COREDO > Licensing > EMI Licence

EMI Licence

EMI Licence: Electronic Money Institution Licence in the EU

EMI Licence — authorization to issue electronic money and provide payment services in the EU under EMD2 and PSD2 frameworks. It enables operations across the EEA and business scaling through passporting in 27 countries.

COREDO delivers complete EMI licensing: document preparation, application submission, regulator communication, and licence acquisition.

Get a Consultation

Cost of the service
from 25 000 EUR

Who Needs an EMI Licence

An EMI Licence is required by companies that intend to issue electronic money or provide payment services as regulated activities. It is most relevant for:

Fintech startups

launching digital wallets, prepaid card products, or neobank services

Payment gateway operators

processing transactions for EU merchants or consumers

Remittance companies

offering cross-border money transfers within the EEA

E-commerce platforms

seeking to embed payment and stored-value functionality

Corporate treasury departments

automating multi-currency payment flows across European entities

If your business model involves holding client funds electronically or initiating payment transactions, an EMI Licence is typically the appropriate regulatory framework.

What the EMI Licence Permits

The EMI Licence authorizes the following business activities:

Electronic money issuance (e-money) — Create and manage electronic financial instruments for end users.

E-wallet services — Provide digital wallet services and manage customer funds.

Debit payment card issuance — Emit debit payment cards for clients.

Payment services — Offer fund transfers, collection, currency conversion, and other payment operations.

Payment account management — Manage accounts for storing and processing customer electronic money.

Each service is strictly regulated. Specific security, client data protection, and asset management requirements apply.

EMI Licence Requirements

Obtaining an EMI Licence requires compliance with rigorous regulatory standards:

Minimum Capital:

EUR 350,000 fully paid and held in a bank account in the European Economic Area.

This requirement is set by Directive 2009/110/EC (EMD2, Article 4) and mandatory across all jurisdictions. Capital guarantees your ability to meet client obligations.

Competent Management:

Founders and board members must hold appropriate qualifications, possess professional experience in the financial sector, and maintain an impeccable business reputation.

Regulators conduct thorough background checks, including sanctions list screening and Political Exposed Person (PEP) verification.

AML/CFT Compliance:

Implement mandatory AML controls and CFT procedures under the AMLD6 directive.

This includes customer identification (KYC), beneficial owner verification (KYB), transaction record-keeping, monitoring, and regular audits.

IT Infrastructure and Security:

Develop and deploy robust data protection systems and ensure operational resilience under DORA (Digital Operational Resilience Act).

Ensure GDPR compliance for personal data protection and implement backup systems.

Business Plan:

Provide detailed description of planned services, target market, financial forecasts for initial years, risk management strategy, and development roadmap.

The regulator assesses your business model viability.

Physical Presence:

Maintain a registered office and operational center in the jurisdiction where you submit your licence application.

This requirement ensures the regulator’s ability to supervise your operations and service delivery.

How We Work: Licensing Stages

Obtaining an EMI Licence typically takes 3 to 6 months across four stages:

Stage 1: Document Preparation (3–4 weeks)

Collect and prepare all required documentation: company articles, founding documents, financial statements, and management qualification records.

Prepare business plan describing services, IT infrastructure and security protocols, comprehensive AML/CFT policies, and office location proof.

01

Stage 2: Application Submission (1–2 days)

Submit the official application and all appendices to the national regulatory authority (central bank or financial supervisory body). The review period begins upon submission.

02

Stage 3: Application Review (2–4 months)

The regulator conducts comprehensive analysis, evaluates management qualifications, assesses business plan and IT infrastructure. Regulators may request additional information at this stage.

Review timelines vary by jurisdiction and document completeness.

03

Stage 4: Licence Issuance (1 week after approval)

Following approval, the licence appears in the regulator’s registry. Your institution receives official authorization to begin operations under the granted licence.

04

Total timeline from document preparation to licence acquisition is typically 3–6 months, depending on jurisdiction, document completeness, and business plan complexity.

Jurisdictions and EMI Licence Pricing

COREDO provides comprehensive EMI licensing services across the following jurisdictions.

Prices reflect COREDO service costs (document preparation, application submission, regulator communication). Government fees vary by country:

Jurisdiction	COREDO Price	Notes
Canada (MSB)	from EUR 25,000	Fast licensing, favorable fintech regulatory framework
Estonia	from EUR 40,000	Digital-first approach, fintech-focused, advanced IT infrastructure
Czech Republic	from EUR 45,000	EU member, close to COREDO HQ, experienced regulator (ČNB)
Singapore	from EUR 55,000	Asian market access, recognized global jurisdiction, high standards
Lithuania	from EUR 70,000	EU member, rapid review, growing Baltic fintech hub
Portugal	from EUR 80,000	EU member, stable regulation, attractive European market
Spain	from EUR 80,000	Major European jurisdiction, large market potential

Each jurisdiction has distinct regulatory characteristics, typical review timelines, and specific requirements.

COREDO helps you select the optimal option based on your goals, target market, and readiness level.

E-Money Licensing Beyond the EU

While EMI licensing is structured primarily within the EU and EEA framework, fintech companies seeking global reach must understand regulatory requirements in major non-EU financial centers.

United Kingdom (FCA)

Electronic money institutions are regulated by the FCA under the Electronic Money Regulations 2011 and Payment Services Regulations 2017.

Minimum capital: GBP 350,000 (fully paid).
Regulation: FCA Handbook (EMoney sourcebook).
Safeguarding: segregated accounts or insurance/guarantees for client funds.
Authorization timeline: 3–12 months.
Key requirements: AML/CFT compliance, IT security, governance frameworks.

Switzerland (FINMA)

No dedicated EMI license exists; electronic money services are regulated under banking law and FINMA supervision.

FinTech license (BankA Art. 1b): up to CHF 100 million deposits without lending activities.
Capital: CHF 500,000 – 2,000,000 depending on business model.
FINMA Sandbox: up to 24 months, CHF 1 million deposit limit.
SRO membership required (e.g., SIX-approved SROs).
Regulatory approach: risk-based and proportional.

Dubai and UAE (VARA/DFSA/CBUAE)

Multi-regulatory framework for electronic money and digital asset services.

CBUAE SVF: AED 5–10 million capital, AML/CFT and cybersecurity requirements, 4–6 months authorization.
DFSA (DIFC): USD 500,000–1,000,000 capital, 2–4 months timeline.
ADGM: dedicated EMI and payment services regime.
VARA: regulation of stablecoins and crypto-linked payment tokens.
Key feature: jurisdiction selection based on target market (local vs international).

Passporting: Expand to Other EEA Countries

A key licence advantage is the ability to operate not only in your licensing jurisdiction but also across European Economic Area (EEA) countries.

This is achieved through licence passporting under Article 3 of Directive 2009/110/EC (EMD2) and Article 28 of Directive 2015/2366/EC (PSD2).

After obtaining your EMI Licence, you can:

Notify your regulator of your intention to provide services in other European countries
Begin offering services in selected jurisdictions without obtaining separate licences
Expand operations across geographies without additional licensing costs

Passporting makes the EMI Licence exceptionally attractive for companies planning European expansion or serving multi-country clients.

Comparison Table

Licence	Minimum Capital	Timeline	Jurisdictions	Passporting
EMI (Estonia)	EUR 350,000	3–4 months	EU, EEA	✅ Yes
EMI (Spain)	EUR 350,000	4–6 months	EU, EEA	✅ Yes
MSB (Canada)	Not required	3–5 months	Canada	❌ No

Case Studies

Case 01Fintech Virtual Card Issuer in Estonia.

A fintech startup developing virtual card issuance platform required EMI licence with EUR 350,000 capital. COREDO prepared comprehensive business plan, AML/CFT policies, and payment infrastructure documentation. EMI licence obtained in 4 months; startup immediately launched virtual card product and expanded to 8 EEA markets through passporting without additional licensing requirements.

Case 02Payment Gateway Operator in Lithuania.

A money transfer specialist sought EMI licence in Lithuania to serve EU clients and enable SEPA transfers. COREDO coordinated full licensing application including infrastructure specifications and compliance framework. Licence approved in 3.5 months; operator began processing payments and grew client base 5x within 12 months across all EU jurisdictions.

Case 03Electronic Money Platform in Czech Republic.

An e-commerce payment platform needed EMI licence to issue electronic money products and facilitate cross-border transfers. COREDO handled licensing documentation, regulatory coordination with ČNB, and post-licence operational setup. Licence issued in 4 months; platform launched white-label e-money solutions with EUR 20 million transaction volume in first quarter.

Discuss Your Acquisition

Why Choose COREDO

COREDO is a leading European financial licensing consultant with deep expertise in EMI, PSP, CASP, and other financial licences.

Experience:

Since 2016, COREDO has prepared and obtained over 100 financial licences for clients across all European jurisdictions and beyond.

Each project builds accumulated expertise, regulatory nuance knowledge, predictive regulator inquiry ability, and understanding of different supervisory authorities’ preferences.

Personal Manager:

COREDO assigns each client a dedicated manager overseeing the entire process from start to finish.

Your manager ensures timeline adherence, document quality, efficient regulator communication, and rapid resolution of any emerging issues.

Full-Cycle Service:

COREDO doesn’t just advise — we handle all work: prepare all documents, obtain required certificates, submit applications to regulators.

We conduct negotiations and correspondence with regulators and secure your licence. You only provide source data and approve key decisions.

Global Coverage:

We operate across all 27 EU member states plus Canada, Singapore, and other key jurisdictions.

This enables selecting the optimal option for your specific goals and target market.

Expert Team:

COREDO’s qualified legal and financial licensing consultants possess deep understanding of different regulators’ requirements.

Contact us

Our Experts

Pavel Kos

Leads COREDO's legal team since July 2020. Pavel coordinates EMI licensing processes across multiple jurisdictions. Education: University of Finance and Administration, Prague.

Frequently Asked Questions

Can a non-EU company or foreign founder apply for an EU 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.

What are the ongoing compliance obligations after obtaining an EMI Licence?

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), conduct annual internal AML audits, 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.

What documents are needed for an EMI Licence application?

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.

What is the difference between an EMI Licence and a Payment Institution (PI) Licence?

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.

What AML/KYC requirements apply with an EMI Licence?

You must implement comprehensive customer identification (Know Your Customer — KYC), beneficial owner verification (Know Your Business — KYB), and real-time transaction monitoring under AMLD6.

Mandatory reporting of suspicious transactions is required. COREDO provides AML consulting, compliance audits, and ongoing compliance support.

Do I need an office in the licensing jurisdiction?

Yes, physical presence is mandatory. You must maintain a registered office and operational center in your licence application jurisdiction. This ensures local regulator supervision of your operations. COREDO can assist with company registration and office space location in your chosen jurisdiction.

Why do EMI Licence prices vary significantly by jurisdiction?

Price differences reflect several factors: regulatory complexity in each jurisdiction, typical review timelines (4 weeks to 4 months), required documentation volume, and COREDO’s experience with local regulators.

Canada and Estonia offer more favorable regimes, so prices are lower. Spain and Portugal require more preparation time and resources.

How does PSD3 affect existing and new EMI Licences?

PSD2 is being replaced by the Payment Services Regulation (PSR) and the Payment Services Directive 3 (PSD3), currently advancing through the EU legislative process. Existing EMI Licences issued under PSD2/EMD2 will remain valid, but licence holders will need to assess and update their compliance frameworks, safeguarding arrangements, and customer disclosure obligations once PSD3 enters into force (expected in 2026–2027). The EMD2 is also under review as part of this broader payments legislation overhaul. COREDO monitors these regulatory developments and can advise clients on transition planning.

Contact COREDO

Ready to start the EMI licensing process? Contact COREDO for a free consultation.

Phone: +420 228 886 867 · Email: info@coredo.eu K Cervenemu dvoru 3269/25a, Prague, 130 00, Czech Republic