Regulatory status: a technical service provider, not a payment institution
Licensed software and infrastructure for regulated payment institutions, acquirers and PSPs. We are a technical service provider: we never hold, receive, transfer or settle funds, are not a party to any payment, do not contract with or onboard merchants and do not perform KYC. Card data is processed under PCI DSS as a service provider on behalf of our licensed clients.
Where the law says so directly
Several jurisdictions exclude technical service providers from payment regulation in so many words, as long as the provider never enters into possession of the funds and does not provide payment initiation or account information services:
- European Union — PSD2 (Directive (EU) 2015/2366), Article 3(j): services provided by technical service providers that support the provision of payment services without entering at any time into possession of the funds. The revised framework (PSR) keeps the exclusion.
- United Kingdom — Payment Services Regulations 2017, Schedule 1, Part 2, paragraph 2(j); FCA PERG 15.5.
- United States (federal) — 31 CFR 1010.100(ff)(5)(ii)(A): a person that only provides the delivery, communication or network access services used by a money transmitter is not a money transmitter.
- United Arab Emirates — CBUAE Retail Payment Services and Card Schemes Regulation, Exclusions 6.1–6.7.
- Saudi Arabia — SAMA Implementing Regulations of the Law of Payments and Payment Services, Article 7(9).
- Türkiye — Law 6493, Article 12(2)(g).
- Kazakhstan — Law on Payments and Payment Systems, Article 12, paragraph 2, subparagraph 5: technological support of payment services is not a payment service.
- India — RBI Payment Aggregators Directions 2025, paragraphs 4(j) and 10(g): a payment gateway provides technology without handling funds and is outside the Directions.
- Singapore — Payment Services Act 2019, First Schedule, Part 2, paragraph 2(h).
- South Korea — Electronic Financial Transactions Act, Article 28(3)(2): transmitting payment information without direct involvement in the transfer of funds needs no registration.
How the flow of funds works
| Step | Who holds the money | What Tranzify does |
|---|---|---|
| The payer pays | The payer’s bank or wallet, then the provider | Routes the request to the provider the client’s rules chose; records the attempt |
| The provider confirms | The provider, on the client’s account with it | Verifies the callback, updates the status, notifies the merchant |
| Settlement to the client | The provider pays the client’s account | Records the settlement the provider reports in the ledger |
| Settlement to the merchant | The client pays the merchant from its own accounts | Shows the balance, the fees and the reserve; prepares the instruction the client approves |
| Payout to a recipient | The client’s account with the provider pays the recipient | Instructs the provider, records the result |
| Refund or chargeback | The provider and the client’s accounts | Records the event, updates the ledger, notifies the merchant |
At no step does money pass through an account of Tranzify Tech. The ledger is a record of what the client’s accounts hold and owe, kept for the client; it is not an account.
What stays with us
- PCI DSS as a service provider: card numbers are stored and tokenised in an encrypted vault under our clients’ instructions.
- Data protection: we process personal data as a processor under a data processing agreement with each client.
- Information security: journals of every payment for five years, audit trails, zero-downtime releases, and deployment in the client’s own cloud account when required.
What stays with our clients
The licence or registration in every country they serve; the contracts with merchants and with providers; the onboarding, KYC and KYB of merchants and, through their partners, of payers; AML and sanctions screening of transactions; the holding and settlement of funds; the handling of disputes and chargebacks; the reports to their regulators. The platform gives them the records and the tools; the obligations are theirs, and the agreement says so in plain terms.
How our clients use this
Our clients are the licensed parties: they contract with merchants, perform KYC and AML checks, hold and settle funds. Tranzify gives them the software that routes, cascades, tokenises and reports. In countries where a hosted gateway itself requires registration regardless of handling funds — among them Canada, Ukraine, Indonesia, Vietnam, the Philippines, Nigeria, Kenya, South Africa and Australia — the platform is operated under the client’s own licence and registration and domain, and the licensed local providers perform the intermediation; Tranzify contracts there with licensed or registered companies only.
What we do not claim
We do not claim to be regulated, supervised or licensed as a payment institution anywhere, and we do not claim that no regulation applies to us: company law, data protection law, the card schemes’ standards and the general law of the countries where we operate all do. We claim one thing: we provide no payment service and need no payment licence, because we never hold, receive, transfer or settle funds, and our clients are licensed where they operate.
This page describes our position; it is not legal advice. Each client confirms its own obligations in its own jurisdictions.
Updated: 2026-11-08