EMI License Requirements

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?

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?

Local staffing and premises are budgeted separately.

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?

What Changes by Country?

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?