COREDO > EMI Licence in Estonia

EMI Licence in Estonia

What is an Electronic Money Institution Licence

Estonia is one of Europe’s leading jurisdictions for obtaining an EMI licence thanks to its transparent regulation and advanced digital infrastructure. An Electronic Money Institution (EMI) licence allows companies to issue electronic money, provide payment services, and operate across the EEA through the passporting mechanism.

Since 2016, COREDO has been assisting clients with obtaining EMI licences in Estonia, providing full support — from company incorporation to communication with the regulator and licence approval.

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Cost of the service
from 40 000 EUR

Regulatory Framework: EMD2 and Estonian Legislation

The legal basis for the activities of electronic money institutions in Estonia consists of several levels of regulatory standards.

At the EU level, the key instrument is the Directive 2009/110/EC (EMD2, the second electronic money directive), which establishes minimum requirements for capital, organisational structure, and passporting of EMI institutions throughout the EEA. The Directive 2015/2366/EU (PSD2) regulates payment services that EMIs provide in parallel with electronic money emission.

At the Estonian level, the activities of electronic money institutions are regulated by the Payment Institutions and E-money Institutions Act (MERAS). Supervisory functions are exercised by the Financial Supervision Authority of Estonia — Finantsinspektsioon (EFSA). As of 18 March 2026, applications for payment institution and electronic money institution licences are submitted exclusively through the specialised portal of Finantsinspektsioon.

Requirements in the field of anti-money laundering (AML/CTF) are based on the EU AML Package 2024: Regulation (EU) 2024/1624 (AMLR), applicable from 10 July 2027, as well as Directive (EU) 2024/1640 (AMLD6). All operating EMI companies are required to maintain continuous AML compliance.

Licence Details: What an EMI Licence in Estonia Permits

An EMI licence holder approved by Finantsinspektsioon is entitled to carry out the following types of activities:

Emission and Management of Electronic Money:

Issuance of electronic money (e-money) in any form: digital wallets, prepaid cards, electronic money tokens
Redemption (exchange) of electronic money for cash upon the holder’s request
Storage of electronic money in client accounts

Payment Services (included in the EMI licence):

Transfers of funds, including SEPA transfers and international transactions
Issuance and acquiring of payment instruments (cards and others)
Money remittance services
Initiation and execution of payment orders
Provision of account information services

Additional Operations:

Provision of short-term credit related to payment operations (with a term of up to 12 months, exclusively for the purposes of carrying out transactions and not at the expense of client funds)
Provision of operational and ancillary services (currency exchange, data storage, transaction security)

An EMI licence issued in Estonia is perpetual and valid throughout the EEA thanks to the passporting mechanism.

Requirements for Obtaining an EMI Licence in Estonia

Finantsinspektsioon establishes comprehensive requirements for the organisational, financial, and operational readiness of the applicant company.

Minimum Share Capital

To obtain an EMI licence in Estonia, it is necessary to establish share capital of at least EUR 350,000. Contributions are accepted exclusively in monetary form with confirmation of the lawful origin of funds. This is a regulatory requirement established by EMD2 (Art. 4) and should not be confused with the cost of COREDO’s services for assisting in obtaining the licence.

Management Body Requirements

Management board (board of directors) — at least two members
Each director must possess the necessary education, experience, and professional qualifications to manage an EMI, as well as an impeccable business reputation
At least one director or responsible person must have a real presence in Estonia and be available to the regulator
Shareholders and beneficial owners undergo assessment in terms of business reputation and financial solvency

Physical Presence

Estonian legislation requires a real presence of the company in the jurisdiction: a registered office in Estonia, hiring of employees, or engagement of a local representative. Nominal presence is not accepted by Finantsinspektsioon.

AML/CFT and Internal Compliance

Developed AML/CTF policy with procedures for customer identification (KYC/KYB) and transaction monitoring
Appointment of a person responsible for AML compliance
Internal rules for conducting operations and maintaining accounting records in accordance with MERAS
Mechanisms for regular audit and reporting to the regulator

IT Infrastructure and Security

Description of information technology systems, security systems, and control mechanisms
Business continuity policy and risk management procedures
Description of mechanisms for client fund safeguarding

Cost of COREDO Services

Service	Cost
EMI Licence in Estonia	from EUR 40,000 + VAT

The stated cost covers complete legal assistance in the licensing process: preliminary analysis of the applicant, preparation of the documentation package, interaction with Finantsinspektsioon, consultation at all stages up to and including obtaining the licence.

The final cost depends on the specific circumstances of the project: the complexity of the corporate structure, the need to register a legal entity in Estonia, the scope of required AML policies, and other factors. The final price is determined following an initial consultation.

Payment Terms

COREDO applies a staged payment system linked to project progress:

40%

advance payment upon signing of the service agreement

40%

upon completion of preparation of the complete documentation package and its submission to Finantsinspektsioon

20%

upon receipt of the licence

This structure ensures that the interests of the client and COREDO are fully aligned: the principal portion of compensation is paid upon completion.

Comparison with Other Licence Types in Estonia

In Estonia, financial companies can choose from several types of licences depending on their planned activities:

Licence Type	Regulatory Capital	Timeframe (Regulator)	COREDO Price	Page
EMI (electronic money)	EUR 350,000	3–6 months	from EUR 40,000 + VAT	This page
PI / Securities (Securities Dealer)	from EUR 50,000 to EUR 730,000	3–6 months	from EUR 25,000 + VAT	estonia-pi
Investment Licence	from EUR 50,000	2–4 months	from EUR 60,000 + VAT	estonia
Forex Broker	EUR 730,000	3–6 months	from EUR 25,000 + VAT	estonia

EMI vs PI: A Payment Institution (PI) licence permits the conduct of payment operations but does not grant the right to issue electronic money. If your business model involves storing client funds in electronic form (float), you will need an EMI licence. Capital requirements for EMI are higher (EUR 350,000 compared to EUR 20,000–125,000 for PI), however the functionality is significantly broader.

Passporting in EEA: An EMI licence opens the opportunity for passporting throughout all 30 EEA countries through a notification procedure to the home regulator (Finantsinspektsioon) without obtaining separate licences in each country. This is a key competitive advantage of the Estonian EMI licence.

For more information on financial licences in Estonia: Financial Licences in Estonia.

List of Documents for Obtaining an EMI Licence

To submit an application to Finantsinspektsioon, the applicant shall prepare the following categories of documents:

Incorporation Documents — articles of association, deed of incorporation, certificate of registration of the legal entity in Estonia

Business Plan — description of planned activities, target market, revenue model, development strategy, complying with MERAS requirements

Financial Plan — initial balance sheet, forecast of income and expenses for three years, confirmation of established share capital (EUR 350,000)

Documents on Managers and Owners — full biographies (CV), education documents, employment records or position certificates, list of all current and previous positions; for all management board members — areas of responsibility

List of Shareholders — names, identification codes, share sizes and voting rights; documents on beneficial owners (UBO)

AML/CTF Policy — developed internal rules on anti-money laundering and terrorist financing, KYC/KYB procedures, transaction monitoring, staff training

Description of Organisational Structure — governance scheme, list of key functions and responsible persons, description of use of agents or outsourcing

IT Description — characteristics of information technology systems used, security platforms, cybersecurity measures, backup and data recovery procedures

Rules for Client Fund Safeguarding — description of mechanisms for segregation and protection of client funds

Risk Management Policy — identification of operational, market, legal, and reputational risks and measures to mitigate them

Auditor Information — name, address, identification code of the company’s authorised auditor

Contracts with Critical Service Providers (where applicable) — IT platform, processing centre, correspondent banks

Documents Confirming Physical Presence — office lease agreement, employment contracts with local employees, or agreement with a resident representative

Procedure for Obtaining an EMI Licence in Estonia

The process of obtaining an EMI licence through COREDO proceeds in several sequential stages.

Preliminary Assessment and Strategy (1–2 weeks)

COREDO conducts an analysis of the client’s corporate structure, business model, and readiness for licensing. On the basis of the results, a work plan is formed, the list of documents is agreed upon, and an optimal corporate structure is determined.

01

Registration of Legal Entity in Estonia (2–4 weeks)

If the applicant does not yet have an Estonian company, COREDO registers a legal entity: prepares articles of association, assists with the formation of share capital (EUR 350,000), and opens a corporate account. Estonian legislation allows for the registration to be significantly accelerated through the e-Residency system.

02

Preparation of Documentation Package (6–10 weeks)

The most labour-intensive stage. COREDO prepares the business plan, financial forecasts, AML/CTF policy, IT infrastructure description, internal rules, and all necessary annexes to the application. Documents are brought into compliance with MERAS requirements.

03

Submission of Application to Finantsinspektsioon

As of 18 March 2026, applications are submitted exclusively through the specialised portal of Finantsinspektsioon. COREDO prepares the final package and oversees its submission.

04

Regulator Review of Application (3–6 months)

Finantsinspektsioon conducts a completeness review of the submitted documentation package within 30 days. Once the application is recognised as complete, the regulator makes a decision within three months (but no later than six months from the date of initial submission). During the review process, requests for additional information may be made.

05

Receipt of Licence

Following a positive decision by Finantsinspektsioon, the company is entered into the public register of licensed EMI institutions. The licence is issued indefinitely.

06

Overall Estimated Timeframe: 4–8 months from the beginning of document preparation.

Advantages of Obtaining an EMI Licence in Estonia

Estonia offers a number of significant competitive advantages for fintech companies:

Passporting Throughout the EEA.

A single EMI licence opens access to the market of all 30 EEA countries through a notification procedure — without the need for separate licences and regulatory approvals in each jurisdiction.

Digital Infrastructure.

Estonia holds leading positions in global ratings of digitalisation of government services. 99% of banking operations in the country are conducted online. Most administrative procedures, including company registration and licence application submission, are available in electronic form.

e-Residency Programme.

A programme unique to Europe of electronic residency allows foreign entrepreneurs to manage an Estonian company remotely using digital signature — without the requirement for permanent physical presence in the country.

Zero Tax Rate on Reinvested Profits.

Estonia applies a principle of deferred taxation: as long as profits are not distributed to shareholders, corporate tax is not levied. This significantly reduces the tax burden for growing fintech companies.

Transparent Regulation.

MERAS represents a clear and predictable legal framework. Finantsinspektsioon has a reputation as a constructive and accessible regulator.

Open Fintech Ecosystem.

Estonia actively supports innovation: the country is the birthplace of Skype, Wise (formerly TransferWise) and TransferGo. A developed ecosystem of fintech startups and venture financing operates here.

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Our Experts

The COREDO team has guided projects in financial licensing since 2016 and possesses verified experience of work with Finantsinspektsioon.

Pavel Kos

Head of Legal. Pavel has led COREDO's legal team since July 2020 and has worked at the company since 2016. He specialises in financial licensing in EU jurisdictions, including EMI and PI licences in Estonia, Lithuania, and other EEA countries. He possesses extensive experience in interaction with European regulators, including Finantsinspektsioon.

Basang Ungunov

Lawyer. Basang has worked as a lawyer at COREDO since 2022. He assists clients in obtaining financial licences, preparing AML documentation, and resolving legal issues within regulatory processes in the EU.

Frequently Asked Questions

How does an EMI licence differ from a Payment Institution (PI) licence in Estonia?

An EMI licence provides broader authority: in addition to conducting payment operations, it permits the issuance of electronic money — creating digital wallets, prepaid cards, and other electronic money products. A PI licence is limited to payment services without the right to issue electronic money. If your business model involves holding client funds in electronic form (float), you will specifically need an EMI licence.

What is the minimum share capital for an EMI licence in Estonia?

The minimum share capital for obtaining an EMI licence is EUR 350,000 in accordance with EMD2 (Directive 2009/110/EC, Art. 4). Contributions are accepted exclusively in monetary form, and confirmation of the lawful origin of capital is required. This is a regulatory requirement, not related to the cost of COREDO’s services.

How long does it take to obtain an EMI licence in Estonia?

The overall timeframe is approximately 4–8 months: 2–4 weeks for company registration (if necessary), 6–10 weeks for document preparation, and 3–6 months for review of the application by Finantsinspektsioon. The regulator is required to make a decision no later than six months from the date of submission of the complete package.

Can an Estonian EMI company be managed remotely?

The e-Residency programme allows management of a company remotely using an Estonian digital signature. However, to obtain a licence, real presence in Estonia is required: a registered office, at least one director available to the regulator, and actually functioning management bodies. Nominal presence is not accepted by Finantsinspektsioon.

Does an Estonian EMI licence permit operation in other EU countries?

Yes. An EMI licence issued by Finantsinspektsioon permits the provision of services in all 30 EEA countries through the passporting mechanism (based on EMD2, Art. 3 and PSD2, Art. 28) by notifying the home regulator of the intention to commence operations in the target country. This is one of the primary advantages of an Estonian licence.

What is the cost of COREDO services for obtaining an EMI licence in Estonia?

The cost of COREDO services for assisting in the obtention of an EMI licence in Estonia is from EUR 40,000 + VAT. The final price depends on the complexity of the project, the need for company registration, and the scope of additional services. For an exact calculation, please contact us.

What requirements are imposed on the directors of an EMI company?

The management board must consist of at least two members. Each director must possess appropriate education, experience in the financial sector, and an impeccable business reputation. Finantsinspektsioon conducts an individual assessment of each director (fit & proper assessment).

Is it necessary to open an account at an Estonian bank for an EMI company?

The presence of a corporate account at a bank or licensed payment institution is a practical necessity for the formation of share capital and operational activities of the EMI. COREDO assists clients in opening corporate accounts — both in Estonia and at other European financial institutions.

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Ready to begin the process of obtaining an EMI licence in Estonia? COREDO specialists have been guiding clients since 2016 — from preliminary assessment to final receipt of the licence from Finantsinspektsioon.