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Dr. Bernd Fletzberger

Partner and attorney at law

Bernd heads the Banking & Finance team at PFR Attorneys at law. He has many years of experience in advising banks, payment and e-money institutions, fund companies and managers, investment firms, insurance companies, pension funds, fintech firms and crypto service providers. He advises on all aspects of financial markets law, in particular regulatory matters. He is recognised by Chambers, Legal 500 and Juve as a leading Austrian lawyer in banking & finance as well as fintech law.

Practice areas

Curriculum

  • PFR Attorneys at law (since 2008)

  • Lecturer in Banking and Finance, FH des bfi Vienna (2007 to 2010)

  • Bar exam (2008)

  • Binder Grösswang Attorneys at law (2007 to 2008)

  • Austrian Financial Market Authority (2003 to 2006)

  • Dorda Attorneys at law (2001 to 2002)

  • Doctoral studies in law, University of Vienna (2001 to 2003)
  • Law studies, Universities of Vienna and Maastricht (1995 to 1999)
Languages
German, English

Contact

Phone +43 1 877 04 54
Mail This email address is being protected from spambots. You need JavaScript enabled to view it.

Bernd Fletzberger hat fundiertes Fachwissen und eine strategische Herangehensweise.

 

Juve Ranking 2024

PFR hat sich als Top Kanzlei im regulatorischen Bereich etabliert, insbesondere wenn es um Anti-Geldwäsche geht.

Juve Ranking 2024

Bernd Fletzberger ist einer der wenigen Anwälte, der im Bereich Payments aktiv ist.

Juve Ranking 2024

Bernd Fletzberger of PFR Rechtsanwälte is known in the market for his expertise in a broad range of banking and finance regulatory issues. He offers strength in fintech-related matters, including payment services and cryptocurrencies. He also has good experience advising on mandates relating to the FMA.

Chambers Europe Guide 2024

Bernd always makes sure to proactively take up issues and pushes them forward. He stands for excellence and state-of-the-art approach.

Chambers Europe Guide 2024

Bernd Fletzberger knows all the details and knows where the regulator is leaning.

Chambers Europe Guide 2024

We really value Bernd's diligent work and know-how, and his ability to convey complex matters in a way that can be easily understood by someone who is not an expert on legal language.

Chambers Europe Guide 2024

Deep knowledge of the banking regulatory framework combined with an understanding of the goals, processes and expectations of the regulator.

Legal 500 Guide 2024

The focus is on pragmatic business law advice and innovative legal solutions for special issues.

Legal 500 Guide 2024

    Latest publications

    Current problems with abusive payments
    Current problems with abusive payments

    Current problems with abusive payments –authorised or not, that is the question! (together with Christopher Falke), ZFR 2024/170, 364

    Handbook Payment Traffic 4.0
    Handbook Payment Traffic 4.0

    Payment services covered by the ZaDiG 2018 and the e-money business in accordance with the E-GeldG 2010 (together with Christian Steiner), in Tuder (Hrsg), Handbuch Zahlungsverkehr 4.0 / FinTechs – Krypto-Assets – Sandbox & Co. (2024)

    ECJ rulings on the Money Laundering Directive
    ECJ rulings on the Money Laundering Directive

    ECJ rulings on the Money Laundering Directive (together with Sanijel Ficulovic), FACTS 1/2023, 16

    ECJ on the enhanced due diligence obligations under the FM-GwG
    ECJ on the enhanced due diligence obligations under the FM-GwG

    ECJ on enhanced due diligence obligations under the FM-GwG and what Nord Stream 2 and KYCC have in common (together with Sanijel Ficulovic), ZFR 2023/53, 113

    The European Commission's anti-money laundering package
    The European Commission's anti-money laundering package

    The European Commission's anti-money laundering package - the longed-for big one? (together with Miriam Broucek), ZFR 2022/59, 117

    Legal commentary regarding § 21 Banking Act
    Legal commentary regarding § 21 Banking Act

    § 21 BWG (together with Angelo Sacilotto) in Laurer/M.Schütz/Kammel/Ratka (Hrsg), Kommentar zum BWG (2022)

    Expectations for dealing with sustainability risks
    Expectations for dealing with sustainability risks

    Expectations for dealing with sustainability risks (together with Miriam Broucek), Raiffeisenblatt 11/2021, 13

    EBA Opinion on easy access to payment accounts
    EBA Opinion on easy access to payment accounts

    EBA Opinion on aasy access to payment accounts, ZFR 2021/62, 155

    Administrative penalties against legal entities under financial market law
    Administrative penalties against legal entities under financial market law

    Administrative penalties against legal entities under financial market law, ZFR 2020/261, 597

    Deceptive calm in administrative criminal law
    Deceptive calm in administrative criminal law

    Deceptive calm in administrative criminal law (together with Rainer Wolfbauer), ZFR 2020/260, 593

    The amended scope of application of PSD2 and the ZaDiG 2018
    The amended scope of application of PSD2 and the ZaDiG 2018

    The amended scope of application of PSD2 and the ZaDiG 2018, ZFR 2018/162, 325

    Preventing money laundering with regard to new payment methods
    Preventing money laundering with regard to new payment methods

    Preventing money laundering with regard to new payment methods, in Wohlschlägl-Aschberger (Hrsg), Geldwäscheprävention (2018)

    Legal commentary regarding §§ 69 bis 71 Banking Act
    Legal commentary regarding §§ 69 bis 71 Banking Act

    §§ 69 to 71 BWG in Laurer/M.Schütz/Kammel/Ratka (Hrsg), Kommentar zum BWG (2017)

    Legal commentary of §§ 1 to 5 Insurance Supervisory Act 2016
    Legal commentary of §§ 1 to 5 Insurance Supervisory Act 2016

    §§ 1 to 5 VAG 2016 in Korinek/G.Saria/S. Saria (Hrsg), Kommentar zum VAG (2016)

    Legal commentary of sections 365m to 365z of the Trade Act
    Legal commentary of sections 365m to 365z of the Trade Act

    §§ 365m bis 365z (AML provisions) in Ennöckl/N.Raschauer/Wessely (Hrsg), Kommentar zur GewO (2015)

    ECB supervision - impact on smaller institutions
    ECB supervision - impact on smaller institutions

    ECB supervision - impact on smaller institutions?, Raiffeisenblatt 9/2014, 6 

    Basel III and Corporate Governance
    Basel III and Corporate Governance

    Basel III and Corporate Governance, in ZFR Spezial – von Basel III zu PRIPS (2014)

    Prohibition of a life insurance tariff by the FMA unlawful
    Prohibition of a life insurance tariff by the FMA unlawful

    Prohibition of a life insurance tariff by the FMA unlawful, ZFR 2013/187, 318

    EU Commission proposal on the Payment Services Directive
    EU Commission proposal on the Payment Services Directive

    EU Commission proposal on the Payment Services Directive, ZFR 2013/163, 289

    Draft for a Bank Intervention and Restructuring Act
    Draft for a Bank Intervention and Restructuring Act

    Draft for a Bank Intervention and Restructuring Act, ZFR 2013/58, 99

    Commission proposal for a directive on the crisis management of credit institutions
    Commission proposal for a directive on the crisis management of credit institutions

    Commission proposal for a directive on the crisis management of credit institutions - a first analysis, ZFR 2012, 298 

    The new Media Transparency Act
    The new Media Transparency Act

    In force from July: The new Media Transparency Act, Compliance Praxis 2012/2, 6

    New rules for electronic money
    New rules for electronic money

    New rules for electronic money, ZFR 2011/26, 50

    Legal commentary of sections 16, 23 and 24 Investment Services Act (2012)
    Legal commentary of sections 16, 23 and 24 Investment Services Act (2012)

    §§ 16, 23, 24 in N. Raschauer/Gruber, Großkommentar zum Wertpapieraufsichtsgesetz 2007

    ZFR Spezial - Compliance and financial market law
    ZFR Spezial - Compliance and financial market law

    Compliance and regulatory law - basis, organisation and competences, in ZFR Spezial - Compliance and financial market law (2011)

    Will e-money be woken from its slumber?
    Will e-money be woken from its slumber?

    Will e-money be woken from its slumber?, Die Presse, Rechtspanorama, 27.9.2010

    Non-binding standard insurance terms and conditions on the brink of extinction?
    Non-binding standard insurance terms and conditions on the brink of extinction?

    Non-binding standard insurance terms and conditions on the brink of extinction?, AssCompact 2010/4

    National Rescue Measures in response to the current financial crisis
    National Rescue Measures in response to the current financial crisis

    National Rescue Measures in response to the current financial crisis, in: European Central Bank (Hrsg), Legal Working Paper Series No 8 / July 2009

    Disclosure of major transactions with related parties
    Disclosure of major transactions with related parties

    Disclosure of major transactions with related parties pursuant to the Stock Exchange Act, ZFR 2009/2, 45

    EU will strictly regulate rating agencies
    EU will strictly regulate rating agencies

    EU will strictly regulate rating agencies, Wirtschaftsblatt vom 5.2.2009

    New investor compensation
    New investor compensation

    New investor compensation, ZFR 2009/18, 34f

    Regulatory provisions for insurance companies regarding AML
    Regulatory provisions for insurance companies regarding AML

    Regulatory provisions for insurance companies, in Wohlschlägl-Aschberger (Hrsg), Money Laundering prevention: practical measures for companies (2009)

    Income taxation of life insurance policies
    Income taxation of life insurance policies

    Income taxation of life insurance policies, AssCompact 2008/11, 30

    Insurance tax for unit-linked life insurance policies
    Insurance tax for unit-linked life insurance policies

    Insurance tax for unit-linked life insurance policies, AssCompact 2008/9, 56

    On the road to Solvency II - Part 2
    On the road to Solvency II - Part 2

    On the road to Solvency II - Part 2 (together with Karin Harreither), ZFR 2008, 206

    Prospectus Supervision in Austria
    Prospectus Supervision in Austria

    Prospectus Supervision in Austria – Guidance form the Supervisor (together with Michael Binder), IBA Securities Newsletter, November 2007

    On the road to Solvency II - Part 1
    On the road to Solvency II - Part 1

    On the road to Solvency II - Part 1 (together with Karin Harreither), ZFR 2007, 124

    Regulatory assessment of second-hand policies
    Regulatory assessment of second-hand policies

    Regulatory assessment of second-hand policies, VersR 11/2006, 13 ff

    On the admissibility (under public procurement law) of “consortial pension fund tenders”
    On the admissibility (under public procurement law) of “consortial pension fund tenders”

    On the admissibility (under public procurement law) of “consortial pension fund tenders” – comments to VKS Wien 13.3.2006, VKS-248/06, ZFR 2006, 113 ff.

    Prohibition of a life insurance tariff pursuant to § 104 para 1 VAG
    Prohibition of a life insurance tariff pursuant to § 104 para 1 VAG

    Prohibition of a life insurance tariff pursuant to § 104 para. 1 VAG – comments to VwGH 26.9.2006, 2006/17/0132, ZFR 2006, 102 f

    Second-hand policies: a legal inventory
    Second-hand policies: a legal inventory

    Second-hand policies: a legal inventory, ÖZW 2006, 70 ff

    Cross-border activities of institutions for occupational retirement provisions
    Cross-border activities of institutions for occupational retirement provisions

    Cross-border activities of institutions for occupational retirement provisions, wbl 2006, 106 ff

    Money laundering prevention and distance selling of financial services
    Money laundering prevention and distance selling of financial services

    Money laundering prevention and distance selling of financial services in Fletzberger/Schopper (Hrsg), Praxishandbuch Fernabsatz von Finanzdienstleistungen (2004)

    Practical handbook on distance selling of financial services (2004)
    Practical handbook on distance selling of financial services (2004)

    AML provisions, in Fletzberger/Schopper, Praxishandbuch Fernabsatz Finanzdienstleistungen (2004)

    Show all publications

    Latest news from

    Dr. Bernd Fletzberger

    PFR represents Maksu GmbH in FMA license procedure as a payment institution

    19 May 2026
    We are proud to have successfully advised and represented Maksu GmbH and its entire team, led by Vlado Galevski, in obtaining the…
    read more

    Consumer Rights Amendment Act 2026

    31 March 2026
    On 12 February 2026, the Federal Ministry of Justice published a ministerial draft (80/ME) entitled "Consumer Rights Amendment Ac…
    read more

    Interplay between MiCAR and PSD2: Update on the EBA No-Action Letter

    18 February 2026
    The beginning of March 2026 marks the end of an important transition period for crypto asset service providers (CASPs) that provi…
    read more

    Stablecoins and the Interplay between MiCAR, EMD2, and PSD2 – EBA No-Action Letter

    15 December 2025
    On June 10, 2025, the European Banking Authority (EBA) published a No-Action letter (EBA/Op/2025/08) on the interplay between Reg…
    read more
    Show all news

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