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EMI licence
Applying for a licence to issue electronic money and provide payment services, in the EU, the UK or Asia.
- €350,000 of capital across the EU and the UK
- Singapore and Hong Kong compared
- Safeguarding and policies prepared with you
What the licence allows and who needs it
An electronic money institution (EMI) licence authorises a company to issue electronic money (balances in wallets, accounts and prepaid cards) and to provide payment services around it. It suits businesses that hold client funds for more than a transaction takes: wallets, neobanks, payroll and expense platforms, marketplaces that hold seller balances.
In the EU and the UK the second Electronic Money Directive sets the same capital (€350,000) and the same three-month decision in every state; the choice between them is about the regulator, the local practice and the passport. Singapore and Hong Kong run their own regimes.
Countries
Each country opens with the regulator, the licence, the capital, the fees the regulator publishes, the requirements, the documents, the steps and the sources we checked, with the date we checked them.
| Country | Regulator | Minimum capital | Government fees | Timeline | Last reviewed | |
|---|---|---|---|---|---|---|
| United Kingdom | FCA | €350,000 | FCA application fee by category | 3 months (complete) or 12 months (incomplete), statutory | 2026-11-11 | |
| Lithuania | Bank of Lithuania | €350,000 | Bank of Lithuania fees | 3 months from a complete application (statutory) | 2026-11-11 | |
| Ireland | Central Bank of Ireland | €350,000 | Central Bank fees | 3 months from a complete application (statutory) | 2026-11-11 | |
| Malta | MFSA | €350,000 | MFSA application and supervisory fees | 3 months from a complete application (statutory) | 2026-11-11 | |
| Cyprus | Central Bank of Cyprus | €350,000 | Central Bank fees | 3 months from a complete application (statutory) | 2026-11-11 | |
| Netherlands | DNB | €350,000 | DNB application fee | 3 months from a complete application (statutory) | 2026-11-11 | |
| Luxembourg | CSSF | €350,000 | CSSF application fee | 3 months from a complete application (statutory) | 2026-11-11 | |
| Singapore | MAS | S$250,000 base capital | MAS application and annual fees | Ask us | 2026-11-11 | |
| Hong Kong | HKMA | HK$25,000,000 paid-up capital | HKMA fees | Ask us | 2026-11-11 |
United Kingdom
A very large fintech licensing market under the FCA: the EU capital rules without the passport, with lighter small-firm registrations.
- Regulator
- Financial Conduct Authority (FCA)
- Licence
- Electronic money institution (EMI)
- Initial capital
- €350,000 (EMD2 Article 4)
- Own funds
- At least 2% of average outstanding e-money (Method D)
- Statutory review
- 3 months (complete) or 12 months (incomplete), statutory
- Passport
- United Kingdom only
What the licence allows
An electronic money institution issues e-money (prepaid value held in wallets, accounts and cards) and provides every payment service a payment institution may provide. It may hold client funds indefinitely, which a payment institution may not; it may not take deposits or lend from client funds.
Capital and safeguarding
EMD2 sets initial capital of €350,000 and ongoing own funds of at least 2% of average outstanding electronic money (Method D), or the initial capital if higher. Client funds are safeguarded in a segregated account at a credit institution or covered by insurance; they are not covered by a deposit guarantee scheme.
Requirements
- A company with its registered office and head office in the member state, and part of its business there
- Fit-and-proper qualifying shareholders and directors; local management with payments experience
- Safeguarding arrangements, a wind-down plan and professional indemnity insurance where required
- Governance, internal control, ICT and security risk management (DORA), outsourcing policy
- AML/CFT programme with a compliance officer and MLRO
Documents
- Programme of operations and a three-year business plan with projections
- Structural organisation, governance and internal control descriptions
- Safeguarding, security, incident, business-continuity and AML policies
- Identity and good-repute evidence for shareholders, directors and managers; proof of initial capital
Steps and timeline
The competent authority decides within three months of receiving a complete application (PSD2 Article 12, applied to EMIs by EMD2). In practice the file takes months to prepare and most regulators ask several rounds of questions before they treat it as complete.
Local notes
- The UK kept the EU rules after Brexit as the Electronic Money Regulations 2011 and the Payment Services Regulations 2017, without the EU passport
- A small EMI (average outstanding e-money under €5,000,000) and a small payment institution (under €3,000,000 a month) register under lighter requirements
- Safeguarding is moving to a CASS-style regime with audits under the FCA's 2025 policy
Last reviewed: 2026-11-11
Lithuania
A major EU EMI hub: a regulator that publishes its timelines, and direct SEPA access through the central bank.
- Regulator
- Bank of Lithuania
- Licence
- Electronic money institution (EMI)
- Initial capital
- €350,000 (EMD2 Article 4)
- Own funds
- At least 2% of average outstanding e-money (Method D)
- Statutory review
- 3 months from a complete application
- Passport
- EU and EEA
What the licence allows
An electronic money institution issues e-money (prepaid value held in wallets, accounts and cards) and provides every payment service a payment institution may provide. It may hold client funds indefinitely, which a payment institution may not; it may not take deposits or lend from client funds.
Capital and safeguarding
EMD2 sets initial capital of €350,000 and ongoing own funds of at least 2% of average outstanding electronic money (Method D), or the initial capital if higher. Client funds are safeguarded in a segregated account at a credit institution or covered by insurance; they are not covered by a deposit guarantee scheme.
Requirements
- A company with its registered office and head office in the member state, and part of its business there
- Fit-and-proper qualifying shareholders and directors; local management with payments experience
- Safeguarding arrangements, a wind-down plan and professional indemnity insurance where required
- Governance, internal control, ICT and security risk management (DORA), outsourcing policy
- AML/CFT programme with a compliance officer and MLRO
Documents
- Programme of operations and a three-year business plan with projections
- Structural organisation, governance and internal control descriptions
- Safeguarding, security, incident, business-continuity and AML policies
- Identity and good-repute evidence for shareholders, directors and managers; proof of initial capital
Steps and timeline
The competent authority decides within three months of receiving a complete application (PSD2 Article 12, applied to EMIs by EMD2). In practice the file takes months to prepare and most regulators ask several rounds of questions before they treat it as complete.
Local notes
- Direct access to SEPA through the Bank of Lithuania's CENTROlink, without a sponsor bank
- A restricted EMI licence exists for Lithuania-only business under lower thresholds
- The Bank of Lithuania publishes its three-month statutory timeframe and a Newcomer Programme for applicants
Last reviewed: 2026-11-11
Ireland
An EU passport from an English-speaking common-law jurisdiction, with a thorough and well-documented authorisation process.
- Regulator
- Central Bank of Ireland
- Licence
- Electronic money institution (EMI)
- Initial capital
- €350,000 (EMD2 Article 4)
- Own funds
- At least 2% of average outstanding e-money (Method D)
- Statutory review
- 3 months from a complete application
- Passport
- EU and EEA
What the licence allows
An electronic money institution issues e-money (prepaid value held in wallets, accounts and cards) and provides every payment service a payment institution may provide. It may hold client funds indefinitely, which a payment institution may not; it may not take deposits or lend from client funds.
Capital and safeguarding
EMD2 sets initial capital of €350,000 and ongoing own funds of at least 2% of average outstanding electronic money (Method D), or the initial capital if higher. Client funds are safeguarded in a segregated account at a credit institution or covered by insurance; they are not covered by a deposit guarantee scheme.
Requirements
- A company with its registered office and head office in the member state, and part of its business there
- Fit-and-proper qualifying shareholders and directors; local management with payments experience
- Safeguarding arrangements, a wind-down plan and professional indemnity insurance where required
- Governance, internal control, ICT and security risk management (DORA), outsourcing policy
- AML/CFT programme with a compliance officer and MLRO
Documents
- Programme of operations and a three-year business plan with projections
- Structural organisation, governance and internal control descriptions
- Safeguarding, security, incident, business-continuity and AML policies
- Identity and good-repute evidence for shareholders, directors and managers; proof of initial capital
Steps and timeline
The competent authority decides within three months of receiving a complete application (PSD2 Article 12, applied to EMIs by EMD2). In practice the file takes months to prepare and most regulators ask several rounds of questions before they treat it as complete.
Local notes
- An English-speaking EU passport favoured by groups serving the UK and the EU together
- The Central Bank publishes application forms and a pre-application engagement process
Last reviewed: 2026-11-11
Malta
An EU passport from a regulator used to payments, gaming and crypto groups under one roof.
- Regulator
- Malta Financial Services Authority (MFSA)
- Licence
- Electronic money institution (EMI)
- Initial capital
- €350,000 (EMD2 Article 4)
- Own funds
- At least 2% of average outstanding e-money (Method D)
- Statutory review
- 3 months from a complete application
- Passport
- EU and EEA
What the licence allows
An electronic money institution issues e-money (prepaid value held in wallets, accounts and cards) and provides every payment service a payment institution may provide. It may hold client funds indefinitely, which a payment institution may not; it may not take deposits or lend from client funds.
Capital and safeguarding
EMD2 sets initial capital of €350,000 and ongoing own funds of at least 2% of average outstanding electronic money (Method D), or the initial capital if higher. Client funds are safeguarded in a segregated account at a credit institution or covered by insurance; they are not covered by a deposit guarantee scheme.
Requirements
- A company with its registered office and head office in the member state, and part of its business there
- Fit-and-proper qualifying shareholders and directors; local management with payments experience
- Safeguarding arrangements, a wind-down plan and professional indemnity insurance where required
- Governance, internal control, ICT and security risk management (DORA), outsourcing policy
- AML/CFT programme with a compliance officer and MLRO
Documents
- Programme of operations and a three-year business plan with projections
- Structural organisation, governance and internal control descriptions
- Safeguarding, security, incident, business-continuity and AML policies
- Identity and good-repute evidence for shareholders, directors and managers; proof of initial capital
Steps and timeline
The competent authority decides within three months of receiving a complete application (PSD2 Article 12, applied to EMIs by EMD2). In practice the file takes months to prepare and most regulators ask several rounds of questions before they treat it as complete.
Local notes
- Licensed under the Financial Institutions Act with the EU capital rules
- Often paired with gaming and crypto groups already supervised in Malta
Last reviewed: 2026-11-11
Cyprus
An EU passport beside Cyprus's investment firms, with a new pre-application stage that tells you early whether the file will fly.
- Regulator
- Central Bank of Cyprus
- Licence
- Electronic money institution (EMI)
- Initial capital
- €350,000 (EMD2 Article 4)
- Own funds
- At least 2% of average outstanding e-money (Method D)
- Statutory review
- 3 months from a complete application
- Passport
- EU and EEA
What the licence allows
An electronic money institution issues e-money (prepaid value held in wallets, accounts and cards) and provides every payment service a payment institution may provide. It may hold client funds indefinitely, which a payment institution may not; it may not take deposits or lend from client funds.
Capital and safeguarding
EMD2 sets initial capital of €350,000 and ongoing own funds of at least 2% of average outstanding electronic money (Method D), or the initial capital if higher. Client funds are safeguarded in a segregated account at a credit institution or covered by insurance; they are not covered by a deposit guarantee scheme.
Requirements
- A company with its registered office and head office in the member state, and part of its business there
- Fit-and-proper qualifying shareholders and directors; local management with payments experience
- Safeguarding arrangements, a wind-down plan and professional indemnity insurance where required
- Governance, internal control, ICT and security risk management (DORA), outsourcing policy
- AML/CFT programme with a compliance officer and MLRO
Documents
- Programme of operations and a three-year business plan with projections
- Structural organisation, governance and internal control descriptions
- Safeguarding, security, incident, business-continuity and AML policies
- Identity and good-repute evidence for shareholders, directors and managers; proof of initial capital
Steps and timeline
The competent authority decides within three months of receiving a complete application (PSD2 Article 12, applied to EMIs by EMD2). In practice the file takes months to prepare and most regulators ask several rounds of questions before they treat it as complete.
Local notes
- Licensed under the Electronic Money Law and the Payment Services Law with the EU capital rules
- A revised licensing process from 3 August 2026 starts with a pre-application exploratory stage and an initial meeting
Last reviewed: 2026-11-11
Netherlands
A northern-European passport with high supervisory standing, for payment groups that want the Dutch banking ecosystem.
- Regulator
- De Nederlandsche Bank (DNB)
- Licence
- Electronic money institution (EMI)
- Initial capital
- €350,000 (EMD2 Article 4)
- Own funds
- At least 2% of average outstanding e-money (Method D)
- Statutory review
- 3 months from a complete application
- Passport
- EU and EEA
What the licence allows
An electronic money institution issues e-money (prepaid value held in wallets, accounts and cards) and provides every payment service a payment institution may provide. It may hold client funds indefinitely, which a payment institution may not; it may not take deposits or lend from client funds.
Capital and safeguarding
EMD2 sets initial capital of €350,000 and ongoing own funds of at least 2% of average outstanding electronic money (Method D), or the initial capital if higher. Client funds are safeguarded in a segregated account at a credit institution or covered by insurance; they are not covered by a deposit guarantee scheme.
Requirements
- A company with its registered office and head office in the member state, and part of its business there
- Fit-and-proper qualifying shareholders and directors; local management with payments experience
- Safeguarding arrangements, a wind-down plan and professional indemnity insurance where required
- Governance, internal control, ICT and security risk management (DORA), outsourcing policy
- AML/CFT programme with a compliance officer and MLRO
Documents
- Programme of operations and a three-year business plan with projections
- Structural organisation, governance and internal control descriptions
- Safeguarding, security, incident, business-continuity and AML policies
- Identity and good-repute evidence for shareholders, directors and managers; proof of initial capital
Steps and timeline
The competent authority decides within three months of receiving a complete application (PSD2 Article 12, applied to EMIs by EMD2). In practice the file takes months to prepare and most regulators ask several rounds of questions before they treat it as complete.
Local notes
- A demanding regulator with a strong name among banks and card schemes
- Applications go through DNB's digital portal with the standard EU forms
Last reviewed: 2026-11-11
Luxembourg
The passport of choice for large payment groups, with a regulator that expects real substance in the Grand Duchy.
- Regulator
- Commission de Surveillance du Secteur Financier (CSSF)
- Licence
- Electronic money institution (EMI)
- Initial capital
- €350,000 (EMD2 Article 4)
- Own funds
- At least 2% of average outstanding e-money (Method D)
- Statutory review
- 3 months from a complete application
- Passport
- EU and EEA
What the licence allows
An electronic money institution issues e-money (prepaid value held in wallets, accounts and cards) and provides every payment service a payment institution may provide. It may hold client funds indefinitely, which a payment institution may not; it may not take deposits or lend from client funds.
Capital and safeguarding
EMD2 sets initial capital of €350,000 and ongoing own funds of at least 2% of average outstanding electronic money (Method D), or the initial capital if higher. Client funds are safeguarded in a segregated account at a credit institution or covered by insurance; they are not covered by a deposit guarantee scheme.
Requirements
- A company with its registered office and head office in the member state, and part of its business there
- Fit-and-proper qualifying shareholders and directors; local management with payments experience
- Safeguarding arrangements, a wind-down plan and professional indemnity insurance where required
- Governance, internal control, ICT and security risk management (DORA), outsourcing policy
- AML/CFT programme with a compliance officer and MLRO
Documents
- Programme of operations and a three-year business plan with projections
- Structural organisation, governance and internal control descriptions
- Safeguarding, security, incident, business-continuity and AML policies
- Identity and good-repute evidence for shareholders, directors and managers; proof of initial capital
Steps and timeline
The competent authority decides within three months of receiving a complete application (PSD2 Article 12, applied to EMIs by EMD2). In practice the file takes months to prepare and most regulators ask several rounds of questions before they treat it as complete.
Local notes
- The home of PayPal's and Amazon's European payment licences
- The CSSF expects substance in Luxembourg and a detailed outsourcing framework
Last reviewed: 2026-11-11
Singapore
E-money in Singapore, under a single payment-services licence that can carry wallets, transfers, acquiring and crypto.
- Regulator
- Monetary Authority of Singapore (MAS)
- Licence
- Major Payment Institution licence for e-money issuance (Payment Services Act 2019)
- Base capital
- S$250,000, plus a security deposit
- Safeguarding
- Customer money safeguarded in trust, by guarantee or insurance
- Management
- At least one executive director resident in Singapore
What the licence allows
E-money issuance above the standard-institution thresholds needs a Major Payment Institution licence. The same licence can carry account issuance, domestic and cross-border transfers, merchant acquisition and digital payment token services.
Requirements
- A Singapore company with a permanent place of business and a resident executive director
- Fit-and-proper controllers and directors
- Safeguarding of customer money, technology risk management and AML/CFT notices
- Base capital maintained at all times, with a security deposit for a major institution
Last reviewed: 2026-11-11
Hong Kong
Hong Kong's wallet licence: a high capital bar and a protected float, for e-money schemes serving Hong Kong and the region.
- Regulator
- Hong Kong Monetary Authority (HKMA)
- Licence
- Stored Value Facility (SVF) licence, Payment Systems and Stored Value Facilities Ordinance
- Paid-up capital
- HK$25,000,000
- Float
- The stored value float is protected in a trust or by a bank guarantee
What the licence allows
Prepaid wallets and cards that store value for payments need an SVF licence from the HKMA, unless the scheme is a bank or falls under a small exemption. Licensees may also offer payment and remittance features around the stored value.
Requirements
- A Hong Kong company with a principal place of business in Hong Kong
- Fit-and-proper controllers, directors and chief executive
- Float protection, prudent management of the float, and risk management for technology and AML
Last reviewed: 2026-11-11
What regulators look at
The detail differs by country. Applications are usually assessed on:
- Capital: the minimum the licence requires, held in a form the regulator accepts, and where it comes from
- People: fit-and-proper owners, directors and the compliance, risk and anti-money-laundering officers
- Substance: a physical office, local directors or staff where the country requires them
- Policies: the business plan, the compliance manual, risk management and the protection of client money
- Systems: the trading or payment platform, its security, its records and its outsourcing
What we do and what you provide
What we do
- Compare the countries that license your activity against your plan, clients and capital
- Prepare the application file and the policies with you
- Coordinate with the regulator during the review and answer its questions
- Set out the obligations once licensed, and keep the calendar
What you provide
- A business plan for the e-money business
- Background documents for owners, directors and key staff
- Evidence of the capital and its source
- Decisions on structure, staff and office
Steps and timeline
- 1ConsultationWe talk through what you need, where you operate and what you already have in place.
- 2PlanYou receive a plan that sets out the steps, the documents and the parties involved, so you can decide how to proceed.
- 3Set-upWe prepare the applications and documents with you and coordinate with the providers involved.
- 4Ongoing supportAfter set-up, we stay available for renewals, changes and questions.
Your choice, our commitment
Your business model
The structure follows how your business works and where it operates.
Your resources
We start from the documents and people you already have, and say clearly what is still needed.
Support
Questions about the company, the accounts and the licence are handled in one conversation.
Clear next steps
You see what each step involves before you decide to go ahead.
Frequently asked questions
Still have a question?
Talk to usHow long does it take?
It depends on the jurisdiction, the provider and the documents involved. We give you an estimate for the licence after the consultation.
What does it cost?
Costs depend on the jurisdiction and on the services you choose. We set them out for the licence after the consultation, before any work starts.
Do I need to travel?
Some steps can be completed remotely and others need you in person. We tell you which applies to your case before you start.
Is the licence guaranteed?
No. The regulator decides. We prepare the application so it is complete and consistent with the regulator's requirements.
Where do the facts on this page come from?
From the regulators' and registries' own publications, linked in each country's dialog with the date we last checked them. Rules change; we confirm the current position in the consultation before anything starts.
Used in these set-ups
What comes next
Each service leads to the next: the structure, then the accounts, then the payments and the licence.
Plan your licence application
Talk to us- IncorporationForming a company or foundation, and keeping it in good standing.Talk to us
- BankingBusiness and personal accounts, and accepting payments.Talk to us
- LicensingFinancial licences for regulated activities.Talk to us
- InvestmentsOpening investment accounts for a company or for yourself.Talk to us