The day Germany's comparison-site fines crossed the European passport

How we got here

A decade ago Europe decided that comparing current accounts should not be a privilege: the 2014 Payment Accounts Directive requires every country to guarantee consumers at least one fee-comparison website. In Germany that comparison site is run today by BaFin itself: a public database of some 1,100 providers and 6,600 account tariffs, where anyone offering accounts to German consumers must report their models and fees in standardised terminology. The law behind it, the ZKG, devotes a section, §17, to the reporting duty, and it binds every payment-account provider: bank or not.

And the database was already biting. This year BaFin had been fining local banks for the same failure: 10,000 euros for Volksbank Senden, 12,500 for the Alxing-Brucker cooperative. The database had spent months fining banks at home. Yesterday, on what has been published so far, is different: the bank bunq sells from Amsterdam, the bank BforBank from Paris, and Wise Europe, which is not a bank, from Brussels. None of them needs a German licence; the EU passport is enough. What the passport does not remove are the local consumer duties of the country where they sell.

What moves the thesis today

On August 26 BaFin published all three decisions. bunq: fines totalling 28,000 euros (final since August 4) for faulty or missing reports to the comparison site, cost information left unpublished for an extended period, and non-standard terminology. BforBank: 27,500 euros (final since July 31) for not reporting its account model, with partly incorrect fee information and an incomplete glossary. Wise Europe: 16,000 euros (final since August 1) for likewise failing to report the account model it offers in Germany, with the same breaches of information duties. The package of failures is nearly identical across the three files.

All three decisions sit on BaFin's website and German outlets are already covering them. In the English-language financial press, as this edition closes, no trace.

The mechanism

The EU passport moves the licence, not the operation. Selling accounts in Germany carries duties that do not travel with the passport: feeding the official comparison site, publishing fee information the way local law requires, using the standardised terminology. That is how the European map is deliberately drawn: the host country's consumer rules are enforced by the host, not by the supervisor back home. It is plumbing, and that is why it gets neglected: it makes no headlines, the home supervisor does not look at it because it is not its job, and the fine for ignoring it costs less than a marketing campaign.

The average German picks a bank on private comparison sites, and BaFin itself describes its own as the tool that gives consumers a first orientation when looking for an account. But it is the yardstick the law uses to measure whether you are present in the market, and there sits the irony the decision does not spell out: the failure being punished is, precisely, transparency. Not the marketing kind, the mandatory kind. And the series says something more: the same database just caught the same failure in a Dutch, a French and a Belgian firm, and German banks fall too, so what the photo shows is reach: Germany just bit three foreign firms at once.

What we watch

Three things. Whether the series keeps crossing borders: BaFin's sanction list sits in the open and can be counted, and more passported entities in it would turn yesterday's snapshot into supervisory policy. Whether bunq, BforBank and Wise Europe fix their comparison-site entries, which is the part customers feel. And whether other host supervisors (France, Spain and Italy carry the same European comparison-site mandate) start looking at passported banks with the same lens. Next time a neobank brags about its passport, ask about the comparison site of every country where it sells.