EMI Licence

Yes. Non-EU shareholders and foreign founders can apply for an EMI Licence in EU jurisdictions. However, the applicant company must be incorporated in the chosen EU/EEA jurisdiction, and founders/directors will be subject to the same fit-and-proper checks regardless of nationality. In some countries additional scrutiny may apply to shareholders from high-risk jurisdictions. COREDO assists with company formation, registered office, and directorship arrangements where required.

Once licensed, an EMI must maintain minimum capital at all times, safeguard client funds in segregated accounts or covered by insurance/guarantee, submit periodic regulatory reports (annual accounts, prudential returns), have AML policies and controls tested by an independent audit function where appropriate to the size and nature of the business, renew AML policies as regulations change, and notify the regulator of material changes to ownership, management, or business model. Failure to maintain ongoing compliance can lead to licence suspension or revocation. COREDO offers post-licence compliance support and MLRO outsourcing services.

A complete documentation package is required: company registration documents, financial statements and forecasts, management information (resumes, qualification confirmation, reputation certificates), detailed business plan, IT systems and security policy descriptions, comprehensive AML/CFT policies, office location proof. COREDO prepares a complete document checklist for your specific jurisdiction.

An EMI Licence allows you to issue electronic money (store funds on behalf of clients) and provide payment services. A Payment Institution (PI) Licence only covers payment services — the PI cannot issue e-money or hold client funds for purposes other than executing payment transactions. EMI holders typically serve a broader range of fintech use cases including digital wallets, prepaid cards, and stored value accounts. The minimum capital also differs: EUR 350,000 for EMI vs EUR 20,000–125,000 for PI depending on the services offered.

You must implement comprehensive customer identification (Know Your Customer — KYC), beneficial owner verification (Know Your Business — KYB), and real-time transaction monitoring under national AML laws based on Directive (EU) 2015/849.

Mandatory reporting of suspicious transactions is required, and from 10 July 2027 the EU AML Regulation (2024/1624) applies directly. COREDO provides AML consulting, compliance audits, and ongoing compliance support.

Price differences reflect several factors: regulatory complexity in each jurisdiction, typical review timelines, required documentation volume, and COREDO’s experience with local regulators.

The Canadian option is an MSB registration, a different regime from an EMI licence, so it costs less; among EMI licences, Estonia is priced lowest. Spain and Portugal require more preparation time and resources.

PSD2 is being replaced by the Payment Services Regulation (PSR) and the Payment Services Directive 3 (PSD3). The Council’s final compromise texts date from April 2026, and the European Parliament’s ECON committee approved them on 5 May 2026. As of October 2026 neither act has been formally adopted, so PSD2 and EMD2 remain the law in force. Under the agreed texts, PSD2 and EMD2 are repealed 21 months after PSD3 enters into force. An existing EMI may continue its activities for up to 27 months after entry into force while its regulator assesses the information it submits. Once compliance is confirmed, it is treated as an authorised payment institution. Licence holders should plan to update their compliance frameworks, safeguarding arrangements, and customer disclosures. COREDO monitors these regulatory developments and can advise clients on transition planning.