Payment card and terminal overlooking a European financial district at dusk, illustrating electronic money services.

Electronic money institution (EMI) license

Last Update: 30.09.2026

Gofaizen & Sherle provides electronic money institution (EMI) licensing support for businesses building wallets, stored-value products and payment accounts. Products, markets and existing permissions determine scope.

Services are delivered directly in Lithuania. For Malta and Cyprus, Gofaizen & Sherle can arrange support through partners, subject to agreement.

Service Snapshot

Regime

Full authorization or a qualifying national small EMI route.
Authority

The home country’s national competent authority (NCA).
Deliverable

Application support, with passport notification separately scoped.
Initial capital

EUR 350,000 for an authorized EU EMI, excluding project costs.
Safeguarding

Protection of customer funds is required.
Safeguarding

Protection of customer funds is required.
Preparation

Estimated after assessment.
Regulator review

Country-specific, separate from preparation.
Service price

Quoted for the agreed scope.

Is This the Right Fit?

May fit: an e-money issuer, wallet provider or payment account provider holding customer balances.

May not fit: a payment-only business or software supplier that never controls funds.

Needs review: card programs, remittance, acquiring, embedded finance and marketplace payments. Deposit-taking, lending, investments, crypto services and e-money tokens require separate analysis.

Which Regulatory Route Applies?

Business model	Activity	Route	Authority	Limitation
Independent issuer	E-money	Authorized EMI	Home NCA	Approved scope
Limited domestic issuer	E-money	Small EMI	Home NCA	National waiver only
Payment-only provider	Transfers, PIS/AIS	Payment institution / AIS-only registration	Home NCA	No e-money issuance
Principal’s representative	Payments/distribution	Agent/distributor	Principal’s NCA	No independent authorization
Existing EEA issuer	Cross-border business	EMI branch/passport	Home/host NCAs	Notification required
Deposit-taking business	Deposits	Credit institution	Banking supervisor	Separate banking regime

Which Activities Can Be Covered?

Core
Issue electronic money and redeem it at par—the same monetary value.

Payments
Payment accounts, credit transfers, direct debits, card payments, money remittance and acquiring, within approved permissions.

Additional scope
Payment initiation services (PIS), account information services (AIS) and ancillary currency exchange.

Separate assessment
Credit cannot be funded from safeguarded customer money. Investment and crypto activities need their own assessment.

What Will Gofaizen & Sherle Handle?

Activity assessment and jurisdiction selection.
Company setup, governance and shareholder/management files.
Business plan, program of operations and financial projections.
Safeguarding model, AML controls, outsourcing and applicable DORA documentation.
NCA filing, responses to questions and agreed launch or ongoing compliance support.

Clients supply evidence, funding and management decisions. The NCA decides. Banks approve accounts, auditors audit, and vendors implement technology. Local partners deliver their agreed workstreams.

What Does the Service Cost?

Scope	Included	Excluded	Quote	Preparation
Regulatory assessment	Route and gap review	Application dossier	Project-specific	After intake
Application and optional ongoing support	Agreed documents, filing, compliance support	Capital, NCA fee, incorporation disbursements, staffing, premises, banking, audit, technology	Separate setup/recurring quote	After gap review

Local staffing and premises are budgeted separately.

Experts Behind the Work

Laura Puidokiene

Associate, Lawyer

+370 661-083-08 laura@gofaizen-sherle.com

How Does the Application Process Work?

Step 1 Assess. Gofaizen & Sherle reviews client information and confirms the route.

Step 2 Prepare. Client and advisers organize the company, management and application dossier.

Step 3 Submit. Advisers support filing and NCA questions. The regulator decides.

Step 4 Launch. Management completes conditions, provider onboarding and any passport notification before operations.

What Do We Need From You?

Founders, shareholders, ultimate beneficial owners (UBOs) and directors.
Products, target markets, payment methods and customer fund flows.
Existing entities, licenses, funding evidence and projections.
Available AML policies, technology, outsourcing and safeguarding arrangements.

These support initial assessment. The full application dossier follows the selected route.

How Long Does Each Stage Take?

Assessment → preparation → NCA review → launch

Recruitment, incorporation, documentation and banking affect different stages. Preparation receives a project-specific estimate.

In Lithuania, the statutory review is three months after sufficient documents are submitted, including requested additions. This excludes preparation and launch. Malta and Cyprus have separate procedures.

How Do the Electronic Money and Payment Services Directives Apply?

The Electronic Money Directive (EMD2) and Payment Services Directive (PSD2), implemented through national law, govern electronic money institution authorization. The home Member State’s NCA grants permission. The EBA maintains a central register and supervisory guidelines, rather than issuing licenses. Applicants must demonstrate capital, governance, safeguarding and operational readiness. Ongoing own funds (regulatory financial resources) depend on activity and may exceed initial capital. EU/EEA passporting covers permitted activities after the required notification procedure, not unrestricted international operations. The optional small EMI waiver provides no passport.

What Is the Current Regulatory Status?

Item	Status
EMD2/PSD2	Applicable framework with national implementation
PSD3/PSR	Reform: provisional agreement confirmed in April 2026, not a substitute for current application rules
DORA	Applies since January 17, 2025, subject to scope/exemptions
AMLA transition	Direct supervision of selected entities starts in 2028

What Changes by Country?

EU baseline	National overlay	Source	Project effect
Authorization	Application fee	Bank of Lithuania	EUR 1,463 full-license levy
Governance	Management requirements	Malta MFSA rules	Local management and controls
Application	Preliminary procedure	Central Bank of Cyprus	Preliminary exploratory stage since August 3, 2026

Presence, safeguarding, reporting, tax and fees require national assessment.

What Continues After Approval?

Finance
Maintain own funds and safeguarding continuously. File returns/accounts on national schedules under EMD2/PSD2 and NCA rules.

Compliance
Maintain AML/CFT checks, transaction monitoring and complaints handling. Notify changes when required by national rules.

Management/IT
Maintain security, strong customer authentication (SCA) and outsourcing controls continuously. Apply DORA testing/reporting at statutory intervals or triggering events.

What Are the Regulatory Risks?

Unauthorized activity, safeguarding breaches, capital shortfalls, AML failures or missed reporting can trigger national enforcement. Measures can include fines, restrictions, suspension or withdrawal. There is no universal EU turnover-based fine for every breach.

What Banking and Payment Infrastructure Is Needed?

Authorization does not guarantee a safeguarding account, IBAN issuance, SEPA access, card-scheme membership or processor approval. Payment infrastructure support is separately scoped.

Provider assessment covers:

Ownership, funding and AML profile.
Flows, volumes, jurisdictions and counterparties.
Settlement, safeguarding and technical integration.

What Tax Considerations Apply?

Corporate tax, payroll, withholding, permanent establishments and transfer pricing depend on the structure. VAT exemptions concern qualifying services, not every fee earned by an EMI. Local advisers assess each service and place-of-supply rules.

How Do the Alternatives Compare?

Activity	Route	Output	Passporting	Limitation
E-money	Full EMI	Issuance	Notification	Approved scope
Domestic e-money	Small EMI	Limited issuance	No	National limits
Payments	Payment institution (PI)	Payment services	Notification	No issuance
Deposits	Bank	Banking permission	Applicable procedure	Banking requirements
Representation	Agent/distributor	Principal’s services	Through principal	No own passport
Software	Technical provider	Technical support	None	No regulated services
Crypto/EMTs	CASP/EMT issuer route	Activity-specific	Regime-specific	CASP does not replace EMI

Official Sources

Last reviewed 30.09.2026

Frequently Asked Questions

Who needs an EMI license?

Businesses issuing e-money generally need the relevant permission unless an exclusion applies. Gofaizen & Sherle assesses who receives customer funds, who owes the balance and how it can be spent. A product called a wallet does not determine the route by itself.

What counts as e-money?

It is electronically stored monetary value, representing a claim against the issuer, issued for funds and accepted by others for payments. A closed-loop product may require a different analysis. The contractual promise and actual fund flows matter more than the product name.

Can a payment institution hold customer money?

Yes, for providing payment services under its permitted scope, with applicable protection requirements. This does not authorize issuing e-money or taking bank deposits. Gofaizen & Sherle can review whether your planned balances support payment execution or constitute a separate stored-value product.

Can a small EMI expand abroad?

Not using the small EMI waiver as an EU passport. A domestic testing phase and an international launch therefore need different planning. If cross-border expansion is central to your business plan, the assessment should consider full authorization before committing to the restricted route.

Is initial capital the entire budget?

No. Capital is distinct from professional fees, operating expenses and protected customer funds. Ongoing own funds can also exceed the initial minimum as the business grows. Ask for a budget separating regulatory resources, application work, infrastructure and recurring compliance before choosing a jurisdiction.

Is safeguarding the same as deposit insurance?

No. Safeguarding protects relevant customer funds using legally permitted arrangements, such as segregation or qualifying insurance or guarantees. It does not turn wallet balances into insured bank deposits. The model must match national requirements and the actual way your business receives and moves money.

What documents are needed for a quote?

Start with the business model, ownership, markets, payment flows and existing materials listed above. Gofaizen & Sherle uses these to identify missing work and estimate the scope. The later regulator submission is more extensive and includes evidence supporting the company’s ability to operate.

Can you confirm a launch date before filing?

Only a conditional project schedule can be prepared. Regulator questions, recruitment, technology and bank onboarding can change the launch date. Preparation, assessment and operational readiness have different owners. Gofaizen & Sherle will distinguish its agreed work from decisions controlled by regulators and other providers.

Can compliance be outsourced?

Some work can be outsourced where permitted, but management remains responsible. AML oversight, DORA obligations and provider controls must fit the institution’s risk profile. The proposed staffing and outsourcing model should therefore be reviewed before relying on external providers for core operational functions.

Does authorization cover e-money tokens?

Not by itself. MiCA adds requirements for e-money token issuers, including white-paper obligations. Article 48 generally requires an EMI or credit-institution status, subject to specified exceptions. Gofaizen & Sherle can assess issuance and any related crypto services separately before agreeing the application scope.