EMI Licence in Malta

An Electronic Money Institution (EMI) licence in Malta allows a company to issue electronic money, maintain electronic money accounts, and provide a wide range of payment services, including card issuing, acquiring, money transfers, and payment initiation services.

COREDO provides end-to-end licensing support, including company incorporation in Malta, preparation of the licensing application, communication with the Malta Financial Services Authority (MFSA), assistance with building the required local team, and project support through to the issuance of the EMI licence.

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Cost of the service
from EUR 91,000

Regulatory Framework: MFSA, EMD2 and PSD2

The activities of electronic money institutions in Malta are regulated at two levels.

At the EU level, the foundation is formed by Directive 2009/110/EC (EMD2, the second electronic money directive), which establishes requirements for capital, organisational structure, and passporting of EMI institutions, and Directive 2015/2366/EU (PSD2), which regulates the payment services that EMIs provide in parallel with electronic money issuance. As a full EU member state, Malta applies both directives as part of the European regulatory framework.

At the jurisdiction level, supervision is exercised by the Malta Financial Services Authority (MFSA) — the sole regulator for financial services in Malta. The MFSA receives and reviews applications, issues licences, and carries out ongoing supervision of licensed institutions. This centralised regulatory model means direct access for the applicant to the regulator: all licensing matters are handled by a single authority under clear procedures.

Licence Details: What an MFSA EMI Licence Permits

An EMI licence issued in Malta grants its holder the following rights.

Issuance of Electronic Money:

  • Issuance of electronic money (e-money) and maintenance of client e-money accounts
  • Creation of own payment products based on electronic money — digital wallets and prepaid instruments

Payment Services — All 8 Categories under PSD2:

  • Issuance of payment cards and acquiring of payment transactions
  • Credit transfers
  • Direct debits
  • Money remittance
  • Payment initiation services
  • Account information services

Passporting Across the Entire EU/EEA.

A Maltese EMI licence is valid in all EU/EEA member states: the holder may operate either through the establishment of branches or on a cross-border basis, without a physical presence in each country and without obtaining a separate licence in each jurisdiction.

Important Restriction: a licensed institution may not accept deposits from the general public. Deposit-taking remains the prerogative of credit institutions (banks).

Requirements for Obtaining an EMI Licence in Malta

The MFSA imposes comprehensive requirements on the applicant’s capital, staffing, infrastructure, and reputation.

Minimum Share Capital

The required minimum capital depends on the scope of services the company plans to provide:

Capital Scope of Services
EUR 20,000 Money remittance services only (service category 6)
EUR 50,000 Payment initiation services only (service category 7)
EUR 125,000 All payment services (categories 1–8), excluding electronic money issuance
EUR 350,000 All payment services (categories 1–8) including electronic money issuance — full EMI licence

A full EMI licence with the right to issue electronic money requires capital of at least EUR 350,000. This is a regulatory requirement and should not be confused with the cost of COREDO’s project services.

Management Bodies and Staffing

Minimum staffing requirements for a Maltese EMI company:

  • At least 2 (two) local executive directors
  • Local AML Officer — responsible for anti-money laundering
  • Local Compliance Officer
  • Legal counsel — may be outsourced
  • IT specialist — may be outsourced
  • Accountant — may be outsourced

Directors, managers, and key personnel must demonstrate relevant education and professional experience in finance, law, or information technology.

Physical Office

A physical office in Malta is a mandatory condition for licensing. COREDO assists clients in identifying and securing suitable premises; office rental in Malta starts from EUR 360/month.

AML/CFT and Internal Controls

The applicant must develop and implement a system for combating money laundering and terrorist financing:

  • Description of internal AML/CFT controls and compliance procedures
  • Procedures for complying with wire transfer information requirements
  • Internal rules and accounting policies in accordance with MFSA requirements
  • Appointment of a local AML Officer and a local Compliance Officer

Prior to commencement of the project, COREDO conducts a standard client due diligence (KYC/AML) check in accordance with applicable compliance and regulatory requirements.

Fit & Proper: Reputation Requirements

  • All persons connected with the company must have a clean criminal record; criminal record certificates form part of the document package
  • For directors and managers, a complete set of information is submitted: identity details, education, full employment history, and documentation demonstrating fitness and propriety

Cost of COREDO Services

Company registration in Malta + MFSA EMI licence

EUR 91,000 + VAT

  • Company incorporation in Malta (Ltd), including registered address for 1 year, company secretary for 1 year, power of attorney (translation and notarisation), notarial deed of incorporation, and all state fees.
  • Preparation of all documentation required for the MFSA licence application.
  • Submission of the licence application to the MFSA.
  • Representation and liaison with the regulator throughout the entire licensing process.
  • Assistance with recruitment of local staff: executive directors, AML Officer, and Compliance Officer.
  • Assistance with identifying and securing a physical office in Malta.
  • Full legal support throughout the project.

Additional Services

from EUR 360

  • Corporate account opening (Safeguard account, IBAN via Central Link Switch, correspondent banking in multiple currencies) — EUR 14,500.
  • Technical solution (payment software): ready-made engine — from EUR 192,000.
  • Technical solution (payment software): built from scratch — from EUR 435,000.
  • Annual software maintenance — EUR 36,000.
  • Local executive director — from EUR 2,200/month.
  • Local AML Officer — from EUR 2,000/month.
  • Local Compliance Officer — from EUR 2,200/month.
  • Physical office rental in Malta — from EUR 360/month.

The final cost may vary depending on the specific case and the scope of services required. An exact calculation is provided following an initial consultation.

MFSA Regulatory Fees and Payment Terms

In addition to the cost of COREDO services, the applicant pays regulatory fees directly to the MFSA (not included in the package):

One-time non-refundable licence application fee — EUR 3,500 payable to the MFSA upon submission of the formal application

Annual supervisory fee — 0.02% of total balance sheet assets as at the end of the prior year, minimum EUR 2,500 per year

The terms and schedule of payment for COREDO services are set out in the service agreement. Work on the project begins after the client passes the standard due diligence (KYC/AML) procedure.

List of Documents for Obtaining an EMI Licence

Basic Client Documents

Registration is carried out remotely: all documents must be notarised, apostilled, and sent to COREDO via courier.

  • Copy of passport of each shareholder and director
  • Proof of address — utility bill, driving licence, or bank statement
  • Power of attorney
  • Criminal record certificate for each shareholder

Documents for the MFSA Application

  • Articles of association and founding documents of the applicant company
  • Operational plan describing the planned payment services or electronic money services
  • Business plan meeting MFSA requirements
  • Financial statements — opening balance sheet and income/expenditure overview; annual reports for the last 3 years (if available)
  • Internal rules and accounting policies in accordance with MFSA requirements
  • Description of IT and technical infrastructure, security systems, and controls
  • Description of internal AML/CFT controls, compliance procedures, and wire transfer information requirements
  • Description of organisational structure, including any use of agents, branches, or outsourcing arrangements
  • Shareholder list and details of qualifying shareholders
  • Information on directors and managers — identity, education, full employment history, and fit & proper documentation
  • Details of auditor and internal auditor
  • Any other documents required by the MFSA

Procedure for Obtaining an EMI Licence in Malta

Obtaining an EMI licence through COREDO proceeds in several sequential stages.

Preliminary Assessment and Due Diligence

COREDO analyses the business model, corporate structure, and scope of planned services — which determines the required capital (from EUR 20,000 to EUR 350,000). A standard client KYC/AML check is conducted, and the project plan and list of documents are agreed upon.

01

Company Incorporation in Malta (3–4 weeks)

COREDO incorporates the Maltese company (Ltd): prepares the notarial deed of incorporation, arranges the registered address and company secretary for the first year and the power of attorney with translation and notarisation, and pays all state fees. Incorporation takes 3–4 weeks and is carried out remotely — on the basis of the power of attorney and documents sent via courier.

02

Preparation of the Application and Local Infrastructure

The most labour-intensive stage: preparation of the business plan and operational plan, financial statements, AML/CFT policies, and descriptions of the IT infrastructure and organisational structure. In parallel, COREDO assists with recruitment of local staff (two executive directors, AML Officer, Compliance Officer) and the search for a physical office.

03

Submission of the Application to the MFSA

COREDO compiles the final package and submits the formal application to the MFSA. At this stage, the applicant pays the one-time non-refundable fee of EUR 3,500 to the regulator.

04

Review of the Application and Receipt of the Licence

COREDO represents the client throughout the entire review: responds to MFSA queries and coordinates refinement of the documents. Obtaining the EMI licence takes approximately 8–12 months, subject to the applicant’s full compliance with all MFSA requirements.

05

Estimated Project Timeline: company incorporation — 3–4 weeks; licence obtainment — approximately 8–12 months.

Advantages of Malta for EMI Licensing

Full EU Passporting Rights.

An MFSA-issued EMI licence allows the holder to provide services across all EU/EEA member states — through branches or on a cross-border basis — without obtaining a separate licence in each jurisdiction.

Established Regulatory Framework.

Malta has a mature, well-regarded financial services regulatory environment with clear procedures and direct access to the MFSA — the sole regulator for financial services on the island.

Effective Tax Rate of Approximately 5%.

Corporate income tax (CIT) is 35%; however, the tax refund mechanism may reduce the effective rate to approximately 5%. The standard VAT rate is 18%, with reduced rates of 7% and 5% applying to certain goods and services.

Wide Scope of Licensable Services.

The EMI licence covers all eight categories of payment services under PSD2 — including card issuance and acquiring, credit transfers, direct debits, money remittance, payment initiation, and account information services.

Electronic Money Issuance.

The full EMI licence allows the holder to issue electronic money and maintain client e-money accounts — the foundation for digital wallets and prepaid products.

Our Experts

The COREDO team has guided financial licensing projects since 2016.

Pavel Kos
Pavel Kos
Head of Legal. Pavel has worked at COREDO since June 2017 and leads the company's legal department. He specialises in financial licensing in EU jurisdictions, including EMI and PI licences, and possesses extensive experience in interaction with European regulators.
Basang Ungunov
Basang Ungunov
Lawyer. Basang has worked as a lawyer at COREDO since June 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 a full EMI licence differ from a licence for individual payment services?

The minimum capital in Malta depends on the scope of services: EUR 20,000 — money remittance only (category 6); EUR 50,000 — payment initiation only (category 7); EUR 125,000 — all payment services (categories 1–8) excluding electronic money issuance. A full EMI licence with capital of EUR 350,000 covers all eight categories of payment services and additionally grants the right to issue electronic money. If your business model involves digital wallets or prepaid products, you will specifically need a full EMI licence.

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

For a full EMI licence — all payment services in categories 1–8 plus electronic money issuance — capital of EUR 350,000 is required. Lower thresholds apply for narrower scopes of services: EUR 20,000, EUR 50,000, or EUR 125,000. This is an MFSA regulatory requirement, not related to the cost of COREDO’s services.

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

Incorporation of the Maltese company takes 3–4 weeks. Obtaining the EMI licence takes approximately 8–12 months, subject to the applicant’s full compliance with all MFSA requirements.

What staff is mandatory for a Maltese EMI company?

Minimum: two local executive directors, a local AML Officer, and a local Compliance Officer. Legal counsel, an IT specialist, and an accountant may be outsourced. A physical office in Malta is mandatory. Directors and key personnel must demonstrate relevant education and experience (finance, law, or IT), and all persons connected with the company must have a clean criminal record. COREDO assists with recruitment of local staff and the office search.

How much do COREDO services cost, and what fees does the MFSA charge?

The full COREDO project package — company registration plus complete licensing support — costs EUR 91,000 + VAT. Regulatory fees are paid directly to the MFSA: a one-time non-refundable application fee of EUR 3,500 and an annual supervisory fee of 0.02% of balance sheet assets as at the end of the prior year (minimum EUR 2,500 per year).

Can a Maltese EMI licence be used to operate across the entire EU?

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 a physical presence in each country and without separate licences in each jurisdiction. However, a licensed institution may not accept deposits from the general public.

Contact Us

Ready to begin the process of obtaining an EMI licence in Malta? COREDO specialists have been guiding clients since 2016 — from preliminary assessment and company registration to receipt of the licence from the MFSA.

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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.