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EMI license: the electronic money institution license by country

An EMI license is the authorization to issue electronic money: balances in wallets, accounts and prepaid cards that clients hold and spend.

  • €350,000 initial capital in the EU and the UK
  • Three months from a complete file
  • Nine regimes, each with its sources

What an EMI license is and who needs one

You need one if your business keeps client funds as stored value beyond a single payment. In the EU and the UK it takes €350,000 of initial capital, safeguarded client funds, approved management and a decision within three months of a complete file.

Electronic money is prepaid value: the client pays funds in, receives a balance, and spends, transfers or withdraws it later. An electronic money institution may hold those funds for as long as the client keeps the balance, which a payment institution may not; it may not lend them or take deposits. It may also provide every payment service a payment institution provides, so one license covers issuing the money and moving it. The license suits wallets, neobank-style accounts, prepaid card programs, payroll and expense platforms, and marketplaces that hold seller balances.

What it takes: 1. A company with its registered office and head office in the licensing state, and part of its business there. 2. €350,000 of initial capital, then own funds of at least 2% of average outstanding e-money (Method D) once that is higher. 3. Safeguarding: client funds in a segregated account at a credit institution, or covered by insurance. 4. Fit-and-proper qualifying shareholders and directors, and local management with payments experience. 5. A program of operations and a three-year business plan, governance and internal control, ICT and security risk management (DORA), a wind-down plan and an AML/CFT program with a compliance officer and MLRO.

What it costs: initial capital runs from S$100,000 in Singapore to HK$25,000,000 paid up for a stored value facility in Hong Kong. In Singapore, S$100,000 covers a standard institution under the e-money thresholds; above them it is S$250,000 plus a security deposit. Between the two sits €350,000, the same in every EU state (EMD2 Article 4) and in the UK (the Electronic Money Regulations 2011). Own funds then grow with the float: at least 2% of average outstanding e-money once that passes the initial capital. Each regulator sets its own application and supervisory fees, named in its row; the FCA charges by category. A small UK issuer, with average outstanding e-money under €5,000,000, registers under lighter requirements.

Time frame: from three months after a complete application in every EU state (PSD2 Article 12, applied by EMD2) to twelve months for an incomplete UK file. Most regulators ask several rounds of questions before they treat a file as complete. Since 3 August 2026, Cyprus starts with a pre-application exploratory stage and an initial meeting, and Lithuania publishes its timeline. (Hint: if you will never hold client balances beyond a single transaction, the payment institution license asks less capital; check that before you size the EMI file.)

Electronic money institution license by country

Nine regimes: seven under the EU's e-money rules, which the UK kept after Brexit (the UK, Lithuania, Ireland, Malta, Cyprus, the Netherlands and Luxembourg), and Singapore and Hong Kong under their own. Open one for the regulator, the capital, how client funds are safeguarded and the local notes.

Filter by region
Electronic money institution license by country
CountryRegulatorMinimum capitalGovernment feesTime frameLast reviewed
Open details forUnited KingdomFCA€350,000FCA application fee by category3 months (complete) or 12 months (incomplete), statutory2026-11-14
Open details forLithuaniaBank of Lithuania€350,000Bank of Lithuania fees3 months from a complete application (statutory)2026-11-11
Open details forIrelandCentral Bank of Ireland€350,000Central Bank fees3 months from a complete application (statutory)2026-11-11
Open details forMaltaMFSA€350,000MFSA application and supervisory fees3 months from a complete application (statutory)2026-11-11
Open details forCyprusCentral Bank of Cyprus€350,000Central Bank fees3 months from a complete application (statutory)2026-11-11
Open details forNetherlandsDNB€350,000DNB application fee3 months from a complete application (statutory)2026-11-11
Open details forLuxembourgCSSF€350,000CSSF application fee3 months from a complete application (statutory)2026-11-11
Open details forSingaporeMASS$250,000 base capitalMAS application and annual feesAsk us2026-11-11
Open details forHong KongHKMAHK$25,000,000 paid-up capitalHKMA feesAsk us2026-11-11

EMI license tiers: passport, home market or Asian hub

The EU rules give one capital figure and one clock; Singapore and Hong Kong run e-money under their own laws.

EU passport

Regulators
Bank of Lithuania, Central Bank of Ireland, MFSA, Central Bank of Cyprus, DNB, CSSF
Initial capital
€350,000
Client funds
Segregated at a credit institution or insured
Time frame
3 months from a complete application (statutory)
Verdict
One license for every EU and EEA state; choose the regulator by its practice and its banking access.

United Kingdom

Regulators
FCA
Initial capital
€350,000; small EMIs register under lighter rules
Client funds
Safeguarded under the FCA's CASS 15 rules since 7 May 2026, with daily reconciliations and annual audits
Time frame
3 months (complete) or 12 months (incomplete), statutory
Verdict
The UK market alone, with a lighter route for small issuers.

Singapore

Regulators
MAS
Initial capital
S$250,000 base capital and a security deposit above the standard thresholds; S$100,000 below them
Client funds
Safeguarded in trust, by guarantee or by insurance
Time frame
Ask us
Verdict
E-money inside a modular license that can also carry transfers, acquiring and crypto.

Hong Kong

Regulators
HKMA
Initial capital
HK$25,000,000 paid up
Client funds
Float protected in a trust or by a bank guarantee
Time frame
Ask us
Verdict
A high capital bar for wallet schemes serving Hong Kong.

Safeguarding and the other checks on an EMI

Safeguarding is the part of the file that sets an e-money issuer apart from other payment firms.

  • Client funds kept apart from the institution's own, in a segregated account at a credit institution or covered by insurance
  • No lending and no deposits: an EMI may not lend client funds or take deposits
  • Not a bank deposit: safeguarded funds are outside any deposit guarantee scheme
  • Own funds that follow the average outstanding e-money (Method D), never below the initial capital
  • A wind-down plan that shows how client funds are returned if the business stops
  • ICT and security risk management under DORA, with incident and business-continuity policies
  • Local management with payments experience, and qualifying shareholders the regulator approves

Who does what in an EMI license application

What we do

  • Size the e-money business: the float, the flows and the own funds they require
  • Write the safeguarding, wind-down and AML policies with you
  • Prepare the program of operations and the three-year plan the regulator reads
  • Answer the regulator's rounds of questions until the file is complete
  • Prepare the safeguarding and operating account applications that follow the license

What you provide

  • The initial capital and evidence of its source
  • Managers with payments experience, based where the regulator expects them
  • The product design: how funds come in, how they are held and how they leave
  • The technology and security documentation for the ICT review

How to get an EMI license: the order of the setup

The product's money flows decide the license, so they are mapped before anything is filed.

  1. 1Map the money flowsHow funds come in, how long they stay and how they leave decide between an EMI and a payment institution license.
  2. 2Form the companyThe license goes to a company with its head office in the licensing state, so the company and its managers come first.
  3. 3Apply for the licenseThe regulator reviews the program of operations, the capital, the people and the safeguarding plan together.
  4. 4Open the safeguarding accountA credit institution holds the client funds, and it reviews the license before it opens the account.
  5. 5Connect payment schemesCard schemes, SEPA and acquirers review the license and the accounts, so they come last. In Lithuania, CENTROlink gives direct SEPA access without a sponsor bank.

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 license are handled in one conversation.

  • Clear next steps

    You see what each step involves before you decide to go ahead.

EMI license questions

Still have a question?

Talk to us
What is an EMI license?

The authorization an electronic money institution needs to issue e-money and provide payment services around it. EU law sets it in the second Electronic Money Directive (EMD2); the UK keeps the same rules in the Electronic Money Regulations 2011.

What is the difference between an EMI and a payment institution?

The holding time. An EMI issues e-money and may hold client funds for as long as the client keeps a balance; a payment institution moves money and keeps it only while a payment is under way. The EMI starts with more initial capital; a payment institution's capital depends on the services it lists.

How much does an EMI license cost?

The initial capital is fixed by law in the EU and the UK, and the own funds you keep rise with the e-money you hold; Singapore and Hong Kong set their own rules. Each regulator adds its own application and supervisory fees. The capital is under What it costs above and in each row; our own fees are set out after the consultation.

How do Lithuania, Malta and Cyprus compare for an EMI license?

The capital and the statutory clock are the same in all three; the regulator is what differs. Lithuania publishes its timeline and gives direct SEPA access through CENTROlink. Malta suits groups it already supervises for gaming or crypto. Cyprus now starts with a pre-application stage that tells you early whether the file will fly.

Can a UK EMI license serve clients in the EU?

No. The UK kept the EU capital rules after Brexit but not the passport; an EU client base needs an EMI authorized in a member state.

Is there a small EMI license?

In the UK, a small EMI can register instead of seeking full authorization, as long as its average outstanding e-money stays under the threshold. Lithuania has a restricted EMI license for business in Lithuania only. Neither reaches other countries.

Are client funds at an EMI protected like a bank deposit?

No. They are safeguarded: kept apart from the EMI's own money at a credit institution, or covered by insurance. They are not covered by a deposit guarantee scheme.

Is an EMI license guaranteed?

No. The regulator decides, usually after several rounds of questions. We prepare the application so the program of operations, the safeguarding plan and the figures agree.

Used in these setups

What comes next

Each service leads to the next: the structure, then the accounts, then the payments and the license.