EMI Licence in Malta

For a full EMI licence — payment services plus electronic money issuance — initial capital of at least EUR 350,000 is required. Lower initial capital thresholds apply for narrower scopes of services: EUR 20,000, EUR 50,000, and EUR 125,000. Where a company combines electronic money issuance with payment services, the MFSA may set a higher requirement. No initial capital is required for account information services alone: such a provider registers with the MFSA. This is an MFSA regulatory requirement, not related to the cost of COREDO’s services.

Incorporation of the Maltese company takes 3–4 weeks, and obtaining the EMI licence takes approximately 8–12 months, subject to the applicant’s full compliance with all MFSA requirements. The regulator’s formal time limit is shorter: by law, the MFSA decides within three months of receiving a complete application or the information it requested. After in-principle approval, the applicant has up to six months to meet the pre-licensing conditions.

At least two persons must effectively direct the business from Malta, and the board of directors has at least three members. An AML Officer (MLRO) and a Compliance Officer are mandatory; legal counsel, an IT specialist, and an accountant may be outsourced. FIAU rules allow the MLRO to be based outside Malta if the business model justifies it and the MLRO remains accessible to the supervisory authorities. At the same time, the MFSA assesses which key functions the company places on the island, so COREDO assists with recruitment of local staff and the office search.

The full COREDO project package costs EUR 91,000 + VAT. Regulatory fees are paid separately, directly to the MFSA, and are non-refundable. The one-time non-refundable fee for processing the application (licence application fee) is EUR 15,000, payable upon submission of the application. The annual supervisory fee is from EUR 35,000. The first supervisory fee is paid on the day the licence is issued — this is the fixed part, calculated pro rata for the remainder of the calendar year. In subsequent years the fee is paid in two instalments.

Yes. An EMI licence issued by the MFSA passports across all EU/EEA member states — through the establishment of branches or on a cross-border basis, without separate licences in each jurisdiction. Before starting operations in another country, the company notifies the MFSA under the procedure of Article 28 of PSD2. Payment initiation and account information services additionally require professional indemnity insurance in the territories where the services are provided.

An EMI must segregate and safeguard all funds received in exchange for the electronic money it has issued. One method is a separate account: it is opened in the company’s own name with a credit institution of an EU/EEA member state or with the Maltese branch of a third-country bank. The safeguarding arrangements are reviewed by an auditor every year. COREDO offers corporate account opening (Safeguard account) as an additional service.

The company pays corporate income tax at the rate of 35%. The 6/7 tax refund is claimed by a shareholder registered for this purpose after receiving dividends. For passive interest and royalties the refund is 5/7, and the 6/7 refund does not apply to profits on which the company has claimed double taxation relief. The alternative is a final tax of 15% with no refund: this regime is chosen for at least five years. The tax structure should be reviewed with a Maltese tax adviser for the specific case.