Electronic money institution (EMI) license
Obtaining an EMI license in Europe is a crucial step for fintech innovation, providing companies with the opportunity to implement advanced payment solutions and access to the vast EU market. With the support of Gofaizen & Sherle, you will be provided with a full range of e-money license services, from initial consultation to successful authorization.
Get Electronic Money Licenses in European Countries
EMI license is an authorization to issue electronic currency for legal entities and individuals. When registering this type of license, a company receives the rights that classic payment companies use. Such an organization will be able to make offline/online payments and provide sub-accounts within a bank account, which provides the ability to create electronic wallets and provide individual IBANs.
Users can use the exchange of cash for electronic money issued by the company and use financial storage services. In addition, users will be able to pay for services or goods with electronic currency or perform various payment operations.
It is possible to register an EMI license almost all over the world, but the most popular is the EU license. They allow you to cover a large market, using the reliable and stable reputation of the European economy, and also provide access to SEPA translations.
The most popular countries in jurisdictions where this license can be registered are Lithuania, the United Kingdom, Malta, the Czech Republic, Cyprus, etc.
What gives an EMI license
SPI (Small-Scale Payment Institution)
- Payment system management
- Provision and implementation of payment services/money remittance
- Carrying out activities with the provision of loans (using equity capital only)
The maximum turnover for 12 months on sub-accounts of users of the payment system cannot exceed 36 million EUR (based on 3 million EUR per month)
The payment institution has the right to provide services only in the territory of the country of registration. However, it does not prohibit having Clients from any country in the world.
PSP (Payment Service Provider)
- Payment system management
- Provision and implementation of payment services/money remittance
- Carrying out activities with the provision of loans (using equity capital only)
The maximum turnover on sub-accounts of users of the payment system is unlimited
The payment institution has the right to provide services through out the EEA and have the users from any country in the world.
EMI (Electronic Money Institution)
- Emission of electronic money
- Services allowing the use of issued electronic money as a payment instrument
- Exchange of emitted electronic money for fiat currency
- Payment system management
- Provision and implementation of payment services / money remittance
- Carrying out activities with the provision of loans (using equity capital only)
What is Electronic Money Institution
EMI (Electronic Money Institution) is a legal company or a person who has the right to create electronic money, quasi-money, and in addition, can make payments on these assets.
Many people confuse an EMI with a classic bank, but this is a misnomer. The main difference between EMIs and standard banks is that an Electronic Money Institution has no legal right to hold deposits or issue loans. They were originally invented to pay and service businesses and individuals.
The limitation on sub-account transactions, in most cases, depends on the level of customer identification and differs depending on the specifics of the jurisdiction. Statutory provisions that govern this issue are constantly changing around the world, so it is recommended to conduct separate clarification studies for each new project.
Full list of Capabilities
EMI
- Emission of electronic money
- Possibility of using e-money by users as a unit of account for payment for services/goods of third parties
- Exchange of emitted electronic money for fiat currenc
EMI, PSP, SP
- Opening sub-accounts for Clients inside a corporate account of a Payment Service Provider
- Services allowing users placing cash on a current account
- Services allowing users to withdraw cash from a current account
- Execution of payment transactions and money transfers/money remittance (including between payment accounts of users of a payment institution)
- Account information services
- Provision of loans. The loan cannot be provided from funds that have been entrusted to the payment institution for the payment transaction and the equity capital must be equivalent to the total amount of the loan provided. The loan must be repaid by the borrower within one calendar year. Issuance and/or purchase of payment instruments
- Assign existing payment bank cards to Client sub-accounts and issue cards of major vendors (VISA, MC)
The difference between EMI and PI
PI (Payment Institution) license allows companies to provide financial and intermediary services not only for Internet business. For Example opening and closing of accounts, provision of account replenishment services by other payment systems; withdrawal of funds from individual and personal accounts; various payment operations between customer accounts; money transfers; creation of own and involvement of third-party payment instruments, etc.
The main difference between EMI and PI is that EMI has the right to issue electronic currency and store client money for a longer period, while PI does not have the right to issue electronic funds. EMI can produce payment cards, e-wallets, and other payment instruments that provide for the storage of client funds.
The list of services of the electronic payment system corresponds to the services offered by traditional banks. In addition, EMI allows the use of innovative developments and the speed of transactions, which implies a reduction in payment fees and leads to an increase in customer loyalty.
Request more information about EMI licenses
Types of EMI licenses
There are two types of European e-money licenses: Small EMI licenses and EMI licenses. The two license types do not differ functionally or in terms of validity (both are not time-limited and do not require renewal). The main difference between the two relates to minimum initial capital requirements and transaction limits.
Under the Electronic Money Rules 2011 and EMD 2, EMI and Small EMI are defined as follows:
- Small Electronic Money Institution License (Small EMI)
Small EMI, or small electronic money institution license, is one of the two types of licenses governing electronic finance activities. This license is issued to institutions whose electronic money activities are at a small level of transaction volume and capital.
- Minimum initial capital: Institutions holding a Small EMI license are required to maintain an initial capital of at least 2% of the e-money volume they generate. If the financial history of the company does not allow for a standardized calculation of virtual currencies, an assessment should be made based on the business project of the company and taking into account all requirements prescribed by the Financial Regulator and the supervisory authority.
- Transaction Limit: To maintain Small EMI status, the total amount of transactions per month, averaged over the year before application, must not exceed a certain level. For example, the average e-money balance before registration should not exceed €5,000,000 and the total transactions per month should not exceed €3,000,000.
If a Small EMI exceeds the prescribed limits, it must apply for EMI status within a certain timeframe.
The Small EMI provides the prospect for small electronic money institutions to operate in compliance with regulatory requirements, fostering competition and innovation in the financial sector.
Electronic Money Institution License (EMI)
Emi licenses are issued to companies that issue electronic money and provide financial services on a larger scale than small e-money institutions.
- Minimum initial capital: EMI-licensed institutions are required to maintain a certain minimum initial capital by regulatory requirements. For example, the required minimum initial capital requirement may be €350,000 or 2% of EMI capital.
- Unlimited transaction volumes: Unlike Small EMIs, EMI-licensed companies have no limit on the number of transactions and e-money they can process.
EMI represents a key element of the financial infrastructure, providing the ability for large institutions to issue and manage e-money, which promotes the digital economy and financial inclusion.
In many European Union countries, the regulator conducts a thorough check on all company founders who apply for an EMI license.
Requirements may vary from jurisdiction to jurisdiction, but as a general rule, a company must:
- Have at least 2 executives residing in the EU
- Prove relevant education and professional experience of employees in the financial sector
- Contribute a minimum share capital ( usually from €350k)
- All managerial positions must have an impeccable reputation and a clean criminal record
- Open a local office
Rules and regulations are set by different jurisdictions, but there are necessary and generally accepted PSD2 guidelines:
- The company must have the appropriate software
- Implementation of procedures to monitor different risks
- Implementation of AML policies
- Transparent and secure customer identification procedures
- Existence of technology bases and separate client accounts
- Mandatory accounting records
- Ability to obtain SWIFT
- Institution clients receive IBAN accounts
- Ability to open accounts remotely
- Issuance of Visa or MasterCard payment card for clients
- The company can transfer payments with global banks in different currencies
- In-house AML department
- The company can make its own payment decisions and open accounts. In addition, correspondent accounts all over the world.
- Providing services for cash deposit or withdrawal and all operations necessary for payment account operation.
- Access to the Single Euro Payments Area (SEPA), facilitating cross-border transactions in 36 countries.
- Emi license is valid in 30 EEA jurisdictions, allowing you to offer services in different countries without obtaining additional licenses.
- Reliability and transparency through compliance with European regulatory standards.
- The license allows you to support clients with international payment needs.
- Access to a thriving European fintech ecosystem, including technical talent and strategic partnerships.
European jurisdictions for obtaining an e-money license
If you are looking to expand your business through an Electronic money institution license for sale within Europe, choosing a location for your business is a critical step. Each country in the European Union has a unique set of rules and regulations regarding electronic payments, which makes it necessary to thoroughly analyze both the economic potential and the legal environment in potential countries for registration. Your choice should take into account how easily your company will be able to adapt to these conditions, given your business model and resource availability. Despite the diversity of requirements and processes, some countries stand out due to their flexibility and favorable terms, including indefinite licenses, which can significantly increase their attractiveness for your business.
Emi license in Lithuania
Emi license in Lithuania is a key tool for FinTech business development, allowing to legally issue electronic money and provide payment services in the EEA without additional licenses. Licensing opens access to international transfers and payments, facilitating expansion into the EU. Regulation by the Central Bank of Lithuania provides a robust framework for operation, promoting transparency and security of financial transactions.
ExploreBusiness climate
Currently, the Czech Republic and Lithuania are the most attractive jurisdictions in the EU for establishing a company in order to obtain an electronic money institution or payment service provider license, as evidenced by the map above. By 2021, 40 PSP / EMI and 104 small-scale payment institutions are registered in the Czech Republic, while in Lithuania there are 112 full-scale payment systems. The growth in Lithuania has almost doubled since 2018 when the number of full-scale PSP / EMI was 63.
Interest in the Czech Republic and Lithuania jurisdictions caused by the relatively low cost of labor in the EU, a convenient regulatory system and transparent tax system. The speed of processing the application by the regulator is also significant. While in Germany, Malta and other EU jurisdictions, the process can take from 6 to 12 months, in the Czech It should also be noted that in Lithuania an application for a license could be submitted without setting up a company.
Since the requirements are almost the same in all EEA countries for EMI/PSP license acquisition (except small formalities), the steps needed to be undertaken also does not vary significantly.
Sequence of the steps
Company formation in the jurisdiction of choice
Address of registration and virtual box service for one year
Shareholders and Management Board Members/Directors due diligence
Assistance with preparation of application documents
Completing a License Application
Submitting the application to the Financial Authority and following it up until finalized
We are working directly with the following regulators
FSA
Financial Supervisory Authority of Estonia
FIU
Estonian Financial Intelligence Unit
CBN
Czech National Bank
Bank of Lithuania
Lithuanian Central Bank
CBI
Central Bank of Ireland
BaFin
Federal Financial Supervisory Authority (FFSA) of Germany
FCIS
Financial Crime Investigation Service
GFSC
Gibraltar Financial Services Commission
Gofaizen & Sherle will provide professional assistance in jurisdiction choice and with PSP or EMI license acquisition, including preparation required documents for application, company formation, search for personnel, support with Bank account opening, consulting on IT issues and full compliance with applicable regulations. Upon licensing process completion Gofaizen & Sherle will provide corresponding maintenance (accounting and reporting and legal support of current activities).
FinTech lawyers
Trends in the E-money market in Europe
The e-money market in Europe continues to grow and develop, reflecting broader global trends in financial technology and digital payments. Key trends affecting this market include:
Increased regulation
European regulators are actively working to update and strengthen the legal framework governing e-money to improve payment security and user data protection.
Growth in cashless payments
The COVID-19 pandemic has accelerated the shift from cash to cashless payments as consumers and businesses seek safer and more convenient ways to transact. E-money has become an important tool in this transition, providing the foundation for innovative payment solutions.
Innovations in technology
Blockchain and distributed ledger technologies (DLT) are having a significant impact on the e-money market, providing new opportunities for decentralized and secure payment systems.
Expansion of central bank digital currencies
Many European countries are actively researching and developing their central bank digital currencies. These projects could radically change the e-money market, providing new opportunities to integrate traditional financial systems with digital economies.
Increased funding for fintech startups
Financial technology startups continue to attract significant investment, reflecting the strong interest in innovation in the e-money market. This funding supports the development of new products and services, making the market more competitive and dynamic.
Cooperation between traditional banks and fintech companies
Collaborations and partnerships between traditional financial institutions and financial technology startups are becoming increasingly popular
European Regulations on E-Money
In each country of the European Union, the activities of electronic money institutions (EMIs) are strictly supervised by national financial regulators. These authorities are responsible for issuing licenses, supervising EMIs, and checking their activities against national and European legislative standards. European directives ensure regulatory harmonization across the continent, giving EMIs the ability to focus on payment innovation with clarity and confidence in legislative support.
This regulated environment is underpinned by key EU directives aimed at the development and security of financial and payment services.
The General Data Protection Regulation (GDPR) sets a high standard for the protection of personal data, requiring companies in the EU and beyond to implement measures to protect the data of EU citizens. GDPR introduces obligations for organizations to report data security breaches and requires them to obtain consent to process data from users. This regulation has significantly increased the responsibility and burden on organizations, but at the same time has increased trust and security in the digital sphere.
The Electronic Money Directive 2 (EMD2) purposely simplifies market entry for new e-money issuers by reducing minimum capital requirements and simplifying licensing processes. It also increases transparency in e-money transactions and strengthens consumer protection. EMD2 harmonizes rules across all EU member states, which facilitates cross-border transactions and promotes the development of a single digital market.
The Payments Directive 2 (PSD2) opens up the banking sector to third parties by obliging banks to provide access to accounts and payment information upon customer request. This encourages competition and innovation, allowing start-ups and other fintech companies to offer new payment services. The introduction of mandatory strong customer authentication enhances payment security, reducing the risk of fraud and building user trust in electronic payments.
The Sixth Anti-Money Laundering Directive (AMLD6) expands the list of predecessor offenses to money laundering, including terrorism, tax crimes, and cybercrime, and strengthens requirements for financial institutions to identify customers and monitor their transactions. AMLD6 also strengthens cooperation and information sharing among countries and regulators to more effectively combat financial crime.
Together, these laws and regulations provide a strong and flexible framework for the development of a safe, transparent, and innovative financial market in Europe, protecting the interests of consumers and supporting the integration and efficiency of the European market.
FAQ about EMI license
What is an EMI license?
An E-money license is a permit issued by the regulator that allows companies to issue electronic money and provide payment services in the EU. It ensures that e-money transactions are executed and circulated, building trust and security in financial transactions.
How can I get an EMI license?
To obtain an electronic money institution license, decide on a jurisdiction, register a company, open an account, and deposit an authorized capital of 350,000 euros. In addition, you will need to hire staff, rent an office, apply with documentation that includes a business plan, and an AML policy, and fulfill other regulatory requirements.
What is the difference between an EMI and a bank license?
Emi licenses allow the issuance of electronic money and payment services, requiring less equity capital than a bank license, which gives the right to accept deposits, lending, and other banking transactions, and is subject to strict regulation and control.
How much does an EMI license cost?
The EMI license cost includes a minimum initial capital requirement, which is usually €350,000. In addition, government fees will be required, which vary from country to country.
What does an EMI license allow?
An EMI license allows you to issue electronic money, exchange it for fiat, open sub-accounts, and provide payment services, including transfers and account transactions. In addition, it allows to issuing of loans with certain restrictions and payment cards (VISA, MasterCard).
How long does it take to obtain a European EMI license?
Obtaining an e-money license can take from 3 to 12 months depending on the correct application and the regulatory workload of the authorized body. However, the process can be delayed due to the need for additional documents or changes in the regulatory environment. Help to significantly reduce the licensing time.
Can citizens of non-EU countries apply for a European EMI license?
Yes, citizens of non-EU countries can apply for a European EMI license if they meet the requirements set by the relevant regulators. Some countries, such as Lithuania, provide such opportunities for non-EU citizens. However, requirements and procedures may vary from country to country and from regulator to regulator.
Which country is best for an EMI license?
Lithuania is an attractive choice for obtaining an EMI license in Lithuania. The process is quick and relatively simple. Companies can provide a wide range of services including IBAN issuance, payment cards, SWIFT transfers, and correspondent accounts. The tax system is relatively favorable, the license is unlimited in duration, and there is scope for expansion to other EU countries.
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