I had never heard the term before but Wikipedia says this:
> There were two main types of company that provided services digitally: companies that applied for their own banking license and companies in a relationship with a traditional bank to provide those financial services. The former were called challenger banks and the latter were called neobanks.
That (as well as this article) seems to suggest that neobanks are by definition companies that do not have a banking licence. But I have no idea if that is the correct or current usage. Wikipedia also describes N26 (for example) as a neobank - N26 originally launched without a banking licence but now has one.