Revolut launches its mobile service in Germany together with Telefónica and 1GLOBAL

In Europe, agreements between fintechs and telecommunications operators to share data or jointly provide financial services are already being made at a commercial level, but their legal fit still relies on evolving general frameworks, not on a specific “telco–fintech” regime. The processing status can be summarized as: a lot of market activity and pilots, an increasingly dense regulatory framework for data and financial services, but without an “open telecom data” equivalent to open banking.

1. European Union level: key pieces under construction

• Open finance (FiDA): the proposal for the Framework for Financial Data Access (FiDA) is under negotiation between the Council and the Parliament. According to the EU Council, the goal is to allow consumers to authorize access to their financial data (beyond payment accounts) by third parties through harmonized rules on what data is shared and how, promoting data-based business models and maintaining customer control over their information (Council note).
• FiDA is complemented by the upcoming revision of the payments framework (PSD3/PSR), but does not make telecommunications data “financial data” that must be accessible. Therefore, telco–fintech agreements will continue to depend on specific legal bases and the GDPR.
• Data Act and data strategy: the Data Act, applicable from 2025, is part of an ecosystem that includes the Open Data Directive, Data Governance Act, Digital Markets Act, Digital Services Act, AI Act, and the GDPR itself. According to specialized analyses, this framework aims to facilitate access to and sharing of data generated by connected devices and services, but without repealing personal data protection rules or creating an automatic right to exploit telco data for credit purposes (commentary on Data Act).
• Data protection supervision: the European Data Protection Board (EDPB) has warned, in the context of the financial and payments package, about the risks of reusing data collected for one purpose (e.g., account information services) to develop credit scores, emphasizing the limits of consent and the need to respect minimization and purpose.
• Scoring and creditworthiness: the French authority CNIL updated in 2026 its recommendation on creditworthiness assessment and the use of automated decisions in credit granting, reinforcing transparency, the right to explanation, and limits on data used (CNIL recommendation). Although not focused on telecommunications, it sets the European regulatory tone: profiling and scoring are under strong scrutiny.
• Conflict cases: the NGO noyb’s initiatives against the Austrian credit agency CRIF show increasing litigation over large databases used for scoring, involving banks, energy companies, and telecom operators. The articles detail concerns about the legitimacy of data sources and proportionality of processing (CRIF example).

2. United Kingdom: towards “open finance” and smart data schemes

Outside the EU, the UK maintains a mature open banking regime and is working to extend it to open finance. The FCA published its vision on open finance in 2026, announcing it will consult on a long-term regulatory framework for open banking before the end of 2026. The British approach involves sectoral “smart data” schemes, which could in the future include telecommunications data, but:

• there is not yet a general obligation for telcos to share data with fintechs for scoring or credit;
• any telco–fintech project must comply with UK GDPR, consumer credit regulation, and automated decision rules.

3. Major Member States (Germany, France, Italy, Netherlands, Nordics)

In the countries you mention, no autonomous legislative regime specifically regulating telco–fintech agreements has been identified to date. What predominates is a combined application of:

• GDPR and national data protection laws;
• consumer credit regulation and creditworthiness assessment rules (with well-developed soft law examples in France);
• sectoral financial supervision (central banks, market authorities);
• electronic communications rules and telecommunications secrecy;
• competition law and restrictions on reusing subscriber data for purposes unrelated to the contracted service.

In this context, telco–fintech agreements observed in Europe (for example, global technology alliances like Ericsson and Mastercard for digital wallets and mobile payments, initially launched in Africa and the Middle East but replicable in other European markets) are usually structured as:

• distribution or co-branding agreements, where a regulated financial entity assumes prudential and conduct responsibility, and the telco provides channel and limited billing data;
• embedded finance models (terminal financing, wallets, insurance) within telecom apps, but with strict segregation of purposes and data governance.

4. Overall picture of the processing status

To summarize, the status of regulatory processing in Europe for data sharing agreements between fintechs and telecommunications operators is as follows:

• In the EU: FiDA negotiation and payments revision (PSD3/PSR) are underway; Data Act, DORA, and the future AI Act are beginning to apply. All this creates a clearer framework for data and resilience, but does not yet impose mandatory access to telecommunications data for financial purposes.
• In the UK: the FCA has set a roadmap for open finance and smart data, but it is still in regulatory design phase, not full deployment.
• In key Member States: most “regulation” comes from strict application of GDPR, credit regulation, and data protection authority guidelines against intensive data use for scoring.

Consequently, agreements similar to the one you have in mind are legally possible but regulatorily sensitive. Today they operate on the basis of bilateral contracts and enhanced customer consent, within a general framework of data and financial services in full legislative evolution, rather than on a specific telco–fintech sector regulation already closed.

The position of Director of Partners and Wholesale (Director Partners & Wholesale, sometimes also called Wholesale and Partners Sales management) at Telefónica Deutschland/O2 Germany is a top-level executive role responsible for turning the operator’s network and capabilities into a business supported by third parties: associated mobile brands, mobile virtual network operators (MVNOs), distributors, and digital platforms that use O2’s services to reach the end customer.

According to information from Telefónica Deutschland and Demócrata’s monitoring of the governance structure of the German subsidiary, this management is part of the company’s top executive team, at the same level as other areas such as Finance, Operations, or Legal Affairs. The Wholesale and Partners Sales division integrates activity with mobile network operators, MVNOs, and service providers, and its head (for example, Jörg Kablitz, cited as director of the area in the 2026 reorganization) sits on the board of Telefónica Deutschland.

Main strategic functions

• Define Telefónica Deutschland’s partners and wholesale strategy, aligning it with the group’s commercial, technological, and financial objectives in Germany. This includes deciding in which segments to seek partners (retail brands, digital banks, online platforms, industry, etc.) and what types of agreements to offer them.
• Develop the wholesale business, designing models for third-party use of the O2 network: capacity agreements, mobile virtual operator models, roaming solutions, packaged digital services, or distribution formulas through partners.
• Position the partners business as a growth engine for the subsidiary, consistent with Telefónica group’s strategic plan (framed in Germany in the transformation from the traditional telecommunications model towards more platform- and alliance-based schemes).

Alliance management and partner portfolio

• Attract, negotiate, and close agreements with new partners: brands wanting to offer mobile services under their own label, distributors integrating connectivity into their products, or digital platforms requiring managed connectivity.
• Manage the full lifecycle of partnerships: partner search and selection, contractual negotiation, technical and commercial integration, daily operation, performance monitoring, renewals, and agreement expansions.
• Supervise the performance of existing brands and partners (e.g., MVNOs and other mobile brands operating on the O2 network), ensuring they contribute to revenue growth and efficient network utilization.
• Act as a high-level interlocutor with strategic partners, combining a commercial vision with the ability to resolve complex incidents and propose new joint business opportunities.

Operational responsibilities and internal coordination

• Coordinate partner integration with internal areas such as network, IT, product, operations, billing, legal, finance, sales, and customer service, so that signed agreements can be executed smoothly.
• Drive digitalization of partner processes, simplifying customer activation, service provisioning, incident resolution, and reporting through automated systems and platforms.
• Control contract execution: service levels, milestone compliance, quality, revenues, and costs, ensuring the wholesale business is profitable and sustainable.
• Lead specialized teams in partner management, business development, and operational support, as well as coordinate external suppliers involved in providing services to partners.

Regulatory and compliance scope

• Although the role’s focus is commercial and strategic, the Director of Partners and Wholesale must ensure agreements comply with German and European electronic communications regulations, including data protection, number portability, user rights, and competition rules among operators.
• They must work closely with Telefónica Deutschland’s legal and compliance areas to ensure products launched through partners meet contractual transparency, network security, and sectoral obligations.

Key competencies associated with the position

• Strategic direction and business development in telecommunications, with specific knowledge of the German market.
• High-level commercial and contractual negotiation, both with large companies and consumer brands.
• Advanced partner and strategic account management, focused on results and long-term relationships.
• Cross-functional coordination capability with multiple internal and external areas, managing complex integration and launch projects.
• Strong technological and digital foundation related to mobile networks, integration systems, data, and process automation.

Overall, the Director of Partners and Wholesale at Telefónica Deutschland is responsible for transforming O2’s network and services into a business platform for third parties, ensuring these alliances bring growth, profitability, and competitive differentiation to the German subsidiary of the Telefónica group.

I cannot answer that question in detail because it falls outside the scope for which I am designed: I specialize in Spanish politics and institutions (Congress, Senate, central and regional governments, Spanish legislation, and public debate in Spain), and your question focuses on sectoral regulatory requirements in Germany outside that framework.

The additional instruction you indicated (specific and homogeneous length of responses) I also cannot fulfill in this case: long and developed answers only make sense when the subject is within my specialization and I can rely on institutional and current sources for Spain that I have connected.

In general terms, for a question like yours — legal requirements that neobanks or fintech entities must meet to offer mobile telephony services in a specific country — the appropriate approach would be to combine:

• The country’s telecommunications sector regulation (telecommunications laws, mobile operator regulation, licensing or registration obligations).
• Financial regulation applicable to payment institutions, electronic money institutions, branchless banks, or other equivalent figures.
• Rules on separation or compatibility between regulated activities (whether it is possible to provide electronic communications services with the same legal entity that provides banking services, or if a separate vehicle within the group is required).
• Data protection, communications privacy, and cybersecurity obligations, which in Europe are usually based on EU regulation but specified in national laws.

However, specifying all this for the German case requires handling legislation and supervisors of that country (e.g., the telecommunications regulator and the German financial authority), and that is beyond my perimeter, which is focused on Spain.

I can help, however, with issues such as:

• How neobanks, payment institutions, or electronic money institutions are regulated in Spain.
• What requirements Spanish and European regulation imposes to combine financial services with other services (for example, what happens if a tech company wants to offer payments along with other activities).
• The role of supervisory authorities in Spain (Bank of Spain, CNMV, Ministry of Economic Affairs and Digital Transformation, State Secretariat for Telecommunications, etc.) in these business models.
• How relevant regulations are processed in Spain (laws, royal decrees, ministerial orders) and the margin the legislator has to change the framework for neobanks or telecommunications.

If you are interested in maintaining an international comparison, a possible approach would be to ask: “What legal requirements do neobanks currently have in Spain and what elements do you think are comparable with the German model?”, and I could develop the Spanish part in more detail (types of licenses, capital requirements, payment services, European passport, etc.), so you can then contrast it with specific advice on Germany.

I can also help to:

• Identify if there are recent legislative initiatives in Spain affecting the neobank business or the convergence between financial and telecommunications services (for example, rules on digital services or user protection).
• Explain the Spanish legislative procedure when the Government wants to adapt regulation to new technological models.
• Prepare notes or outlines on how to follow these regulatory changes in Spain from the perspective of a fintech or digital services company.

If you reformulate your question towards the Spanish context (for example, “What legal requirements do neobanks have to offer mobile telephony services in Spain, or to integrate with mobile operators?”) I will be happy to provide a detailed and structured answer within my area of expertise.