BaFin, Germany’s Federal Financial Supervisory Authority, disclosed on August 26, 2026 three fines against institutions that failed to feed its public payment account comparison website properly. bunq B.V. is paying €28,000, BforBank €27,500, and Wise Europe SA €16,000, for a total of €71,500. The decisions became final between late July and early August 2026.
The amounts are small by the standards of prudential penalties. What matters is the conduct being punished. The comparison database is built entirely from what providers report, and the regulator has no way of reconstructing it on its own. A missing filing does not just leave one institution poorly described: it skews the comparison for the whole segment.
Unreported accounts, faulty fee documents, and nonstandard terms
- All three failed, over an extended period, to report to BaFin the account models they offer to consumers in Germany.
- All three were faulted for an incomplete or inaccurate fee information document and glossary.
- bunq and BforBank used service names that departed from the standardized payment account terminology.
The reporting deadlines are tight. A new account model, or a change to any comparison criterion, must be reported within three business days. A second, separate obligation requires firms to keep their fee information easily accessible to consumers through their own channels. Breaches of each are penalized separately.
| Institution | Home base | Home supervisor | Fine |
|---|---|---|---|
| bunq B.V. | Amsterdam, Netherlands | De Nederlandsche Bank | €28,000 |
| BforBank | France, Crédit Agricole group | ACPR | €27,500 |
| Wise Europe SA | Brussels, Belgium | National Bank of Belgium | €16,000 |
EU law requires a free, public comparison website
Article 7 of Directive 2014/92/EU of July 23, 2014, the Payment Accounts Directive, requires every EU member state to give consumers free access to at least one website that compares the fees payment service providers charge. Germany transposed the requirement in its Zahlungskontengesetz, the Payment Accounts Act, and assigned BaFin to run the site.
The German comparison website went live on January 15, 2025. It lists about 6,900 checking and basic payment accounts, all based on providers’ own filings. Figures cited in the trade press when the fines were announced put the count at about 1,100 providers and 6,600 payment account tariffs. A model that is missing from the database escapes comparison, and consumers have no way of noticing.
Licensed in one country, bound by another’s disclosure rules
All three firms operate in Germany from another member state. bunq is a Dutch bank. Wise Europe SA is a Belgian e-money institution. BforBank is Crédit Agricole’s online bank, supervised by the ACPR, France’s banking supervisor, and has been in the German market since 2024. Their prudential supervision sits with their home country, but the duty to report to the comparison website falls under the law of the country where the account is offered.
France compares services, not whole accounts
France gave the same job to the Financial Sector Advisory Committee (CCSF) under Decree No. 2015-1432 of November 5, 2015. Its website, tarifs-bancaires.gouv.fr, compares 15 services across about 150 credit institutions that account for more than 98% of the French market. The scope differs from the German site, which describes entire account models rather than a list of individual services.
All three cases involve firms that market themselves as digital alternatives to branch-based banks, and whose pitch leans heavily on clear pricing. The obligation at issue has nothing to do with fraud prevention or solvency. It concerns comparability, a longer-standing goal of EU payment account law, and enforcing it depends on a chain of administrative filings that customers never see.