Licensing practice · Payments
EMI and Payment Institution Licence in Europe, 2026
One authorisation. Thirty EEA markets. Built so a bank will actually onboard it.
A blunt first meeting.
Before any engagement we tell you the full budget across all five cost layers, the realistic timeline, and whether your model is approvable at all. Some are not. Better to hear it from us than from the regulator a year later.
EMI, PI, SPI or MSB: which licence fits your product
The choice comes down to one question: does your product store client value, or only move it? Everything else (capital, timeline, budget) follows from that answer.
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| Licence | What it allows | Initial capital | Pick it when |
|---|---|---|---|
| EMI (Electronic Money Institution) | Issue e-money: hold client balances, open IBAN accounts, issue cards, run wallets, plus all payment services | €350,000 | Your product stores value. Neobanks, wallets, prepaid card programmes, IBAN-as-a-service |
| PI (Payment Institution) | Payment services without issuing e-money: transfers, acquiring, payment initiation, account information | €20,000 – €125,000 by service set | You move money but never hold stored balances. PSPs, acquirers, remittance, open banking |
| SPI (small PI, national) | Payment services under national volume caps. No EU passport | Reduced or none | You want a lawful launch and a track record before the full application. Upgrade later |
| MSB (Canada, FINTRAC) | Money services registration: FX dealing, transfers, crypto exchange for non-EU markets | No statutory minimum | Your clients sit outside the EU and speed matters. Registration, not a full licence |
Capital must be genuinely paid in from documented sources and maintained throughout the licence's life. Regulators verify source of wealth for every qualifying shareholder.
Apply under today's rules. Build for tomorrow's.
Payment regulation in the EU is mid-rewrite. PSD3 and the Payment Services Regulation will fold e-money institutions into a single payment institution framework and retire the E-Money Directive. That is not a reason to wait. It is a reason to file a clean application now and let it carry over.
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| Framework | Status | What it means for your application |
|---|---|---|
| EMD2 + PSD2 | In force | The current licensing basis. EMI capital €350,000; PI capital €20,000 to €125,000; safeguarding of client funds mandatory |
| PSD3 / PSR | Expected ~late 2027 | EMIs merge into a unified PI framework with a transition period for existing licences. Authorisations obtained now are expected to carry over without re-application |
| DORA | In force since Jan 2025 | ICT risk management, incident reporting, resilience testing and vendor control are now assessed as part of authorisation, with the same weight as AML |
| Instant Payments Regulation | Phasing in | SEPA instant credit transfers become table stakes. Access strategy (direct via CENTROlink or through an agent bank) belongs in the business plan |
Summarised from EU legislative texts and regulator guidance as at July 2026. We verify the current state at engagement and draft applications so the file maps cleanly onto the incoming PSD3 rules.
EMI initial capital under the current framework. It stays on the balance sheet: think of it as locked working capital, not a fee.
Expected PSD3 entry into force, followed by a transition window. A licence obtained in 2026 grandfathers into the new regime.
One EU authorisation passports across 27 EU states plus Iceland, Liechtenstein and Norway. Offshore payment licences cannot match this.
Jurisdictions compared: capital, timelines, character
Passporting makes market access equal. What differs is the regulator: how fast it works, what substance it expects, how it treats higher-risk client sectors, and how banks read its name on your licence.
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| Route | Realistic timeline | First-year budget | Character of the route |
|---|---|---|---|
| Lithuania (Bank of Lithuania) | 3–6 months | €250k – €450k | The EU's largest EMI hub. English-language process, filing possible before incorporation, direct SEPA access via CENTROlink. State fee near €1,500 |
| Cyprus (Central Bank of Cyprus) | 6–12 months | €250k – €500k | Favourable tax, experienced advisers, comparatively pragmatic on higher-risk client sectors such as crypto and iGaming flows |
| Malta (MFSA) | 6–12 months | €300k – €500k+ | Strong financial-services ecosystem, natural pairing with Maltese CASP and gaming structures |
| Ireland (Central Bank of Ireland) | 9–14 months | €350k – €600k+ | Demanding but prestigious. Suits well-capitalised models with institutional ambitions; cooler toward high-risk sectors |
| United Kingdom (FCA) | 12+ months | £300k – £600k+ | Separate from the EU passport since Brexit. Needed for a UK client base; rigorous AML scrutiny |
| Canada MSB (FINTRAC) | 4–10 weeks | USD 15k – 40k | Registration rather than authorisation. A fast, credible wrapper for non-EU money services and crypto flows |
Budgets include paid-in capital where required, professional fees, substance and first-year running costs. Every figure is market orientation; your written route comparison will carry verified numbers for your specific model.
What an EMI licence actually lets you build
Wallets and IBAN accounts
Hold client balances as e-money, issue dedicated IBANs, run multi-currency accounts. The core of every neobank product.
Card programmes
Issue prepaid and debit cards against stored value, directly or through a BIN sponsor while your own scheme membership matures.
Payments and remittance
Credit transfers, direct debits, cross-border remittance and merchant payouts. SEPA and SWIFT rails, instant payments included.
Merchant acquiring
Process card payments for merchants as part of the payment services annex. Pairs naturally with our merchant acquiring practice.
Banking-as-a-service
Offer accounts, cards and payments to other businesses under agent and distributor models, with the compliance burden engineered properly.
Fiat rails for crypto groups
An EMI often runs the fiat side of a CASP-authorised exchange. We structure these dual-licence groups regularly. See the crypto licence page.
What the regulator will read, page by page
A payment licence application is a book, typically several hundred pages. These are its chapters. Weak safeguarding and thin ICT sections stall more applications than anything else, so we draft those first.
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| Chapter | What the regulator checks | Notes from practice |
|---|---|---|
| Business plan and 3-year financials | Viability, realistic volumes, capital adequacy over time | Hockey-stick projections invite questions. Conservative numbers read as competence |
| Programme of operations | Exact services from the PSD2 annex you will provide | Over-scoping raises capital and scrutiny. Licence what you will launch, extend later |
| Safeguarding arrangements | Segregated accounts or insurance for client funds, named counterparties | The single most common sticking point. A safeguarding bank should be courted before filing, not after |
| AML and CFT programme | Risk assessment, CDD, monitoring, reporting, a named MLRO who can defend it live | Regulators interview your MLRO. Template policies collapse in that room |
| ICT and DORA documentation | ICT risk framework, incident response, resilience testing, critical vendor register | Since 2025 this chapter carries near-AML weight. Cloud dependencies need mapped exit plans |
| Governance and key functions | Local management, compliance, risk and audit functions with real presence | Letterbox setups fail. Regulators check where decisions are actually made |
| Fit and proper files | Identity, source of wealth, history of every qualifying shareholder and manager | We run this check on your people before the regulator does. Surprises are the one unforgivable filing error |
We prepare every chapter in-house and coordinate local counsel where national law requires it. You receive one checklist and speak to one person.
Ready-made licensed EMIs and payment institutions
Sometimes the market window is shorter than the application queue. Acquiring a company that already holds the licence is the lawful shortcut, and the regulator stays in the loop: any qualifying holding changes hands only after a fit and proper review of the buyer.
Typical regulator review of a change of control. Compare that with 9 to 14 months for a fresh EMI application in most member states.
Where operating EU EMIs usually trade. Price follows licence scope, SEPA access, safeguarding banks and a clean supervisory history. PIs and SPIs cost meaningfully less.
Availability is shared after buyer identification and a source of funds conversation. The same standard the regulator will apply to you, applied early.
Our due diligence covers the licence scope and any conditions attached, correspondence with the supervisor, the safeguarding position, AML audit history, litigation and tax. A cheap EMI with a supervisory letter in its drawer is not cheap. If the target passes, we manage the change of control filing end to end and hand over an institution you can actually run.
Five stages from idea to authorised institution
Route assessment
Product mapped to EMI, PI, SPI or MSB permissions. Two to four jurisdictions compared in writing, with the apply-or-acquire question answered by numbers.
Structure and capital
Corporate structure, paid-in capital plan, safeguarding model, key functions. Designed to what the regulator and the bank both expect.
Application package
Business plan, financials, AML programme, DORA chapters, fit and proper files. Drafted to be read, not just filed.
Regulator review
Submission, completeness checks, substantive questions. We manage the dialogue; the regulator makes the decision.
Launch
Safeguarding and operating accounts, SEPA access, scheme relationships, ongoing compliance. The licence becomes a business.
Frequently asked questions
What is the difference between an EMI and a PI licence?
An EMI issues e-money. It can hold client balances in wallets, open IBAN accounts and issue cards against stored value. Initial capital is €350,000. A PI provides payment services (transfers, acquiring, payment initiation) without issuing e-money, with capital from €20,000 to €125,000 depending on the services. The test is simple: if your product stores client value, you need an EMI. If it only moves money, a PI is usually enough, cheaper and faster.
How much does an EMI licence cost in 2026?
Think in five layers. Capital of €350,000 must be paid in and kept. State fees are small (about €1,500 in Lithuania). Professional fees for a full application run €30,000 to €100,000 and up across the market. Substance (local management, MLRO, office, systems) and ongoing supervision, audit and reporting complete the picture. A realistic first year for an EU EMI lands between €250,000 and €500,000 or more, counting the capital you retain.
How long does the licence take?
Lithuania is the fastest realistic route at 3 to 6 months for a well-prepared file, and it accepts applications before the company is incorporated. Most EU jurisdictions run 6 to 12 months for an EMI and 6 to 10 for a PI. The UK FCA usually takes 12 months or more. File quality moves the needle more than geography does.
Which EU country is best for an EMI?
Lithuania has processed more EMI and PI applications than any other member state and offers direct SEPA access through CENTROlink. Cyprus wins on tax and is more comfortable with higher-risk client sectors. Malta and Ireland suit models with a commercial anchor there. Since any EU authorisation passports across all 30 EEA states, the choice is about regulator fit, substance and banking rather than market access.
Will PSD3 change things?
Yes. PSD3 and the PSR will merge EMIs into a single payment institution framework and repeal the E-Money Directive. Entry into force is expected around late 2027 with a transition period for existing holders, so a licence obtained in 2026 is expected to carry over without re-application. Waiting for PSD3 gains you nothing; filing a clean application now does.
What is safeguarding?
Client funds must be kept apart from the institution's own money, either in segregated accounts with a credit institution or covered by insurance or a guarantee. It is the core consumer protection of the whole regime, and thin safeguarding chapters stall more applications than anything else. We line up the safeguarding bank early, which is one reason our licensing and account opening practices run as one file.
Can I buy a ready-made EMI instead of applying?
Yes, and for funded buyers it is often the faster path. Acquiring a qualifying holding needs prior regulator approval, a review of the new owners that typically takes 2 to 6 months. Operating EU EMIs usually trade in seven figures; PIs and SPIs for less. Due diligence on licence scope, safeguarding and AML history matters as much as price. Anyone offering a transfer with no regulator involvement is selling you a violation.
What is an SPI?
A small payment institution is a national, volume-capped regime with reduced capital and lighter requirements. No EU passport, monthly volume limits, but a lawful way to launch, prove the model and upgrade later. Budgets run in the tens of thousands rather than hundreds.
Does a payment licence cover crypto?
No. Fiat payments and crypto-asset services sit under different regimes. Crypto exchange, custody and transfers for EU clients require CASP authorisation under MiCA. Many groups hold both, with the EMI running fiat rails for the CASP. Details on the crypto licence page.
What does DORA mean for my application?
DORA has applied since January 2025. Your file must show ICT risk management, incident reporting, resilience testing and control over critical vendors. Regulators read these chapters with the same attention as the AML programme, so we draft them as part of the standard package, not as an appendix.