EMI Licence: E-Money Institution Authorisation in Europe

An Electronic Money Institution (EMI) licence is an EU authorisation issued under EMD2 and PSD2 by a national competent authority. It permits your company to issue and redeem electronic money, maintain client IBAN payment accounts, provide the full range of PSD2 payment services and passport all those activities across 30 EU and EEA countries (27 EU member states plus Iceland, Liechtenstein and Norway) from a single authorisation. An EMI can hold client balances as stored e-money, which a Payment Institution cannot.

Electronic money is a monetary value stored on an electronic device or account, issued against receipt of funds, and redeemable at par on demand. A payment account holds funds for executing payment transactions. An EMI can provide both: it issues e-money and can maintain payment accounts linked to IBANs. An EMI account linked to a Mastercard or VISA card that can be used anywhere becomes an open payment account subject to full PSD2 safeguarding rules, not just the closed e‑money rules.

The minimum initial own funds requirement for a full EMI licence is EUR 350,000 across all EU member states, as set by EMD2. NCAs assess ongoing capital adequacy against two methods: a fixed overhead requirement (one quarter of prior year fixed costs) and a percentage of average outstanding e-money. In practice, regulators expect capital well above the minimum at the time of application to demonstrate financial soundness. Contact us for a capital planning assessment tailored to your business model.

NCAs conduct a fit-and-proper assessment of all directors, shareholders holding 10% or more of voting rights and key function holders. Your management body must have adequate education, experience and good repute to run a regulated payment institution. A minimum of two executives who effectively direct the business is typically required. You will need a dedicated MLRO (Money Laundering Reporting Officer), an information security officer and a compliance function. Exact requirements vary by jurisdiction.

A complete application includes a programme of operations, a detailed business plan with financial projections, AML/CFT policies and procedures, the governance structure and management body questionnaires, a description of safeguarding arrangements, an IT security and business continuity plan, a structural organisation chart, shareholder and UBO documentation with source of funds, and evidence of initial capital. NCAs review all documents for consistency with the proposed business model. Incomplete submissions pause the review clock. Contact us for a full document checklist.

Under EMD2, NCAs must decide within 3 months of a complete application. In practice the clock pauses each time the regulator issues supplementary information requests, which is common on first submission. The full process from the initial pre-application meeting to receiving the licence typically takes 9 to 12 months. All four jurisdictions we cover encourage a pre-application meeting before formal submission, which reduces the number of queries during the formal review.

All four NCAs we work with strongly encourage a pre-application meeting before formal submission. At this stage your company does not need to be incorporated yet. The regulator reviews your planned business model, identifies regulatory concerns and advises on documents. This meeting significantly reduces queries during the formal review and in many cases shortens the overall timeline. MAXCORP coordinates pre-application meetings with the NCA as part of the Platinum and Custom packages.

Under EMD2, EMIs must protect client funds using one of two methods: segregation into a dedicated account at an EU credit institution, separate from the EMI’s own funds, or coverage by an insurance policy or comparable guarantee. Most regulators prefer the segregated bank account approach. The safeguarding account must be established before the EMI commences operations, and evidence of it is required as part of the authorisation process. MAXCORP assists with bank introductions for safeguarding accounts.

Yes. A licensed EMI can open and maintain IBAN-linked payment accounts for individual and business clients, and access SEPA via the central bank payment systems in its licensing jurisdiction. This includes TARGET2, SCT Inst (SEPA Instant), SDD and SCT. Direct access to the regulator-operated SEPA infrastructure is one of the main practical advantages of licensing in our covered jurisdictions, enabling your clients to send and receive euro payments across the EU.

Yes. All four jurisdictions require your EMI to have its registered and head office in the member state, and your management body must effectively direct operations from there. NCAs conduct substance assessments during the review. You will need at minimum a locally based MLRO and executive management who can meet with the regulator and are available to the supervisory authority on short notice. MAXCORP provides substance solutions, including outsourced MLRO and compliance officer services, across all four jurisdictions.

Yes. Under MiCA (Regulation (EU) 2023/1114), only credit institutions and authorised EMIs may issue e-money tokens (EMTs) in the EU. Holding an EMI licence therefore provides the regulatory status required to issue stablecoins backed by a single fiat currency. However, issuing an EMT requires separate steps, including preparation of a MiCA-compliant crypto-asset white paper and notification to the NCA. MAXCORP can advise on the combined EMI plus EMT structure. Contact us to discuss.

Authorised EMIs submit regular prudential and AML/CFT reports to their NCA, typically quarterly and annually. Reporting covers outstanding e-money, payment transaction volumes, own funds adequacy and AML risk assessments. NCAs may conduct on-site and off-site inspections at any time. Annual supervisory fees are charged based on the institution’s size and activity. Any material changes to the business model, key personnel or ownership structure require prior NCA notification or approval. MAXCORP provides ongoing compliance support and regulatory reporting assistance after authorisation.