EMI License
Obtain an Electronic Money Institution License for Your Payment Business
An EMI license is the European authorization that lets a company issue electronic money and provide payment services. EMI stands for electronic money institution. The rules come from the EU’s Second Electronic Money Directive (EMD2), which works alongside the Payment Services Directive (PSD2).
If you are building a wallet, neobank, payment processor, or remittance service for Europe, the EMI license is the usual route to market. It also covers issuing e-money tokens (EMTs) under MiCA for stablecoin projects.
LegalBison manages the full project: jurisdiction choice, company formation, capital, compliance program, application, and banking, all through one point of contact. Book a free consultation. We will tell you whether the EMI route fits your business, or whether another structure serves you better.
Packages to Obtain Your EMI License
Explore our EMI licensing packages tailored for payment providers, wallet operators, and Web3 businesses. Start with a free consultation to scope your project details or select full-service support for complete end-to-end setup and launch.
Business Development Manager, leading the mandate engagement function across crypto, FinTech, gaming, and international corporate structuring verticals.
+372 53 42 2033
Our team of experienced professionals to assist you with any question and project pertaining to FinTech projects.
+44 20 4577 0974
Discover about our EMI Licensing service, jurisdiction scoping, timeline and general pricing
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Fit & Jurisdiction Assessment
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Jurisdiction Advisory
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Upfront Pricing & Timeline Scoping
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Company Formation
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Capital Planning
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Compliance Program Build
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Application & Regulator Dialogue
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Banking Setup & Go-Live
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Post-Licensing Support
Full EMI Licensing service package, company formation, to post-licensing support.
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Fit & Jurisdiction Assessment
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Jurisdiction Advisory
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Upfront Pricing & Timeline Scoping
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Company Formation
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Capital Planning
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Compliance Program Build
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Application & Regulator Dialogue
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Banking Setup & Go-Live
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Post-Licensing Support
EMI License vs Payment Institution vs Bank
| EMI | Payment Institution | Bank | |
|---|---|---|---|
| Issue e-money and run e-wallets | Yes | No | Yes |
| Execute payment transactions | Yes | Yes | Yes |
| Take deposits | No | No | Yes |
| Lend | No (credit never from customer funds) | No | Yes |
| Customer funds protection | Safeguarded (segregated or insured) | Safeguarded | Deposit guarantee scheme |
| Minimum initial capital (EU baseline) | €350,000 | €20,000 - €125,000 by service | At least €5,000,000 |
What an EMI license lets you do
An authorized EMI issues electronic money (stored value backed one-to-one by the funds customers paid in) and runs the payment services attached to it. EMD2 permits:
- issue e-money and operate e-wallets
- issue and manage prepaid cards
- execute payments: domestic and cross-border transfers, direct debits, credit transfers, standing orders
- money remittance
- merchant acquiring (accepting card payments for merchants)
- issue e-money tokens (EMTs) under MiCA. Only EMIs and credit institutions may issue EMTs
An EMI cannot take deposits, cannot pay interest on e-money balances, and cannot lend out customer funds. Customer money is safeguarded, not banked: e-money is not a deposit, so deposit guarantee schemes do not cover it.
More on this topic: Difference between ART vs. EMT in MiCA
A payment institution (PI) executes payments but cannot issue electronic money. A bank can do everything an EMI does, plus take deposits and lend. The EMI license sits in the middle: it stores value without being a bank.
The €350,000 figure is the flat EMD2 baseline for full EMI authorization, set in Article 4 of Directive 2009/110/EC. Payment institution capital is tiered by service under PSD2: €20,000 for money remittance, €50,000 for payment initiation, €125,000 for account-based services. Banking capital starts at €5 million under EU banking rules; most bank launches need far more.
One EMI nuance: EMD2 lets an EMI grant credit related to payment services, for up to 12 months, at market rates, and never from safeguarded customer funds (Article 6(1)(b)).
The authorization file must show the regulator:
- initial capital of at least €350,000 (EMD2 Article 4), paid in and evidenced
- safeguarding of customer funds: segregated accounts or an insurance arrangement, in place no later than five business days after e-money is issued (EMD2 Article 7)
- substance in the licensing country: registered office, local management, and a board
- fit-and-proper directors and shareholders; qualifying holdings are assessed
- an AML/CFT program with a compliance or money-laundering reporting officer
- a program of operations: business plan, governance, capital projections, and risk controls
Regulators also require ongoing own funds: at least 2% of average outstanding e-money, plus method-based capital for payment services (EMD2 Article 5).
The baseline is the same across the EEA. National regulators set application detail, fees, and tempo:
| Jurisdiction | Regulator | Capital baseline | Notes |
| Lithuania | Bank of Lithuania | €350,000 | State levy €1,463; assessment up to 3 months from a complete file. Restricted-activity license: no minimum capital, e-money capped at €900,000 a month, Lithuania only, levy €1,235, 2-month assessment. Details |
| United Kingdom | FCA | €350,000 | Set in the Electronic Money Regulations 2011. Small EMI registration: no €350,000 capital; monthly transaction and outstanding e-money caps; no EEA passport |
| Poland | KNF | €350,000 | EMD2 baseline; national requirements apply |
| Cyprus | CySEC | €350,000 | EMD2 baseline; national requirements apply |
| Malta | MFSA | €350,000 | EMD2 baseline; national requirements apply |
| Estonia | Estonian FSA | €350,000 | EMD2 baseline; national requirements apply |
| Ireland | Central Bank of Ireland | €350,000 | Small EMI tier: €125,000 capital, under €3m monthly transactions, registration only (no passport) |
EMD2 also allows a small-EMI route: registration instead of full authorization where average outstanding e-money stays under €5 million (Article 9). National versions differ: the UK small EMI and Lithuania’s restricted license are examples.
The rules are changing. The EU reached political agreement on its new payment package (PSD3 and the Payment Services Regulation) in November 2025, and the Council published the final texts in April 2026. Formal adoption was still pending in August 2026. The package replaces EMD2 and PSD2 and merges the EMI and payment institution regimes into a single authorization. It is expected to apply during 2028.
Firms licensed under the current regime keep operating through a transitional period of about two years, extendable to 30 months, then re-apply for authorization under the new rules. Member states may convert existing licenses automatically.
A license obtained now remains a sound basis to build on.
Core Cost Preparation Breakdown
- Initial Capital: The largest item is the €350,000 baseline capital held in the company (your company’s capital, not a fee).
- Regulator Fees: Fees vary by country (e.g., Bank of Lithuania state levy is €1,463; see Bank of Lithuania details).
- Professional Fees: Depend on jurisdiction, service scope, and team readiness. LegalBison agrees on all pricing upfront during a free consultation.
Our service coverage to get your EMI ready
Company Formation: Setting up the corporate entity in the chosen jurisdiction and preparing company records.
Compliance Build: Establishing the AML/CFT framework, safeguarding mechanics, governance, and operational programs.
Documentation & Application Prep: Compiling the required authorization file, financial projections, and fit-and-proper assessments.
Submission & Review: Regulators assess complete applications within statutory legal windows (e.g., Lithuania evaluates complete files in up to 3 months).
Dialogue & Final Approval: Managing regulator queries, interviews, and final licensing decisions.
Ready-made EMI companies
LegalBison has existing licensed EMI companies available for transfer in some jurisdictions. This is a change of control, not a shortcut: the regulator must approve the new shareholders and management, and the new owners pass fit-and-proper review. Approval is never guaranteed. The regulator decides. A ready-made entity can shorten the timeline when the fit is right; when it is not, a fresh application costs less than fixing someone else’s compliance history.
EMI Licensing services with us
- Fit and jurisdiction check. We map your business model to the license and the country. If the EMI route is wrong for you, we say so.
- Company formation. We set up the entity in the chosen jurisdiction and prepare the corporate records.
- Capital plan. We structure the €350,000 initial capital and the ongoing own-funds position.
- Compliance program. We build the AML/CFT framework, safeguarding mechanics, governance, and program of operations.
- Application and regulator dialogue. We prepare and submit the file, answer regulator queries, and manage fit-and-proper reviews.
- Banking and go-live. We arrange the banking relationship and the operational setup, then hand over a running institution.
Company formation and licensing sit under one roof at LegalBison. See our services overview for the full scope.
- Jurisdictions and passporting
- What you get with LegalBison
| Route | Regulator | Why founders choose it |
| Lithuania | Bank of Lithuania | Established EMI sector, clear assessment windows |
| United Kingdom | FCA | Mature market; separate regime since Brexit |
| Poland | KNF | Established licensing market, large local economy |
| Cyprus | CySEC | Gateway to the EU from the Middle East |
| Malta | MFSA | Established fintech framework |
| Estonia | Estonian FSA | Digital-first regulator |
Passporting is the reason one license is enough. A license from any EEA member state covers the whole EEA (the 27 EU member states plus Iceland, Liechtenstein, and Norway). The home regulator approves the license; a passport notification lets you operate in other member states without further applications. Authorized payment and e-money institutions, their agents, and branches are listed in the EBA register (a register entry confirms, but does not create, authorization).
The UK is outside this system. A UK EMI cannot passport into the EEA, and an EEA EMI cannot passport into the UK. For EEA-wide business, license in the EEA; for UK-only business, license in the UK.
- one point of contact who runs the whole project
- jurisdiction-neutral advice: the recommendation follows your business model, not our office locations
- project-managed delivery across legal, compliance, formation, and banking
- named licensing specialists: the same people from the first call to go-live
- pricing and timelines agreed before engagement
- ongoing compliance and administration support after the license lands
FAQ about obtaining an EMI License
One conversation gets you the answer: which license, which jurisdiction, what it costs, and who does the work. No obligation, no retainer to start. Contact LegalBison to schedule a free consultation.
An EMI license (electronic money institution license) is the European authorization to issue electronic money and provide payment services. It lets a company hold customer balances in e-wallets and run payments without being a bank. Our EMI explainer and wiki entry cover the details.
A payment institution executes payments but cannot issue electronic money. An EMI issues e-money (stored balances, wallets, cards) and can provide the same payment services. Initial capital differs: €350,000 flat for an EMI, €20,000 to €125,000 for a PI depending on services. If your product stores customer balances, the EMI route is usually the fit.
EMI approval is the regulator’s decision to grant authorization. In the EU it is granted under EMD2; in the UK the FCA grants it under the Electronic Money Regulations 2011. Approval follows a full review of capital, fit-and-proper persons, the AML program, and the business plan. Submitting an application never guarantees approval.
Regulator assessment runs to legal windows: up to 3 months in Lithuania from a complete file. Preparation before submission usually takes several months. Plan on that plus the assessment window for your jurisdiction.
Initial capital is the largest line item: €350,000 baseline, held in the company. Regulator fees vary; the Bank of Lithuania state levy is €1,463. Professional fees depend on jurisdiction and scope. LegalBison confirms them before you commit.
Yes. Wallets, exchange fiat rails, and crypto-friendly payment products commonly run on an EMI license. Under MiCA, issuing an e-money token (EMT) requires authorization as an EMI or a credit institution, plus a notified white paper. Our MiCA license guide maps the full picture.
Start your banking and payment business now
Get in touch with LegalBison experts for a dedicated EMI Licensing service.
Business Development Manager, leading the mandate engagement function across crypto, FinTech, gaming, and international corporate structuring verticals.
Our team of experienced professionals to assist you with any question and project pertaining to FinTech projects.
