Bunq, the Dutch challenger bank, has submitted a new application for a national US banking licence with the Office of the Comptroller of the Currency. This marks a return to the process after its earlier attempt in 2024 did not proceed to approval.
The updated filing reflects Bunq’s continued commitment to entering the US market. It also reflects changes in the US regulatory environment, where authorities have shown more openness to challenger banks in recent years. Other fintech companies including PayPal, Nubank and Coinbase have also pursued US banking charters in this period.
Why Bunq Is Trying Again
Bunq’s first effort to secure a US banking charter was withdrawn in 2024. The company faced friction between Dutch regulators and US authorities which created uncertainty about whether the application would be successful. Rather than risk a prolonged process that could distract from other parts of the business, Bunq chose to step back.
Since then, Bunq has taken a more gradual approach to US expansion. In 2025 the company received approval from the Financial Industry Regulatory Authority for a broker-dealer licence. That licence allows Bunq to offer investment services such as stocks and mutual funds in the US. It has allowed the company to start building a presence and a customer base without full banking operations.
The new national banking licence application builds on those foundations. If approved, Bunq would be able to take customer deposits in the US and offer a broader range of retail banking products. Bunq’s proposal includes helping customers build US credit histories by using their European financial data to inform credit scoring. This is a clear attempt to address a common challenge faced by internationally mobile customers.
What Bunq Is Targeting
Bunq has more than 20 million users in Europe. The bank has built a reputation among tech-savvy and globally mobile customers such as expats, frequent travellers, and remote workers. The company sees the US as a natural next market for these users. It plans to focus initially on metropolitan areas with significant expatriate and internationally mobile populations.
Bunq’s strategy suggests it plans to pursue a measured entry rather than compete directly with large US banks from the start. By focusing on a specific niche where existing solutions are weak, Bunq can demonstrate value quickly. Helping customers establish credit histories addresses a real pain point for many people who relocate to the US.
Why This Matters for Fintech
Bunq’s renewed bid is part of a wider trend of fintech firms engaging with US banking regulators. For startups considering global expansion, this trend offers useful insights. Securing a US banking licence is difficult. But recent activity shows that progress can be made with the right strategy and timing.
Using intermediary licences to build local presence while pursuing more comprehensive permissions is one approach to consider. Listening to customer needs in the target market can help refine service offerings and prioritise features that matter most.
Key takeaways for fintech startups
- Regulatory environments change over time which can open new opportunities.
- Building a presence with intermediate licences helps when pursuing larger licences.
- Targeting specific user needs can make market entry more effective.
- Cross-border expansion requires alignment with both home and host regulators.
If you are planning to expand into new markets or navigate complex regulation, reach out to Your Fintech Story to explore practical strategies for growth.
