When Your Business Becomes a Bank

Embedded finance for non-financial companies: the opportunity, the routes in, and the controls that make it work

Reading Time: 4 Minutes

9/24/2026

A supermarket offering instalments at checkout. A telecom operator with a mobile wallet. A developer collecting payments through app. non-financial brands are becoming the front door to financial services, and the responsibility that comes with it is real.

Finance where the customer already is

Embedded finance allows a non-financial company to offer financial services, such as payments, digital wallets or instalment options, inside its own customer journey. A licensed financial institution typically provides those services, while the company focuses on the customer experience.

Interest is growing as customers expect simple digital experiences and technology makes it easier to work with licensed partners. Retailers are adding instalments at checkout, telecom operator’s wallets and bill payments, and mobility platforms instant payouts.

Done well, it creates value on all sides: convenience for customers at the moment of need, deeper relationships for businesses, and new reach for licensed institutions through trusted brands.

Two routes in: partner now, licence later

Regulation follows the activity, not the brand. Offering short-term credit, stored value, payment services or open finance services brings a company into the Central Bank's framework, whatever the delivery channel. There are two legitimate ways in, often used in sequence.

The first is to partner with a licensed institution: faster to market and lighter on capital. The partner holds the licence and obtains any approval required, while the company builds customers, revenue and a compliance track record. The second is to obtain your own licence, for stored value, retail payment services or finance activity. Approval takes longer and capital and governance requirements are higher, but you gain full control of products, economics and customers. The first route builds the evidence for the second.

Two boundaries matter. Technology providers serving only licensed institutions are generally outside the perimeter, unless they carry out, or present themselves as carrying out, a licensed activity. And short-term credit must come from a licensed entity or partner, within the limits set per borrower.

Partnering works when responsibilities are clear

A licensed partner is the right foundation for many embedded models, but a partner's licence does not settle every question. Customers, regulators and the media look first at the brand the customer dealt with. The strongest partnerships agree, in writing and in practice, who owns each area below, and test those arrangements before launch.

Area	The question to settle
Onboarding and KYC	Who captures customer data, who approves it, and who keeps the records?
Fraud prevention	Who monitors transactions and notifies customers?
Complaints and conduct	Who handles disputes, disclosures, affordability checks and collections?
Customer funds	Who holds wallet balances and float, and how are they safeguarded?
Data and privacy	Who controls customer data, consent and security?
Continuity and exit	What happens to customers if the partner has an outage or the partnership ends?

Finance teams have their own questions. Is the company principal or agent, which decides gross or net revenue presentation? If credit sits on the balance sheet, expected credit losses must be provided for. And partner data must reconcile to a standard the auditor can rely on.

How Crowe helps

Crowe supports businesses and their partners across the full journey, so management can stay focused on growth. Before you commit, we run feasibility and readiness reviews, compare the partner route against an own licence pathway, and assess where the regulatory perimeter sits. As the model takes shape, we build the business plan, financial and operating model, help select bank and technology partners, and structure contracts so responsibilities are clearly allocated.

Through approval and launch, we coordinate due diligence and compliance packs, plan for regulatory and in-principal approvals, and manage the programme to go-live. Afterwards, we support compliance monitoring and reporting, track performance against plan, and advise on scaling towards an own licence. The outcome: faster entry, fewer surprises, and a clear path to independence.
Embed the finance.

Embed the controls too.

Embedded finance is one of the most practical growth levers available today, and partnering with a licensed institution is a sensible way to start. But the moment a company handles customers' money or credit; it shares in a financial institution's responsibilities. A partnership is not a shortcut; it is the first step on a longer journey.

Three principles separate the programmes that last: clear ownership, with a named owner and agreed roles for each partner; controls built by design, before launch rather than after; and assurance that scales, with more monitoring and review as volumes grow.

The winners will design their controls as deliberately as their customer experience.

FIVE QUESTIONS FOR THE BOARD

Which regulated activity are we performing, and under whose licence?
Are responsibilities with our partner written down and tested?
What happens to our customers if the partnership ends?
How will credit, customer funds and revenue shares show in our accounts?

Who in our organisation owns this risk, and how is it reported?

To discuss embedded finance, licensing or regulatory readiness, contact Crowe UAE’s Fintech & Banking, Governance, Risk & Compliance team at +971 52 373 4662 or [email protected]

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