Calculator

Will this substance level
pass the regulator?

Substance is the operational reality regulators check at authorisation, inspection, and supervision: real people doing real work in the licence jurisdiction. Five sliders, nine European regulators, real-time pass / conditional / fail per regulator.

Local employees (FTE)
40 – 50
Local board meetings per year
40 – 24
Director residency days per year
900 – 365
Office floor area (m²)
600 – 500

No data is sent or stored. Computation runs locally.

9 regulators
Pass4
Conditional4
Fail1
Per-regulator verdict

BaFin (Germany)

Conditional

Profile is in the BaFin conditional band — passable with documented remediation, but expect questions and an extended authorisation cycle.

4 FTE — needs ≥ 6 to pass
4 meetings — needs ≥ 6
90 days — needs ≥ 180
60 m² — needs ≥ 80 m²

BaFin treats substance as a §32 KWG core check. The two-MD rule applies in practice — at least two managing directors with executive authority in Germany. Inspections regularly probe the local hours of senior management.

DNB (Netherlands)

Fail

DNB would not currently authorise this profile without material substance build-up first.

4 FTE — needs ≥ 6 to pass
4 meetings — needs ≥ 6
90 days — needs ≥ 180
60 m² — needs ≥ 80 m²

DNB has progressively tightened substance expectations since 2020. Day-to-day management must be visibly Dutch-resident; board minutes evidencing local meetings are routinely requested.

Central Bank of Ireland

Conditional

Profile is in the CBI conditional band — passable with documented remediation, but expect questions and an extended authorisation cycle.

4 FTE — needs ≥ 5 to pass
4 meetings — needs ≥ 4
90 days — needs ≥ 110
60 m² — needs ≥ 60 m²

CBI applies the "PCF" (Pre-Approval Controlled Function) regime — local PCF holders count strongly toward substance. CASP/MiCA authorisations are subject to the proportionate substance test; expect ongoing CP86-style outsourcing scrutiny.

ACPR (France)

Conditional

Profile is in the ACPR conditional band — passable with documented remediation, but expect questions and an extended authorisation cycle.

4 FTE — needs ≥ 5 to pass
4 meetings — needs ≥ 4
90 days — needs ≥ 120
60 m² — needs ≥ 60 m²

ACPR substance reviews emphasise the dirigeant effectif — at least two effective directors locally available and decision-empowered. PSP/EMI dossiers prepared without resident effective directors fail at completeness review.

Bank of Lithuania

Pass

Profile meets BoL's observed substance floor. Proceed to inspection / authorisation pack on schedule.

4 FTE — needs ≥ 4 to pass
4 meetings — needs ≥ 4
90 days — needs ≥ 90
60 m² — needs ≥ 40 m²

Bank of Lithuania has the most fintech-experienced supervisory team in Europe and is correspondingly precise on substance. Notable: the 2022 supervisory tightening introduced explicit residency-day expectations for senior management.

Finantsinspektsioon (Estonia)

Pass

Profile meets FI's observed substance floor. Proceed to inspection / authorisation pack on schedule.

4 FTE — needs ≥ 3 to pass
4 meetings — needs ≥ 4
90 days — needs ≥ 90
60 m² — needs ≥ 30 m²

FI tightened VASP substance dramatically in 2022 after broad de-licensing of shell registrations. Real-office, real-staff, real-MLRO is now the floor for any new authorisation.

CSSF (Luxembourg)

Conditional

Profile is in the CSSF conditional band — passable with documented remediation, but expect questions and an extended authorisation cycle.

4 FTE — needs ≥ 5 to pass
4 meetings — needs ≥ 4
90 days — needs ≥ 110
60 m² — needs ≥ 60 m²

CSSF substance bar is high relative to the perception. The "double-hat" test for cross-border boards is enforced; at least one Luxembourg-resident effective director is required at authorisation.

MFSA (Malta)

Pass

Profile meets MFSA's observed substance floor. Proceed to inspection / authorisation pack on schedule.

4 FTE — needs ≥ 4 to pass
4 meetings — needs ≥ 4
90 days — needs ≥ 90
60 m² — needs ≥ 40 m²

Post-Moneyval, MFSA tightened substance review materially. "Substance over form" is a frequent inspection theme; firms relying on outsourced compliance fail without remediation.

CySEC (Cyprus)

Pass

Profile meets CySEC's observed substance floor. Proceed to inspection / authorisation pack on schedule.

4 FTE — needs ≥ 4 to pass
4 meetings — needs ≥ 4
90 days — needs ≥ 90
60 m² — needs ≥ 40 m²

CySEC has recalibrated substance expectations following EU AMLA-readiness exercises. Board minutes, AML programme execution evidence, and MLRO local activity are now routinely sampled.

Dataset version 2026-05-04

For informational purposes only. This tool is not financial, legal, regulatory, or investment advice. Outputs are directional and based on generalised inputs. Decisions should be taken only after consultation with a qualified adviser on your specific facts — book the full assessment before acting on anything you read here.