I have been leading COREDO since 2016, and during that time the team has guided clients through the entire process, from choosing a jurisdiction and forming a legal entity to obtaining financial licenses, setting up AML/compliance and bringing products to markets in Europe and Asia. In this article I have collected the practices and methodology by which COREDO supports projects on the way to an MNB EMI license in Hungary (Magyar Nemzeti Bank), and I also honestly describe the costs, timelines, risks and requirements. My goal is to give entrepreneurs, CFOs and product managers a clear roadmap that saves time and reduces regulatory uncertainty.
Why Hungary for EMI in 2025–2026
Hungary offers a clear regulatory environment, access to the EU market and a mechanism for passporting an EMI license to EU and EEA countries. The MNB (Magyar Nemzeti Bank) is known for attentive but constructive supervision: the regulator provides direct feedback, values mature models and takes a pragmatic approach to outsourcing and cloud infrastructure with appropriate controls. In practice COREDO confirms: a properly prepared dossier and a well‑calibrated business plan speed up the procedure and reduce the number of clarification requests.
PSD2 and the E-money Directive: MNB supervision
EMIs in Hungary are regulated at the EU level by Directive 2009/110/EC (E‑money Directive) and by PSD2 (Payment Services Directive), transposed into national legislation. These frameworks define the range of services, requirements for safeguarding clients’ funds, capital and organisational structure. COREDO’s practice shows that strict adherence to European terminology and methodologies in documents for the MNB reduces communication “noise” and speeds up approvals.
How EMI differs from a payment license
A comparison between an EMI license and a payment license in the EU should be made first. A payment license (PI) allows providing payment services, but not issuing electronic money. EMI, unlike PI, grants the right to issue e‑money and expands product capabilities (wallets, prepaid cards, stored value). Our experience at COREDO has shown that for models with client balances and multi-currency wallets EMI is the natural choice, whereas pure acquiring or PIS/AIS can be more effective in the PI format.
Requirements for an EMI license in Hungary
Fit and proper test for directors and key personnel requires an impeccable business reputation, relevant experience and genuinely engaged management in Hungary. In most cases hiring a local director for an EMI in Hungary is required; the cost depends on the candidate’s profile and starts at senior-level market rates. Internal control, an independent compliance function and an MLRO (officer for AML/CFT) are the core of the operating model, and COREDO’s practice confirms: a clear allocation of roles and regular reporting to the MNB resolves questions at the review stage.
Documents for an EMI license in Hungary
Preparation of the dossier for the MNB EMI license – a project where completeness, logic and interconnections matter. The basic package usually includes:
- Business model plan (business plan) for an EMI license in Hungary, including financial forecasts, stress scenarios, KPIs and unit economics. The document should speak the language of numbers, not slogans.
- Policies and procedures: AML/CFT program and risk assessment (MLRO), KYC/KYB, transaction monitoring and trigger rules, sanctions checks and screening of lists, procedure for confirming source of funds (source of funds).
- Requirements for internal control and the compliance function, conflict of interest management and corporate governance; provisions on independence and escalation.
- Requirements for safeguarding e-money funds in Hungary: models of fund retention (segregated accounts vs trust accounts), custody agreements with partner banks and external confirmation of safeguarding.
- IT security, ISO 27001 and, for card issuing/acquiring, PCI DSS; architecture, BCP/DR (business recovery and continuity plan), incident management, outsourcing of regulatory-significant functions (cloud, processing).
- GDPR and data protection, including the role of the DPO, DPIA and the access model for personal data.
- Registers of beneficial owners (UBO) and EU requirements, ownership structure and confirmation of transparency.
How to obtain an EMI license in Hungary
The practical instructions begin with establishing a legal entity in Hungary for an EMI. The choice of legal form for financial services depends on ownership structure and board requirements, and at this stage we prepare executive candidates and a competency matrix in advance. It is important to align the office, substance and employment contracts of key personnel, otherwise the timeline will “freeze” on formalities.
The timeframes for obtaining an EMI license in Hungary consist of several phases. The preliminary assessment (pre‑application) may take 1–2 months; the full application review takes 6 to 12 months, and in some cases longer. Processing times for EMI license applications in Hungary in 2025 will depend on MNB’s workload and the completeness of the dossier; factors affecting the processing time include the maturity level of IT and AML, evidence of banking relationships and the quality of the business‑plan. If an EMI license is refused: the reasons and remedies usually relate to an unproven model resilience, insufficient outsourcing controls, or incomplete safeguarding policies; COREDO helps structure corrective measures and a reapplication.
Cost of an EMI license in Hungary
Cost of an EMI license in Hungary: it is not a single figure but a comprehensive budget for launching an EMI company. Components of the EMI license cost (legal, IT, compliance) include:
- Legal block: dossier preparation, corporate formation, policies and procedures, interaction with the MNB; this also includes the MNB fee for reviewing an EMI application (Hungary), the amounts of which the MNB periodically updates in its tariffs.
- IT infrastructure and costs for an EMI in Hungary: architecture, licensing, security, integration with payment gateways and the API stack, testing and audit.
- AML/KYC costs for an EMI in Hungary: verification providers, screening platforms, case management and data storage.
- Hiring a local director for an EMI in Hungary, the cost of a compliance officer and MLRO, and the payroll fund for the operations team.
- Audit and external safeguarding confirmation, annual audit costs and regulatory fees, and annual expenses of an EMI in Hungary.
Safeguarding in banking relationships
Correspondent banking relationships for EMIs require starting negotiations early. Interaction with banking partners when opening accounts is best conducted in parallel with licensing: having a letter‑of‑intent (or a draft agreement) strengthens the dossier. The COREDO team implemented a scheme with virtual IBANs and a split of roles between the custodian bank and the processing partner, which increased the model’s resilience and simplified BCP/DR.
IT infrastructure security
IT security, ISO 27001 and PCI DSS for EMIs are not a formality but an operational necessity. Integration of payment gateways and the API‑stack for scaling must account for rate limiting, anti‑fraud, real‑time monitoring and event logging. When performing card issuing, acquiring and interacting with payment schemes, it is important to plan certifications and release schedules already in the business plan.
Operational model of an e-money business
Profitability forecasts and the unit economics of e‑money businesses include fees for wallet issuance/maintenance, interchange income from card issuing, transaction margin and FX markup. Aligning tariffs and fees to ensure profitability must balance competitiveness and regulatory transparency. Financial resilience and stress tests of the business model help justify to the MNB that even in adverse scenarios capital and reserves cover operational needs.
AML/CFT and compliance in operations
Preparing an AML policy and internal controls for an EMI is a process, not a ‘file in a folder’. KYC / KYB procedures and verification of beneficiaries rely on a risk assessment of jurisdictions and products, while PEP screening and rules for handling politically exposed persons establish enhanced checks and the frequency of reassessment. The process of confirming the source of funds (source of funds), transaction monitoring, and trigger rules must be digitized and testable.
GDPR compliance when processing customers’ personal data inevitably overlaps with AML logging and data storage, so access architecture and pseudonymization are important from day one. Reporting to the MNB and regulatory reports, as well as support for MNB audits and inspections, we plan in advance, including templates, registers, and responsible parties. Administrative fines and the risk of license revocation: a reality, but competent AML risk management, operational and IT risk management keep them at bay.
Passporting to European and Asian markets
The conditions for passporting an EMI license to EU and EEA countries from Hungary involve a notification procedure through the MNB and the host regulators. Timelines are usually predictable if the services, distribution channels and local AML specifics are described. A comparison of the timeframes for obtaining an EMI license in Hungary and in other EU jurisdictions shows similar ranges, but Hungary often has the edge in interaction logic and the quality of feedback.
Taxes and corporate structure for IP
Tax aspects of the EMI business model in Hungary depend on the nature of the services, the locations where they are provided and the contractual arrangements with partners. We analyze the VAT position of payment services, transfer pricing and the impact of macroeconomics and currency risks on the payments business. We choose legal forms of companies in Hungary for financial services taking into account corporate governance and protection of minority shareholders.
Legal intellectual property protection of the payment platform is important for assessment by investors and banks. Trademark registration, licensing agreements and vendor code development policies address vulnerabilities. The COREDO solution links the IP strategy with a licensing roadmap to prevent software rights conflicts at the time of inspection.
How to obtain an EMI license in Hungary
- Diagnostics of the model and selection of the service perimeter: we determine whether an EMI license for Hungary is required or a PI is sufficient, and where the boundaries of e‑money issuance lie. This saves months.
- Financial model and ROI‑hypotheses: we build scenarios, unit economics, stress‑tests and regulatory capitalization. This is the basis of MNB’s trust.
- Ownership structure and UBO: we simplify the chain, prepare confirmations, register the UBO. Transparency accelerates Due Diligence.
- Formation of the legal entity in Hungary for an EMI: we register the company, approve the articles of association, substance and office. This is the basis for hiring and contracts.
- Personnel framework: directors, MLRO, compliance, risk‑management; we prepare fit and proper‑packages. People are the key to authorization.
- Safeguarding‑architecture: bank letters of intent, account models, daily reconciliations. This reduces MNB queries.
- IT‑landscape: architecture, security, BCP/DR, ISO 27001/PCI DSS‑plan; integration prototype. The technical specification must be verifiable.
- AML/CFT: risk‑assessment, policies, monitoring scenarios, screening‑providers, reporting. This is assessed separately by the regulator.
- Correspondent relationships and virtual IBANs: preliminary agreements and test configurations. Banks need to see maturity.
- Preparation of the dossier and submission to the MNB: a single narrative, cross‑references, version control. Consistency saves rounds of questions.
- Communication with the regulator: prompt responses, system demonstrations, adjustments. We build the dialogue on facts.
- Test operation and go‑live: pilots with a limited sample, reports to the MNB, expansion of services and geographies. Quality over speed.
COREDO cases: launch scenarios
In one project the COREDO team implemented an EMI for a European fintech with multi-currency wallets and card issuing. We designed safeguarding with two custodian banks, deployed ISO 27001 and prepared for a PCI DSS audit. The timeframe for obtaining an EMI license in Hungary was 9 months thanks to a pre-approved business plan and IT readiness for demonstration.
In the second case the company built an on/off-ramp for digital assets within European regulations and required a combination of VASP registration in one EU country and an EMI in Hungary. We separated product perimeters, described an AML bridge between services and implemented sanctions screening at the level of a unified customer profile. The MNB valued the separate risk accounting and transparency of processes.
Third scenario: a rapid market entry with white-label and partner solutions for a fast EMI launch. At the start we used outsourced transactional processing and a ready virtual IBAN module, while planning our own microservices in parallel. This approach reduced the company’s overall EMI launch budget and provided predictable ROI metrics.
How to reduce the risk of refusal
Factors affecting the processing time of an EMI application are the same: maturity of IT/AML, agreements with banks, and a transparent ownership structure. Our experience at COREDO has shown that a preventive “dry” inspection — rehearsing answers to typical MNB questions — reduces the volume of subsequent requests.
Licensing KPIs and support
Frequently Asked Questions
Timelines and benchmarks for the EU
Comparison of timelines for obtaining an EMI license in Hungary and other EU jurisdictions shows a similar range to countries with comparable supervision: preliminary assessment — from a few weeks, full review — most cases are completed within 9–12 months. Hungary stands out for close feedback from the MNB and the possibility of early technical demonstrations, which helps reduce residual uncertainty. The same principles are critical in any EU country: financial soundness, effective risk management, ownership transparency and technological readiness.
About figures, fees and reporting
How to prove the robustness of the MNB model
The COREDO team is preparing a supporting evidence package: scenario P&L and cash‑flow, sensitivity analysis of transaction margins to tariffs and interchange, a customer acquisition and retention plan tied to LTV/CAC, a reserves policy and regulatory capitalization. Financial stability is confirmed not only by the numbers but also by risk management – credit (for deferred settlements), operational, AML and IT. Such a package demonstrates that the company can manage uncertainty and maintain profitability.
Conclusions
COREDO: a team that speaks the language of regulators and business alike. We support projects from company registration and building compliance to entry into the markets of Europe and Asia, relying on practices and a methodology proven by dozens of licenses. If you need a concrete roadmap — from the dossier to go-live — I am ready to discuss the details and propose a project structure that will deliver results and withstand the test of time and inspections by the MNB.