EMI Licence in Cyprus

What Is an EMI Licence in Cyprus

An EMI licence in Cyprus entitles a company to issue electronic money and provide payment services. It is granted by the Central Bank of Cyprus and lets you do business across the entire EU and EEA market.

COREDO has supported financial licensing projects since 2016. In Cyprus we take the whole journey with you: we incorporate the company, prepare the business plan and AML policies, file the application with the Central Bank of Cyprus and lead the dialogue with the regulator until the licence is granted.

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Cost of the service
EUR 108,000

Regulatory Framework: CBC, EMD2 and PSD2

Electronic Money Institution (EMI) licences in Cyprus are granted by the Central Bank of Cyprus (CBC). The CBC reviews the application, assesses the fitness of the directors and management, and then supervises the licensed company.

EMI activity in Cyprus is governed by the Electronic Money Laws of 2012 and 2018. They transpose Directive 2009/110/EC (EMD2) on electronic money and Directive (EU) 2015/2366 (PSD2) on payment services into Cypriot law. For you, this means something simple: a Cypriot licence is built on the same European rules as licences in other EU countries and is recognised across the entire single market.

The content of the application is set by the Provision and Use of Payment Services and Access to Payment Systems Laws of 2018–2025. The CBC has also issued its own Electronic Money Institutions Directive of 2025. Since 3 August 2026 the CBC has been working under an updated licensing procedure, and COREDO builds every project around it from day one.

Licence Details: What an EMI Licence in Cyprus Permits

With an EMI licence from the CBC, your company gains three sets of capabilities for its fintech product.

Electronic money

  • Issuance of electronic money — the foundation for digital wallets and prepaid products
  • Operational and closely related ancillary services around e-money issuance

Payment services — the full PSD2 list

  • Cash placement on and cash withdrawal from a payment account, plus all operations required for operating a payment account
  • Payment transactions: direct debits, payment card transactions and credit transfers, including those covered by a credit line for the client
  • Issuing of payment instruments and acquiring of payment transactions
  • Money remittance
  • Payment initiation
  • Account information

Business growth

  • Granting credit related to payment services, on the terms set by EMD2 and PSD2
  • Operating payment systems
  • Business activities other than e-money issuance — within EU and Cypriot law
  • Operating in all EU and EEA countries through branches or on a cross-border basis

Important restriction: an EMI does not accept deposits or other repayable funds from the public — that is the domain of banks. Funds received in exchange for electronic money are kept protected by the institution (safeguarding).

Requirements for Obtaining an EMI Licence in Cyprus

The CBC assesses the applicant’s capital, team, presence on the island and internal control framework. Below is what you will need — and where COREDO helps.

Minimum Capital

A full EMI licence, covering all payment services and e-money issuance, requires initial capital of at least EUR 350,000 at the time the licence is granted, and documents in the application confirm that it has been paid up. This is a regulatory requirement for the company itself, not part of the cost of COREDO’s services.

Directors and Key Personnel

The minimum team of a Cypriot EMI company:

  • At least two directors
  • AML/KYC Officer
  • Compliance Officer
  • Legal counsel — may be outsourced
  • IT specialist — may be outsourced
  • Accountant — may be outsourced

Directors, managers and key personnel demonstrate higher education in finance or professional experience. The CBC assesses the fitness of the board of directors and management, so COREDO prepares their information with particular care.

Office and Presence in Cyprus

A physical office in Cyprus is mandatory for licensing, and the applicant is a Cypriot company in the form of a Limited (Ltd). We incorporate it at the very start of the project, together with its registered office and nominee services.

AML/CFT and Compliance

The application shows the regulator your internal AML/CFT controls, including the procedures for information on transfers of funds. It also sets out separately how the company will meet its obligations under the Cypriot anti-money laundering law. COREDO develops AML/CFT policies, compliance procedures and internal rules tailored to your business model.

Client Funds Safeguarding and IT

An EMI must safeguard the funds received in exchange for the electronic money it issues. The application describes the measures for safeguarding and protecting client assets, as well as the IT infrastructure: systems, security mechanisms and controls. We prepare these sections together with your technical team so that the description reflects your product precisely.

Reputation of Owners and Management

No person connected with the company may have a criminal record. For directors and senior management, information on identity, education and employment history is submitted together with fitness and propriety documents. Before incorporation begins, COREDO carries out standard customer due diligence (KYC/AML).

Audit and Reporting

An audit of the financial statements is mandatory for a Cypriot company. We name the auditor and internal auditor who will work with the institution in the application itself.

Cost of COREDO Services

Service Cost
Full package: company incorporation in Cyprus + CBC EMI licence EUR 108,000 + VAT

One package covers the entire journey — from incorporating the Cypriot company to the CBC’s decision on the licence. The package price includes:

  • Company incorporation in Cyprus (Ltd), including registered office, nominee services and all state registration fees
  • Preparation of all documentation for the CBC application
  • Business plan and operational plan in line with CBC requirements
  • AML/CFT policies, compliance procedures and internal rules
  • Submission of the licence application to the Central Bank of Cyprus
  • Representation and liaison with the CBC throughout the entire licensing process
  • Full legal support for the duration of the project

We confirm the final price for your project: it depends on the project’s specifics and the scope of services.

CBC fees are not included in COREDO’s price: you pay them directly to the regulator, on top of the package price.

  • Pre-application stage fee — EUR 5,000. A non-refundable fee; proof of payment is submitted together with the Pre-Application Document
  • Licence application fee — EUR 10,000. The payment receipt is attached to the application

Comparison with Other Licence Types in Cyprus

The scope of services you plan determines the licence type and the minimum capital:

Licence type Services Minimum capital E-money issuance
Payment institution: money remittance Category 6 EUR 20,000 No
Payment institution: payment initiation Category 7 EUR 50,000 No
Payment institution: full range Categories 1–5 EUR 125,000 No
EMI — this page All payment services + electronic money EUR 350,000 Yes

An EMI is the right choice when your product is built on electronic money: a digital wallet, a prepaid card, a stored client balance. The same licence also covers all payment services — from transfers to card issuing and acquiring. If you are still choosing between licence types, see the overview on the Financial Licences in Cyprus page.

List of Documents for an EMI Licence

COREDO prepares most of the package — the business plan, operational plan, AML/CFT policies and internal rules. From you, we need information about the company, its owners and the team.

Corporate Documents and Capital

  • Articles of association and, where applicable, resolutions on amendments
  • Notarised copy of the founding agreement or the resolution on establishing the company
  • Documents confirming paid-up share capital
  • Shareholder list with names and identification details
  • Information on persons holding a qualifying shareholding

Business Model and Finances

  • Operational plan describing the planned payment and electronic money services
  • Business plan
  • Opening balance sheet and income/expenditure overview; annual financial statements for the last 3 years, if available
  • Details of the auditor and internal auditor

Control, Security and Organisation

  • Description of client asset safeguarding and protection measures
  • Internal rules and accounting policies
  • IT infrastructure details: systems, security mechanisms and controls
  • Description of internal AML/CFT controls and wire transfer information procedures
  • Description of the organisational structure, including use of agents, branches or outsourcing

Management

  • Information on directors and senior management: identity, education, employment history and fitness and propriety documents
  • Any other documents requested by the CBC

Pre-Application Stage

  • Pre-Application Document in the CBC’s prescribed form, with the information relevant to the preliminary assessment
  • Proof of payment of the non-refundable EUR 5,000 fee

Procedure for Obtaining an EMI Licence in Cyprus

The project runs through clear stages, and at each of them COREDO carries the main workload.

Client Due Diligence and Project Kick-off (before incorporation begins)

The project starts with standard customer due diligence (KYC/AML). We then agree with you on the scope of services, the company structure and the list of documents.

01

Company Incorporation in Cyprus (approximately 2–3 weeks)

COREDO incorporates the Cypriot company (Ltd), arranges its registered office and nominee services, and pays all state fees.

02

Preparing the Documents for the CBC (before submission)

We prepare the business plan and operational plan in line with CBC requirements, along with the AML/CFT policies, compliance procedures and internal rules. In parallel, we gather information on the directors, owners, IT infrastructure and safeguarding of client funds.

03

Pre-Application Stage with the CBC (approximately 30 working days)

Since 3 August 2026 this stage has been mandatory before the formal application. COREDO prepares the Pre-Application Document and presents the project to the regulator; you pay the non-refundable EUR 5,000 fee directly to the CBC. The CBC carries out its preliminary assessment within 30 working days.

04

Submitting the Licence Application (after the pre-application stage)

COREDO compiles the complete package and submits the application to the Central Bank of Cyprus. The application is accompanied by the receipt for the EUR 10,000 fee, which you transfer directly to the regulator.

05

Review of the Application and Grant of the Licence (approximately 12–16 months)

The CBC examines the application, sends comments and questions, and sets a deadline for the reply. COREDO prepares the replies and refines the documents together with you, representing the company throughout the review until the regulator reaches its decision.

Indicative project timeline: company incorporation — approximately 2–3 weeks from receipt of all documents; pre-application stage — approximately 30 working days; EMI licence — approximately 12–16 months from submission of the complete application to the Central Bank of Cyprus.

06

Advantages of an EMI Licence in Cyprus

A passport to the entire EU and EEA.

A CBC licence lets you operate in all EU and EEA countries — through branches or on a cross-border basis, without a separate licence in each country.

Electronic money and all payment services under one licence.

Wallets, prepaid products, transfers, card issuing and acquiring all run under a single authorisation.

A flexible team.

Legal counsel, an IT specialist and an accountant can be outsourced, so your headcount stays lean at the start of the project.

EU tax system and a network of tax treaties.

Corporate income tax in Cyprus is 15% from 1 January 2026, and the standard VAT rate is 19%. Cyprus has concluded a wide network of double taxation treaties, which works well for an international structure.

Nominee services already in the package.

To benefit from tax treaty relief and tax exemptions, the company needs a VAT number and resident nominee services: a secretary, a director and, preferably, a shareholder. Nominee services are part of the company incorporation in the COREDO package.

One provider for the whole journey.

Company incorporation, documents, the application and the dialogue with the CBC — in one package at a clear price.

Our Experts

Gregory has headed compliance at COREDO since December 2020 and is responsible for the AML/CFT policies and compliance procedures that the regulator assesses.

Pavel Kos
Pavel Kos
Head of Legal. Has been with COREDO since June 2017 and has headed the legal team since July 2020. Possesses extensive experience in supporting financial licensing projects in the Czech Republic and other EU jurisdictions.
Alena Mach
Alena Mach
Executive Director
Nikita Veremeev
Nikita Veremeev
Founder & NED
Gregory Lutsenko
Gregory Lutsenko
Head of Compliance

Frequently Asked Questions

Is it enough to pay in EUR 350,000 of capital once?

Initial capital of at least EUR 350,000 is required at the time the licence is granted. After that, an EMI’s own funds are calculated on the volume of money issued: for e-money issuance, at least 2% of the average outstanding electronic money. Own funds may never fall below the initial capital, however: the higher of the two amounts applies.

Is a registered office alone enough for a Cypriot company?

No. The CBC grants a licence only to a legal person incorporated in Cyprus that has both its registered office and its head office on the island. The company must carry out at least part of its electronic money business in Cyprus. COREDO takes this into account from the outset, when choosing the structure and describing the organisation in the application.

What happens when the CBC raises questions on the application?

The regulator sends comments and questions and sets a deadline for the reply. If no reply arrives in time, the CBC treats the application as withdrawn. That is why COREDO keeps every deadline under control and prepares the replies together with you before it expires.

Can the CBC request an additional review?

Yes. At the pre-application stage or during the assessment of the application, the CBC may request an enhanced due diligence report from a specialist firm. In that case the preliminary assessment takes up to 50 working days. If the CBC commissions such a report from a third-party firm itself, the cost is borne by the applicant.

Can electronic money be issued through agents?

No, an EMI may not issue electronic money through agents. The use of agents, branches and outsourcing for other tasks is described in the organisational structure section of the application. COREDO builds the model you choose into the documents from the very start.

What obligations apply once the licence is granted?

The institution’s annual financial statements are audited by an auditor or audit firm, and the EMI informs the regulator in advance of any material changes to its client funds safeguarding measures. In the event of a major operational or security incident, the company notifies the CBC without undue delay.

What requirements apply to the company's owners?

The regulator refuses a licence if it is not satisfied that the shareholders with a qualifying holding are suitable. That is why the application includes information on such persons and a list of all shareholders with their identification details. The standard KYC/AML check that COREDO carries out before incorporation helps to gather this information in advance.

Contact Us

Want to obtain an EMI licence in Cyprus and enter the EU market? Tell us about your product and plans, and COREDO will take on the journey from company incorporation to the CBC licence.

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    COREDO – EU Legal & Compliance Services Expert legal consulting, financial licensing (EMI, PSP, CASP under MiCA), and AML/CFT compliance across the European Union. Headquartered in Prague, we provide seamless regulatory solutions in Germany, Poland, Lithuania, and all 27 EU member states.