The Directors of Bilderlings Pay Limited (hereinafter - “we”, “Bilderlings” or “Bilderlings Group”, the “Company”) present the Strategic Report for the financial year ended 31 December 2025.
Bilderlings Pay Limited is authorised by the Financial Conduct Authority as an Electronic Money Institution under reference number 900637. Bilderlings Pay Limited provides cross-border payment services, multi-currency account infrastructure and associated financial technology solutions to business and individual customers.
This report sets out Bilderlings Group’s purpose, strategy, business model, operational and financial performance, principal risks and uncertainties, and relevant non-financial disclosures for the year under review.
Purpose, Mission and Values
Purpose
Bilderlings Group exists to make international financial activity simpler, more transparent and more accessible for the businesses and individuals it serves. Bilderlings Group pursues this purpose through the development and operation of secure, regulated digital financial infrastructure.
Mission
Bilderlings Group’s mission is to empower businesses and individuals worldwide by providing reliable and accessible cross-border financial services delivered through modern, compliant financial technology.
Values
Bilderlings Group’s operations are guided by the following values, which inform its approach to customers, partners, regulators and employees:
Respect – valuing the contributions of all individuals Bilderlings Group works with.
Integrity – acting ethically and transparently across all activities.
Customer Focus – placing customer needs and interests at the centre of decision-making.
Excellence – applying expertise and discipline to achieve sustainable, high-quality outcomes.
Teamwork – collaborating effectively across functions to deliver shared objectives.
Continuous Improvement – pursuing ongoing enhancements to service quality and the customer experience.
Strategy
Bilderlings Group’s strategy is to build and operate a scalable, regulated digital financial infrastructure platform that enables businesses and individuals to conduct international financial activity efficiently and securely. The strategy is underpinned by four mutually reinforcing pillars:
Global Payment Infrastructure
Bilderlings Group continues to deepen its international payment connectivity across key financial corridors, including the United States–European Union, United States–United Kingdom and United Kingdom–European Union corridors. This is achieved through partnerships with regulated financial institutions, payment networks and technology providers, and through direct access to payment schemes including SEPA, SEPA Instant and SWIFT.
Platform and Ecosystem Development
Bilderlings Group continues to develop its digital financial platform to support integration with fintech companies, digital platforms and corporate partners. Through application programming interfaces (APIs) and technology integrations, partners may embed regulated financial services into their own digital environments, extending Bilderlings Group’s reach without requiring direct customer acquisition.
Technology and Automation
Bilderlings Group continues to implement automation and data-driven technologies to improve operational efficiency, strengthen financial crime controls and enhance service delivery. During 2025, key initiatives included enhancements to fraud detection systems, optimisation of transaction monitoring rule sets, improvements to customer communication tooling and broader operational analytics capabilities.
Sustainable and Disciplined Growth
Management maintains a disciplined approach to capital allocation, reinvesting earnings into platform development, compliance infrastructure and product innovation. Growth is pursued where it can be supported by Bilderlings Group’s regulatory, operational and financial frameworks.
Business Model
Platform Architecture
The Bilderlings Group platform operates across three integrated layers:
Customer Solutions Layer: Customer-facing services comprising multi-currency accounts, cross-border payments, debit and virtual cards, foreign exchange services and digital financial management tools, accessible through a single digital interface.
Payment Infrastructure Layer: Connectivity to global payment systems, including SEPA, SEPA Instant, SWIFT and card network infrastructure, supporting secure and reliable payment processing.
Compliance and Risk Infrastructure Layer: Automated systems supporting digital onboarding and identity verification, transaction monitoring, sanctions screening, fraud detection, safeguarding ofcustomer funds and regulatory reporting.
Revenue Model
Revenue is generated through the following streams:
Payment transaction fees charged on domestic and cross-border transfers.
Card services and interchange revenue from debit and virtual card products.
Premium and tiered pricing plans offering enhanced service features.
Fintech infrastructure services provided to partner platforms.
Customised financial solutions and ecosystem partner services.
Customer Segments
Bilderlings Group serves the following principal customer segments:
International small and medium-sized enterprises (SMEs) conducting cross-border trade.
Corporate clients with multi-jurisdictional financial activity.
Fintech companies and financial institutions requiring embedded payment infrastructure.
Freelancers, digital entrepreneurs and individual customers with international financial needs.
Market Context and Compound Annual Growth Analysis
Global cross-border financial flows are estimated to exceed $190 trillion annually. Continued growth in international trade, digital commerce and global entrepreneurship sustains demand for efficient cross-border financial services. Bilderlings Group believes that the ongoing digitalisation of financial services presents material opportunities for regulated, technology-enabled infrastructure providers operating with strong compliance frameworks.
Bilderlings Group’s own growth trajectory over the period 2022 to 2025 provides relevant context for assessing the scale of the market opportunity and Bilderlings Group’s positioning within it.
Compound Annual Growth Rate Analysis
To provide a consolidated view of Bilderlings Group’s growth trajectory, the Directors have calculated a Compound Annual Growth Rate (CAGR) across the principal KPIs reported in Bilderlings Group’s strategic reports for 2022 to 2025.
Analysis and Market Implications
The CAGR analysis confirms that Bilderlings Group has grown strongly across all principal performance measures over the three years from 2022 to 2025. Revenue has compounded at 25.4% per annum over the period — well ahead of the global cross-border payments market, which leading industry research estimates to have grown at approximately 7–9% per annum over the same timeframe. This gap is indicative of market share gains rather than growth driven purely by broader market conditions.
Customer portfolio growth has been equally compelling, with a three-year CAGR of 47.5% per annum. The Group's ability to sustain acquisition at this rate — as its portfolio has scaled — points to the continued relevance of its product offering, the breadth of its partner integrations and growing recognition in its target markets. Payment transaction volumes have followed a similar trajectory, expanding at a three-year CAGR of 38.9% per annum, reflecting not only a larger customer base but deeper commercial engagement within it.
Taken together, the long-term CAGR profile across all three KPIs reflects compounding, multi-dimensional growth that has consistently outpaced the broader market. Year-on-year moderation in individual metrics is to be expected as the business matures, and the base of comparison grows — this is a normal feature of scaling businesses and does not detract from the strength of the underlying trajectory. Going forward, management expects growth to be increasingly driven by expanding wallet share within the existing customer base, alongside continued new customer acquisition.
Operational Progress in 2025
Platform Development
During 2025, Bilderlings Group continued to strengthen its digital financial infrastructure. Principal developments included:
Development and enhancement of multi-currency account functionality.
Expansion of debit and virtual card services, resulting in card issuance growth of 14% and card transaction activity growth of 7% year-on-year.
Extension of SEPA Instant payment capabilities to improve speed and efficiency for euro-denominated transactions.
Continued integration of SWIFT infrastructure for international transfers.
Enhancements to automated anti-money laundering (AML) systems and digital onboarding processes.
Expansion of banking and payment partner integrations
Technology and Automation
Bilderlings Group expanded its use of automation and artificial intelligence across operational processes. Specific initiatives during the year included:
Enhancements to the customer support environment, including improved chatbot functionality to reduce response times and operational burden.
ntroduction of artificial intelligence-based fraud detection pilots, subject to oversight and human review protocols.
Optimisation of transaction monitoring rule sets to improve detection accuracy and reduce false-positive rates.
Development of operational analytics tooling to support management oversight and regulatory reporting.
All AI and automation deployments are subject to governance and oversight controls to ensure outputs remain consistent with regulatory expectations and Bilderlings Group’s risk appetite.
Commercial and Partner Development
Commercial and partner development activities during 2025 included:
Participation in industry events to develop institutional partnerships.
Launch of the Bilder Partner Portal to facilitate partner integrations and commercial relationships.
Introduction of a customer referral programme.
Enhancement of digital acquisition channels through search optimisation and communication improvements
Financial Performance and Key Performance Indicators
During 2025, Bilderlings Group maintained profitability and a strong capital position, as summarised below.
Financial Summary
The key financial metrics for the year ended 31 December 2025 are set out below:
Revenue: €23,308,608
Net Profit: €4,897,247 (representing a net margin of approximately 21%)
Total Equity: €16,576,464 (35% YoY)
The FY2025 profit moderation from the FY2024 peak reflects two identified factors: normalisation of elevated interest income on safeguarded client funds (which provided a material one-time contribution to FY2024 earnings as eurozone and UK rates moderated), and deliberate investment expenditure associated with the launch of a US entity and preparatory development of a European subsidiary. Neither factor reflects operational deterioration. The 21% net margin remains consistent with the Company’s historical range.
Bilderlings Group’s capital position remains above regulatory minimum requirements. The Directors consider Bilderlings Group to be well capitalised relative to its current risk exposure and operational profile. To strengthen long-term resilience and support sustainable growth, it is proposed that 50% of the 2025 net profit be retained and reinvested in business and service development. The remaining 50% will be distributed to shareholders in the form of dividends.
Operational Key Performance Indicators
The following operational metrics reflect Bilderlings Group’s growth trajectory during the year:
Operational income from rendering of services (Note 3): 5%
Equity growth: 35%
ROE: 41%
Customer portfolio growth: 27%
Payment transaction count growth: 17%
Payment transaction volume growth: 7%
Card issuance growth: 14%
Card transaction volume growth: 7% (representing 11% of total revenue)
The divergence between transaction count growth (17%) and transaction volume growth (7%) reflects a shift in customer mix towards higher-frequency, lower-value transaction profiles during the period. Management monitors this trend as part of ongoing revenue and risk analysis.
Strategic Initiatives 2026–2028
Bilderlings Group has identified the following principal strategic initiatives for the period 2026 to 2028. Progress against these initiatives will be reported in future Strategic Reports.
Global Market Expansion
Further development of international payment corridors and deepening of partnerships with regulated financial institutions across target markets.
Platform Ecosystem Development
Expansion of API-based platform capabilities to enable embedded financial services for a broader range of partners, subject to appropriate due diligence and compliance oversight.
Stablecoin Settlement Infrastructure
During 2026, Bilderlings Group plans to evaluate the feasibility of stablecoin-enabled settlement capabilities to enhance cross-border payment infrastructure. Potential areas of assessment include fiat-to-stablecoin-to-fiat settlement flows, integration with regulated digital asset infrastructure providers, and stablecoin-based liquidity management mechanisms in selected international payment corridors.
Any such developments will be undertaken exclusively within applicable regulatory frameworks, including any requirements arising from the Markets in Crypto-Assets Regulation (MiCA) and related FCA guidance. The Board will assess regulatory permissions required prior to implementation.
Artificial Intelligence and Automation
Further development of AI-driven fraud detection, transaction monitoring and automated onboarding systems. All AI deployments will be subject to explainability, oversight and model governance standards consistent with regulatory expectations.
Compliance and Operational Resilience
Ongoing investment in financial crime prevention frameworks, cybersecurity infrastructure, operational resilience planning and safeguarding arrangements, in line with Bilderlings Group’s regulatory obligations and the FCA’s operational resilience requirements.
Product and Service Innovation
Continued expansion of financial service offerings, with a focus on additional tools for internationally operating businesses and digital entrepreneurs, developed in accordance with Bilderlings Group’s product governance framework.
Organisational Development
Planned expansion of technology, compliance and operational functions to support business growth and maintain adequate resourcing of risk and compliance capabilities.
Principal Risks and Uncertainties
As a regulated Electronic Money Institution, Bilderlings Group is exposed to the following principal risks. The Board is responsible for setting Bilderlings Group’s risk appetite and for overseeing the effectiveness of the risk management framework.
Regulatory Compliance Risk
Risk that Bilderlings Group fails to comply with applicable laws, regulations or regulatory expectations, including the Electronic Money Regulations 2011, the Payment Services Regulations 2017, FCA rules and financial crime legislation.
Mitigation: Bilderlings Group maintains a dedicated compliance function and conducts regular regulatory horizon scanning. Compliance policies and procedures are reviewed on a periodic basis and updated to reflect regulatory developments.
Financial Crime Risk
Risk of Bilderlings Group being used, knowingly or unknowingly, to facilitate money laundering, terrorist financing, fraud or sanctions evasion.
Mitigation: Bilderlings Group maintains a comprehensive financial crime prevention framework encompassing customer due diligence, enhanced due diligence for higher-risk relationships, transaction monitoring, sanctions screening and suspicious activity reporting. The framework is subject to regular internal review and independent audit.
Operational and Technology Risk
Risk of disruption to operational processes or technology systems, whether through system failure, human error or inadequate controls, resulting in service interruption or customer detriment.
Mitigation: Bilderlings Group has implemented operational resilience frameworks consistent with FCA requirements, maintains business continuity and disaster recovery plans, and conducts regular testing of critical systems and processes.
Cybersecurity Risk
Risk of unauthorised access to, or disruption of, Bilderlings Group’s systems or customer data through cyber attack or data security incidents.
Mitigation: Bilderlings Group maintains cybersecurity controls, including access management, encryption, penetration testing and security monitoring. Incident response procedures are in place and reviewed regularly.
Third-Party and Outsourcing Risk
Risk arising from Bilderlings Group’s reliance on third-party providers for material operational functions, including payment network access, banking partnerships and technology infrastructure.
Mitigation: Bilderlings Group maintains a third-party risk management framework, conducts due diligence prior to engagement and monitors ongoing provider performance and financial stability. Material outsourcing arrangements are notified to the FCA where required.
Strategic and Market Risk
Risk that adverse market conditions, competitive pressures, geopolitical developments or macroeconomic factors negatively affect Bilderlings Group’s financial performance or strategic objectives.
Mitigation: Management monitors market and macroeconomic conditions on an ongoing basis and adjusts operational priorities and resource allocation accordingly. Bilderlings Group’s diversified customer base and revenue streams provide a degree of natural resilience.
Environmental, Social and Governance (ESG)
Bilderlings Group integrates environmental, social and governance considerations into its operations and governance framework. The following disclosures are provided in accordance with applicable non-financial reporting requirements.
Environmental
Bilderlings Group operates as a digital financial services business with no significant direct environmental footprint from manufacturing or physical operations. Bilderlings Group maintains paperless customer onboarding processes, reducing paper consumption across the customer lifecycle.
Bilderlings Group supports environmental projects through partnership programmes and enables customer donations to charitable environmental organisations through its platform.
Social
Bilderlings Group is committed to the fair treatment of customers and employees. Customer-facing policies are designed to ensure accessibility, transparency and fair outcomes, consistent with the FCA’s Consumer Duty requirements applicable to Bilderlings Group’s activities.
Bilderlings Group promotes inclusive workplace policies and seeks to attract and retain a diverse workforce. Employee well-being and professional development are considered in Bilderlings Group’s people strategy.
Governance
Bilderlings Group maintains a governance framework commensurate with its size and regulatory status. The Board of Directors is responsible for oversight of strategy, risk, compliance and financial performance. Bilderlings Group operates in accordance with applicable UK corporate governance requirements and FCA regulatory expectations.
Anti-bribery, anti-corruption and conflicts of interest policies are in place and subject to annual review. Whistleblowing arrangements are maintained to enable employees to raise concerns confidentially.
The Directors are required under section 172 of the Companies Act 2006 to act in the way they consider, in good faith, would be most likely to promote the success of Bilderlings Group for the benefit of its members as a whole, having regard to the matters set out in section 172(1)(a)–(f), including:
the likely consequences of any decision in the long term;
the interests of Bilderlings Group’s employees;
the need to foster Bilderlings Group’s business relationships with suppliers, customers and others;
the impact of Bilderlings Group’s operations on the community and the environment;
the desirability of Bilderlings Group maintaining a reputation for high standards of business conduct; and
the need to act fairly as between members of Bilderlings Group.
During the year under review, the Directors had regard to the above matters in making decisions relating to Bilderlings Group’s strategic direction, capital allocation, product development, partner relationships and regulatory engagement.
Stakeholder engagement: The Board maintains ongoing engagement with key stakeholder groups, including customers (through service quality monitoring and complaint management processes), employees (through management communication and HR processes), regulators (through proactive FCA engagement and regulatory reporting), and commercial partners (through the partner management framework). The interests of these groups are considered by the Board in strategic decision-making.
Long-term success: Capital allocation decisions during the year prioritised investment in compliance infrastructure, platform resilience and technology development, reflecting the Board’s view that sustainable long-term growth requires a strong regulatory and operational foundation.
Outlook
Bilderlings Group expects continued development of its platform capabilities and international partnerships during the 2026 financial year. The strategic initiatives identified in the Strategic initiatives part will be the principal focus of management attention and capital deployment.
While growth prospects remain positive, financial performance may be influenced by the prevailing macroeconomic environment, regulatory developments, competitive dynamics and geopolitical conditions. Management will continue to monitor these factors and adjust operational priorities and resource allocation where appropriate.
The Board is satisfied that Bilderlings Group has adequate financial resources and a resilient operating model to continue operating effectively for the foreseeable future.
On behalf of the board
The directors present their annual report and financial statements for the year ended 31 December 2025.
The results for the year are set out on page 14.
There were dividends of €578,019 paid out during 2025.
The directors who held office during the year and up to the date of signature of the financial statements were as follows:
The directors paid a further dividend of €2,100,000 on the 18 February 2026.
The auditor, Gravita Audit II Limited is deemed to be reappointed under section 487(2) of the Companies Act 2006.
We have audited the financial statements of Bilderlings Pay Limited (the 'parent company') and its subsidiaries (the 'Group') for the year ended 31 December 2025 which comprise the group statement of comprehensive income, the Group balance sheet, the Company statement of comprehensive income, the Company balance sheet, the Group statement of changes in equity, the Company statement of changes in equity, the Group statement of cash flows, the Company statement of cash flows and notes to the financial statements, including significant accounting policies. The financial reporting framework that has been applied in their preparation is applicable law and United Kingdom Accounting Standards, including Financial Reporting Standard 102 The Financial Reporting Standard applicable in the UK and Republic of Ireland (United Kingdom Generally Accepted Accounting Practice).
Basis for opinion
Conclusions relating to going concern
In auditing the financial statements, we have concluded that the directors' use of the going concern basis of accounting in the preparation of the financial statements is appropriate.
Based on the work we have performed, we have not identified any material uncertainties relating to events or conditions that, individually or collectively, may cast significant doubt on the group's and parent company's ability to continue as a going concern for a period of at least twelve months from when the financial statements are authorised for issue.
Our responsibilities and the responsibilities of the directors with respect to going concern are described in the relevant sections of this report.
Other information
Opinions on other matters prescribed by the Companies Act 2006
In our opinion, based on the work undertaken in the course of our audit:
The information given in the strategic report and the directors' report for the financial year for which the financial statements are prepared is consistent with the financial statements; and
The strategic report and the directors' report have been prepared in accordance with applicable legal requirements.
The extent to which our procedures are capable of detecting irregularities, including fraud, is detailed below.
We ensured that the engagement team collectively had the appropriate competence, capabilities and skills to identify or recognise non-compliance with applicable laws and regulations. The laws and regulations applicable to the Company were identified through discussions with directors and other management, and from our commercial knowledge and experience of an electronic money institution. Of these laws and regulations, we focused on those that we considered may have a direct material effect on the financial statements or the operations of the Company, including Payment Services Regulations 2017 (PSR 2017), Electronic Money Regulations 2011 (EMR 2011), Financial Services and Markets Act 2000, Financial Services Act 2012, Companies Act 2006, taxation legislation, data protection, anti-bribery, anti-money-laundering, employment, environmental and health and safety legislation. The extent of compliance with these laws and regulations identified above was assessed through making enquiries of management and inspecting legal correspondence. The identified laws and regulations were communicated within the audit team regularly and the team remained alert to instances of non-compliance throughout the audit.
We assessed the susceptibility of the Company’s financial statements to material misstatement, including obtaining an understanding of how fraud might occur, by:
making enquiries of management as to where they considered there was susceptibility to fraud, their knowledge of actual, suspected and alleged fraud;
considering the internal controls in place to mitigate risks of fraud and non-compliance with laws and regulations; and
understanding the design of the Company’s remuneration policies.
To address the risk of fraud through management bias and override of controls, we:
performed analytical procedures to identify any unusual or unexpected relationships;
tested journal entries to identify unusual transactions;
assessed whether judgements and assumptions made in determining the accounting estimates set out in note 2 were indicative of potential bias; and
investigated the rationale behind significant or unusual transactions.
In response to the risk of irregularities and non-compliance with laws and regulations, we designed procedures which included, but were not limited to:
agreeing financial statement disclosures to underlying supporting documentation;
reading the minutes of meetings of those charged with governance;
enquiring of management as to actual and potential litigation and claims; and
reviewing correspondence with HMRC, relevant regulators including the FCA and the Company’s legal advisors.
There are inherent limitations in our audit procedures described above. The more removed that laws and regulations are from financial transactions, the less likely it is that we would become aware of non-compliance. Auditing standards also limit the audit procedures required to identify non-compliance with laws and regulations to enquiry of the directors and other management and the inspection of regulatory and legal correspondence, if any. Material misstatements that arise due to fraud can be harder to detect than those that arise from error as they may involve deliberate concealment or collusion.
A further description of our responsibilities is available on the Financial Reporting Council’s website at: https://www.frc.org.uk/auditorsresponsibilities. This description forms part of our auditor's report.
Use of our report
This report is made solely to the Parent company’s members, as a body, in accordance with Chapter 3 of Part 16 of the Companies Act 2006. Our audit work has been undertaken so that we might state to the Parent company’s members those matters we are required to state to them in an auditor's report and for no other purpose. To the fullest extent permitted by law, we do not accept or assume responsibility to anyone other than the Parent company and the Parent company’s members as a body, for our audit work, for this report, or for the opinions we have formed.
The profit and loss account has been prepared on the basis that all operations are continuing operations.
The notes on pages 22 to 44 form part of these financial statements.
The notes on pages 22 to 44 form part of these financial statements.
The profit and loss account has been prepared on the basis that all operations are continuing operations.
The notes on pages 22 to 44 form part of these financial statements.
The notes on pages 22 to 44 form part of these financial statements.
The notes on pages 22 to 44 form part of these financial statements.
The notes on pages 22 to 44 form part of these financial statements.
The notes on pages 22 to 44 form part of these financial statements.
Bilderlings Pay Limited (“the Company”) is a private limited company domiciled and incorporated in England
and Wales. The registered office is "13 Regent Street, London, England, SW1Y 4LR".
The Group consists of Bilderlings Pay Limited and all of its subsidiaries.
These financial statements have been prepared in accordance with FRS 102 “The Financial Reporting Standard applicable in the UK and Republic of Ireland” (“FRS 102”) and the requirements of the Companies Act 2006.
The financial statements are prepared in euros which is the functional currency of the Company. Monetary amounts in these financial statements are rounded to the nearest €.
The financial statements have been prepared under the historical cost convention, modified to include the revaluation of certain financial instruments at fair value. The principal accounting policies adopted are set out below.
Bilderlings Pay Limited is a subsidiary of Bilderlings Holdings SIA and the results of Bilderlings Pay Limited are included in the consolidated financial statements of Bilderlings Holdings SIA which are available from Jekaba Street 2, Riga, LV-1050, Latvia.
The consolidated group financial statements consist of the financial statements of the parent company Bilderlings Pay Limited together with all entities controlled by the parent company (its subsidiaries) and the Group’s share of its interests in joint ventures and associates.
All financial statements are made up to 31 December 2025. Where necessary, adjustments are made to the financial statements of subsidiaries to bring the accounting policies used into line with those used by other members of the Group.
All intra-group transactions, balances and unrealised gains on transactions between group companies are eliminated on consolidation. Unrealised losses are also eliminated unless the transaction provides evidence of an impairment of the asset transferred.
Subsidiaries are consolidated in the Group’s financial statements from the date that control commences until the date that control ceases.
Entities in which the Group holds an interest and which are jointly controlled by the Group and one or more other venturers under a contractual arrangement are treated as joint ventures. Entities other than subsidiary undertakings or joint ventures, in which the Group has a participating interest and over whose operating and financial policies the Group exercises a significant influence, are treated as associates.
Investments in joint ventures and associates are carried in the Group balance sheet at cost plus post-acquisition changes in the Group’s share of the net assets of the entity, less any impairment in value. The carrying values of investments in joint ventures and associates include acquired goodwill.
If the Group’s share of losses in a joint venture or associate equals or exceeds its investment in the joint venture or associate, the Group does not recognise further losses unless it has incurred obligations to do so or has made payments on behalf of the joint venture or associate.
Unrealised gains arising from transactions with joint ventures and associates are eliminated to the extent of the Group’s interest in the entity.
At the time of approving the financial statements, the directors have a reasonable expectation that the Group and parent company have adequate resources to continue in operational existence for the foreseeable future. Thus the directors continue to adopt the going concern basis of accounting in preparing the financial statements.
Turnover is recognised at the fair value of the consideration received or receivable for services provided in the normal course of business, and is shown net of VAT and other sales related taxes. The fair value of consideration takes into account trade discounts, settlement discounts and volume rebates.
Turnover represents the value of work carried out in respect of services provided and translation of foreign exchange currency fees to customers and interest generated on customer cash balances.
Interest generated from group and client cash balances is recognised using the effective interest rate method on corporate ‘cash and cash equivalents’. The recognition of interest income on client balances is recognised as turnover on the face of the Statement of the Profit and Loss Account.
The gain or loss arising on the disposal of an asset is determined as the difference between the sale proceeds and the carrying value of the asset, and is recognised in the profit and loss account.
Equity investments are measured at fair value through profit or loss, except for those equity investments that are not publicly traded and whose fair value cannot otherwise be measured reliably, which are recognised at cost less impairment until a reliable measure of fair value becomes available.
In the parent company financial statements, investments in subsidiaries, associates and jointly controlled entities are initially measured at cost and subsequently measured at cost less any accumulated impairment losses.
A subsidiary is an entity controlled by the Group. Control is the power to govern the financial and operating policies of the entity so as to obtain benefits from its activities.
An associate is an entity, being neither a subsidiary nor a joint venture, in which the Company holds a long-term interest and where the Company has significant influence. The Group considers that it has significant influence where it has the power to participate in the financial and operating decisions of the associate.
Investments in associates are initially recognised at the transaction price (including transaction costs) and are subsequently adjusted to reflect the Group’s share of the profit or loss, other comprehensive income and equity of the associate using the equity method. Any difference between the cost of acquisition and the share of the fair value of the net identifiable assets of the associate on acquisition is recognised as goodwill. Any unamortised balance of goodwill is included in the carrying value of the investment in associates.
Losses in excess of the carrying amount of an investment in an associate are recorded as a provision only when the Company has incurred legal or constructive obligations or has made payments on behalf of the associate.
In the parent company financial statements, investments in associates are accounted for at cost less impairment.
Entities in which the Group has a long term interest and shares control under a contractual arrangement are classified as jointly controlled entities.
Investments in government bonds are remeasured at amortised cost through profit or loss at each reporting date until maturity.
At each reporting period end date, the Group reviews the carrying amounts of its tangible and intangible assets to determine whether there is any indication that those assets have suffered an impairment loss. If any such indication exists, the recoverable amount of the asset is estimated in order to determine the extent of the impairment loss (if any). Where it is not possible to estimate the recoverable amount of an individual asset, the Company estimates the recoverable amount of the cash-generating unit to which the asset belongs.
The carrying amount of the investments accounted for using the equity method is tested for impairment as a single asset. Any goodwill included in the carrying amount of the investment is not tested separately for impairment.
Recoverable amount is the higher of fair value less costs to sell and value in use. In assessing value in use, the estimated future cash flows are discounted to their present value using a pre-tax discount rate that reflects current market assessments of the time value of money and the risks specific to the asset for which the estimates of future cash flows have not been adjusted.
If the recoverable amount of an asset (or cash-generating unit) is estimated to be less than its carrying amount, the carrying amount of the asset (or cash-generating unit) is reduced to its recoverable amount. An impairment loss is recognised immediately in profit or loss, unless the relevant asset is carried at a revalued amount, in which case the impairment loss is treated as a revaluation decrease.
Recognised impairment losses are reversed if, and only if, the reasons for the impairment loss have ceased to apply. Where an impairment loss subsequently reverses, the carrying amount of the asset (or cash-generating unit) is increased to the revised estimate of its recoverable amount, but so that the increased carrying amount does not exceed the carrying amount that would have been determined had no impairment loss been recognised for the asset (or cash-generating unit) in prior years. A reversal of an impairment loss is recognised immediately in profit or loss, unless the relevant asset is carried at a revalued amount, in which case the reversal of the impairment loss is treated as a revaluation increase.
The Group has elected to apply the provisions of Section 11 ‘Basic Financial Instruments’ and Section 12 ‘Other Financial Instruments Issues’ of FRS 102 to all of its financial instruments.
Financial instruments are recognised in the Group's balance sheet when the Group becomes party to the contractual provisions of the instrument.
Financial assets and liabilities are offset and the net amounts presented in the financial statements when there is a legally enforceable right to set off the recognised amounts and there is an intention to settle on a net basis or to realise the asset and settle the liability simultaneously.
Basic financial assets, which include debtors and cash and bank balances, are initially measured at transaction price including transaction costs and are subsequently carried at amortised cost using the effective interest method unless the arrangement constitutes a financing transaction, where the transaction is measured at the present value of the future receipts discounted at a market rate of interest. Financial assets classified as receivable within one year are not amortised.
Other financial assets, including investments in equity instruments which are not subsidiaries, associates or joint ventures, are initially measured at fair value, which is normally the transaction price. Such assets are subsequently carried at fair value and the changes in fair value are recognised in profit or loss, except that investments in equity instruments that are not publicly traded and whose fair values cannot be measured reliably are measured at cost less impairment.
Financial assets, other than those held at fair value through profit and loss, are assessed for indicators of impairment at each reporting end date.
Financial assets are impaired where there is objective evidence that, as a result of one or more events that occurred after the initial recognition of the financial asset, the estimated future cash flows have been affected. If an asset is impaired, the impairment loss is the difference between the carrying amount and the present value of the estimated cash flows discounted at the asset’s original effective interest rate. The impairment loss is recognised in profit or loss.
If there is a decrease in the impairment loss arising from an event occurring after the impairment was recognised, the impairment is reversed. The reversal is such that the current carrying amount does not exceed what the carrying amount would have been, had the impairment not previously been recognised. The impairment reversal is recognised in profit or loss.
Financial assets are derecognised only when the contractual rights to the cash flows from the asset expire or are settled, or when the Group transfers the financial asset and substantially all the risks and rewards of ownership to another entity, or if some significant risks and rewards of ownership are retained but control of the asset has transferred to another party that is able to sell the asset in its entirety to an unrelated third party.
Financial liabilities and equity instruments are classified according to the substance of the contractual arrangements entered into. An equity instrument is any contract that evidences a residual interest in the assets of the Group after deducting all of its liabilities.
Basic financial liabilities, including creditors, bank loans, loans from fellow group companies and preference shares that are classified as debt, are initially recognised at transaction price unless the arrangement constitutes a financing transaction, where the debt instrument is measured at the present value of the future payments discounted at a market rate of interest. Financial liabilities classified as payable within one year are not amortised.
Debt instruments are subsequently carried at amortised cost, using the effective interest rate method.
Trade creditors are obligations to pay for goods or services that have been acquired in the ordinary course of business from suppliers. Amounts payable are classified as current liabilities if payment is due within one year or less. If not, they are presented as non-current liabilities. Trade creditors are recognised initially at transaction price and subsequently measured at amortised cost using the effective interest method.
Derivatives, including interest rate swaps and forward foreign exchange contracts, are not basic financial instruments. Derivatives are initially recognised at fair value on the date a derivative contract is entered into and are subsequently re-measured at their fair value. Changes in the fair value of derivatives are recognised in profit or loss in finance costs or finance income as appropriate, unless hedge accounting is applied and the hedge is a cash flow hedge.
Debt instruments that do not meet the conditions in FRS 102 paragraph 11.9 are subsequently measured at fair value through profit or loss. Debt instruments may be designated as being measured at fair value through profit or loss to eliminate or reduce an accounting mismatch or if the instruments are measured and their performance evaluated on a fair value basis in accordance with a documented risk management or investment strategy.
Financial liabilities are derecognised when the Group's contractual obligations expire or are discharged or cancelled.
Equity instruments issued by the Group are recorded at the proceeds received, net of transaction costs. Dividends payable on equity instruments are recognised as liabilities once they are no longer at the discretion of the Group.
The tax expense represents the sum of the tax currently payable and deferred tax.
The tax currently payable is based on taxable profit for the year. Taxable profit differs from net profit as reported in the profit and loss account because it excludes items of income or expense that are taxable or deductible in other years and it further excludes items that are never taxable or deductible. The Group’s liability for current tax is calculated using tax rates that have been enacted or substantively enacted by the reporting end date.
Deferred tax liabilities are generally recognised for all timing differences and deferred tax assets are recognised to the extent that it is probable that they will be recovered against the reversal of deferred tax liabilities or other future taxable profits. Such assets and liabilities are not recognised if the timing difference arises from goodwill or from the initial recognition of other assets and liabilities in a transaction that affects neither the tax profit nor the accounting profit.
The carrying amount of deferred tax assets is reviewed at each reporting end date and reduced to the extent that it is no longer probable that sufficient taxable profits will be available to allow all or part of the asset to be recovered. Deferred tax is calculated at the tax rates that are expected to apply in the period when the liability is settled or the asset is realised. Deferred tax is charged or credited in the profit and loss account, except when it relates to items charged or credited directly to equity, in which case the deferred tax is also dealt with in equity. Deferred tax assets and liabilities are offset if, and only if, there is a legally enforceable right to offset current tax assets and liabilities and the deferred tax assets and liabilities relate to taxes levied by the same tax authority.
The costs of short-term employee benefits are recognised as a liability and an expense, unless those costs are required to be recognised as part of the cost of stock or fixed assets.
The cost of any unused holiday entitlement is recognised in the period in which the employee’s services are received.
Termination benefits are recognised immediately as an expense when the Company is demonstrably committed to terminate the employment of an employee or to provide termination benefits.
Rentals payable under operating leases, including any lease incentives received, are charged to profit or loss on a straight line basis over the term of the relevant lease except where another more systematic basis is more representative of the time pattern in which economic benefits from the leased asset are consumed.
Transactions in currencies other than euros are recorded at the rates of exchange prevailing at the dates of the transactions. At each reporting end date, monetary assets and liabilities that are denominated in foreign currencies are retranslated at the rates prevailing on the reporting end date. Gains and losses arising on translation are included in the profit and loss account for the period.
In the application of the Group’s accounting policies, the directors are required to make judgements, estimates and assumptions about the carrying amount of assets and liabilities that are not readily apparent from other sources. The estimates and associated assumptions are based on historical experience and other factors that are considered to be relevant. Actual results may differ from these estimates.
The estimates and underlying assumptions are reviewed on an ongoing basis. Revisions to accounting estimates are recognised in the period in which the estimate is revised where the revision affects only that period, or in the period of the revision and future periods where the revision affects both current and future periods.
The following judgements (apart from those involving estimates) have had the most significant effect on amounts recognised in the financial statements.
Where client balances are held by the Group, as part of its EMI obligations those funds must be held in segregated accounts and must comply with regulatory safeguarding compliance requirements. The Company is permitted to invest customer cash balances in high quality, liquid assets as sanctioned by the FCA. The Group generates interest income from customer cash balances and as a result, has determined that it does have sufficient control over these balances and reward thereof, to include them and their corresponding liability on the Balance Sheet.
The estimates and assumptions which have a significant risk of causing a material adjustment to the carrying amount of assets and liabilities are as follows.
Intangible fixed assets, are amortised over their useful lives taking into account residual values, where appropriate. The actual lives of the assets and residual values are assessed annually and may vary depending on a number of factors. In re-assessing asset lives, factors such as technological innovation, product life cycles and maintenance programmes are taken into account. Residual value assessments consider issues such as future market conditions, the remaining life of the asset and projected disposal values
Investments measured at fair value through profit or loss are revalued at year end using market values for such investments provided by the Group's partner bank.
Tangible fixed assets, are depreciated over their useful lives taking into account residual values, where appropriate. The actual lives of the assets and residual values are assessed annually and may vary depending on a number of factors. In re-assessing asset lives, factors such as technological innovation, product life cycles and maintenance programmes are taken into account. Residual value assessments consider issues such as future market conditions, the remaining life of the asset and projected disposal values
The average monthly number of persons (including directors) employed by the group and company during the year was:
Their aggregate remuneration comprised:
The actual charge for the year can be reconciled to the expected charge for the year based on the profit or loss and the standard rate of tax as follows:
Details of the Company's subsidiaries at 31 December 2025 are as follows:
The investment of client money in government bonds is measured at amortised cost over the period to maturity.
The investment in own money in corporate bonds is measured at amortised costs..
The investments in government and corporate bonds have been made with relevant funds as approved by FCA as secure and liquid and in accordance with the companies safe guarding policy document.
Relevant funds represent safeguarded funds held on behalf of the customers in relation to regulated e-money services.
As per the Groups safeguarding asset investment policy document the Group has not exceeded the 50% maximum of customer money which can be invested in assets.
Fiduciary loan more than one year relates to a two year €1,000,000 loan to Zugspitze Shipping Company registered in the Republic of the Marshall Islands through a Fiduciary Joint Stock Company "BBG" registered in Latvia.
Fiduciary Joint Stock Company "BBG" is a related company through its beneficial owners.
The loan carries an interest rate of 18% interest per annum and commisison of 1% per annum payable to "BBG" Fiduciary Company and is on an arms length basis.
The outstanding loan at the year end was €1,000,000 and is due for repayment at the end of the term on the 31 July 2027.
Own cash at bank represents the Group's own funds held to maintain the ongoing capital at the level sufficient for the needs of regulatory requirements.
Restricted cash at bank and cash equivalents held in respect of customers' represents safeguarded funds held on behalf of customers in relation to regulated e-money services (relevant funds). Relevant funds are held in accounts specifically opened with authorised credit institutions to safeguard Bilderlings clients relevant funds only in line with the FCA's Payment Services and Electronic Money Our Approach document (Approach document).
Part of cash equivalents consists of assets that are approved by FCA as secure and liquid according to the Approach document. As of 31 December 2025, the amount of assets included is €133,850,100 (31 December 2024: €105,877,484), which presents their amortised cost. Of these amounts, €14,850,100 (2024: €16,877,484) consists of government bonds (see note 18, 19) and €119,000,000 (2024: €89,000,000) consists of deposits included above in cash.
Included within Cash at bank and in hand, is an amount of €3,856,411 (2024: €1,535,341) which relates to safeguarding of client money,
Interest generated on customer money of €4,238,978 (2024: €6,498,322) is included in Turnover (see note 3).
The following are the major deferred tax liabilities and assets recognised by the Group and company, and movements thereon:
The deferred tax liability set out above is expected to reverse within 12 months and relates to accelerated capital allowances that are expected to mature within the same period.
During the year ended 31 December 2025, the Company did not issue any new ordinary shares.
At the reporting end date the Group had outstanding commitments for future minimum lease payments under non-cancellable operating leases, which fall due as follows:
On the 18 February 2026 Bilderlings Pay Limited issued interim dividends of €2,100,000 to its shareholders.
On the 16 March 2026 Bilderlings Pay Limited issued a loan of €200,000 to Bilderlings Pay SIA for a term of 3 years for a fixed interest rate of 6% per annum.
During the year the group entered into the following transactions with related parties:
During the year the company was provided technical and support services of € 4,980,000 (2024: €4,500,000) by Bilderlings Pay SIA, a connected company.
During the year the company received loan interest of €65,639 (2024: €Nil) from loan to Zugspitze shipping company through a Fidcuiary " BBG" Joint stock company, a company under common control.
During the year the company received Interest income and fees of €4,432,103 (2024: €6,894,909 and paid interest and fees of €410,145 (2024 : €505,001) to BluOt Bank, the director Aleksandrs Peškovs is the indirect shareholder and the Chairperson of the Council of BluOr Bank,
During the year the company held Investments (Own Money) with BluOr Bank (see Note 15) and held current account and deposit accounts with BluOr Bank which form part of the cash and cash equivalents (see note 19).
The following amounts were outstanding at the reporting end date:
The following amounts were outstanding at the reporting end date: