An EMI licence authorizes your company to issue electronic money, open IBAN-linked payment accounts and provide the full range of PSD2 payment services, all from a single EU-authorized entity with passporting rights across 30+ countries. Authorized by the national competent authority in your chosen member state, your EMI can serve clients across the entire EU and EEA without per-country licensing.
The EMI licence gives your company the regulatory foundation to issue digital wallets, open client payment accounts, process SEPA transfers and passport all of those services across the entire EU from a single authorization. It is built on two EU payment directives (the Electronic Money Directive and the Payment Services Directive) that set uniform rules across all member states, which is why EMI authorization in one country is accepted and recognized across the full EU and EEA.
The EMI licence is the right authorization if your business needs to issue electronic money, manage client payment accounts or build EU-wide payment infrastructure. Below are the four business types most commonly served by an EMI. If your model combines crypto-asset services with fiat payments, a separate MiCA CASP authorization may also be required alongside the EMI licence.
Companies that need an EMI licence share one common requirement: they must hold client money in a regulated environment and move it across borders compliantly. A Canada MSB or a Swiss SRO can cover crypto-to-fiat exchange without e-money issuance rights, and an EU MiCA CASP licence covers crypto-asset services but not fiat payment accounts. As soon as your business needs to open individual client payment accounts, issue IBANs, operate a prepaid card programme or offer balances redeemable at par, the EMI licence is the only EU framework that covers all of those activities in a single authorization. Our legal opinion assesses your business model to confirm which licence category applies and which jurisdiction offers the most favourable regulatory and tax position for your specific structure.
The single most important difference between an EMI and a Payment Institution is that only an EMI can issue electronic money: stored value held in a client wallet or account that belongs to the client until they spend or redeem it. A PI executes payments on behalf of clients but cannot create or hold e-money balances. In practice this means a PI cannot operate a prepaid card programme, a consumer e-wallet or a multicurrency account where the client holds a balance. Both carry full EU passporting rights and safeguarding obligations, so the choice comes down to whether your model requires e-money issuance or payment execution only.
| Feature | EMI | PI |
|---|---|---|
| Issue electronic money (e-wallets, prepaid cards, stored value) | ✓ Yes | ✗ No |
| Hold client balances as e-money indefinitely | ✓ Yes | ✗ No — payment execution only |
| Open and maintain IBAN-linked payment accounts | ✓ Yes | ✓ Yes |
| All 8 PSD2 payment service categories | ✓ Yes | ✓ Yes |
| SEPA payments, direct debit and credit transfers | ✓ Yes | ✓ Yes |
| Mastercard / VISA card scheme eligibility | ✓ Yes | ✓ Yes |
| Client fund safeguarding obligation | Mandatory (EMD2) | Mandatory (PSD2) |
| EU/EEA passporting rights | ✓ 30+ countries | ✓ 30+ countries |
| Minimum initial capital | €350,000 | €125,000 |
| Typical authorization timeline | 9-12 months | 6-12 months |
Note: both licences are governed by EU directives implemented uniformly across all member states. Capital figures are the regulatory minimums; actual requirements may be higher based on business volume. Contact us to confirm which licence applies to your model.
MAXCORP covers the four leading EU member states for EMI authorization, each offering full PSD2/EMD2 licensing, EU passporting rights and direct SEPA network connectivity. The optimal choice depends on your target markets, corporate tax strategy, substance requirements and time to market. Our Gold readiness audit includes a formal jurisdiction recommendation based on your specific model and objectives.
Jurisdiction selection is included in the Gold readiness audit. We assess your business model, tax objectives and substance capacity before making a formal recommendation.
Contact us for a free initial consultation.
We offer three service tiers to match different stages of readiness and project scope. The Gold readiness audit is a standalone assessment for companies evaluating jurisdictions and costing out their EMI project. Platinum covers the full licensing cycle from legal documentation through NCA authorization. Custom adds operational team building and local substance setup for companies that need a fully operational EMI from day one.
Note: Platinum and Custom pricing depends on jurisdiction and scope. Pricing shown is indicative. Company formation, share capital injection and annual NCA supervisory fees are separate. Contact us for a detailed proposal.
The EMI authorization process follows a structured regulatory sequence common across all EU member states, though exact timelines vary by NCA and application complexity. Well-prepared applications with complete documentation consistently progress faster than those requiring multiple rounds of supplementary information requests from the NCA. In practice, the end-to-end journey from initial engagement through to NCA authorization and SEPA go-live takes 9-12 months for most applicants. The single biggest driver of delays is documentation quality: NCAs pause the formal review clock each time they issue a supplementary information request, which can extend the process by weeks or months. A thorough preparation phase, a pre-submission meeting with the NCA and a complete, internally consistent application pack are the most effective ways to protect your timeline. MAXCORP manages each of these stages, from the initial legal opinion through to post-authorization compliance setup.
* Timelines are indicative and depend on jurisdiction, documentation quality, NCA workload and the volume of supplementary information requests. MAXCORP manages the full process to minimize delays at each stage.
We evaluate your business model, service scope and target markets, determine your optimal jurisdiction from Malta, Cyprus, Lithuania or Latvia, and produce a written readiness report with a clear project roadmap and cost estimate.
We incorporate your EMI entity in the chosen jurisdiction, arrange the registered office and local directorship, and coordinate the initial capital injection of at least €350,000 into a designated EU credit institution account.
Our team prepares the full regulatory documentation package including AML/CFT policies, governance structure, MLRO appointment, business plan and safeguarding arrangements, and files the completed application with the NCA for formal review.
Once the NCA grants authorization, your EMI is registered and passporting notifications can be filed across target EU/EEA markets. We provide ongoing support including MLRO outsourcing, AML reporting and annual supervisory obligation management.
An Electronic Money Institution (EMI) licence is an EU authorization issued under EMD2 and PSD2 by a national competent authority. It permits your company to issue and redeem electronic money, maintain client IBAN payment accounts, provide the full range of PSD2 payment services and passport all those activities across 30+ EU and EEA countries from a single authorization. An EMI can hold client balances as stored e-money, which a Payment Institution cannot.
Electronic money is a monetary value stored on an electronic device or account, issued against receipt of funds, and redeemable at par on demand. A payment account holds funds for executing payment transactions. An EMI can provide both: it issues e-money and can maintain payment accounts linked to IBANs. An EMI account linked to a Mastercard or VISA card that can be used anywhere becomes an open payment account subject to full PSD2 safeguarding rules, not just the closed e-money rules.
The minimum initial own funds requirement for a full EMI licence is EUR 350,000 across all EU member states, as set by EMD2. NCAs assess ongoing capital adequacy against two methods: a fixed overhead requirement (one quarter of prior year fixed costs) and a percentage of average outstanding e-money. In practice, regulators expect capital well above the minimum at the time of application to demonstrate financial soundness. Contact us for a capital planning assessment tailored to your business model.
NCAs conduct a fit-and-proper assessment of all directors, shareholders holding 10% or more of voting rights and key function holders. Your management body must have adequate education, experience and good repute to run a regulated payment institution. A minimum of two executives who effectively direct the business is typically required. You will need a dedicated MLRO (Money Laundering Reporting Officer), an information security officer and a compliance function. Exact requirements vary by jurisdiction.
A complete application includes: programme of operations, detailed business plan with financial projections, AML/CFT policies and procedures, governance structure and management body questionnaires, description of safeguarding arrangements, IT security and business continuity plan, structural organisation chart, shareholder and UBO documentation with source of funds, and evidence of initial capital. NCAs review all documents for consistency with the proposed business model. Incomplete submissions pause the review clock. Contact us for a full document checklist.
Under EMD2, NCAs must decide within 3 months of a complete application. In practice the clock pauses each time the regulator issues supplementary information requests, which is common on first submission. The full process from initial pre-application meeting to receiving the licence typically takes 9-12 months. All four jurisdictions we cover encourage a pre-application meeting before formal submission, which reduces the number of queries during the formal review.
Under EMD2, EMIs must protect client funds using one of two methods: segregation into a dedicated account at an EU credit institution, separate from the EMI’s own funds; or coverage by an insurance policy or comparable guarantee. Most regulators prefer the segregated bank account approach. The safeguarding account must be established before the EMI commences operations and evidence of it is required as part of the authorization process. MAXCORP assists with bank introductions for safeguarding accounts.
All four NCAs we work with strongly encourage a pre-application meeting before formal submission. At this stage your company does not need to be incorporated yet. The regulator reviews your planned business model, identifies regulatory concerns and advises on documents. This meeting significantly reduces queries during the formal review and in many cases shortens the overall timeline. MAXCORP coordinates pre-application meetings with the NCA as part of the Platinum and Custom packages.
Yes. A licensed EMI can open and maintain IBAN-linked payment accounts for individual and business clients, and access SEPA via the central bank payment systems in its licensing jurisdiction. This includes TARGET2, SCT Inst (SEPA Instant), SDD and SCT. Direct access to the regulator-operated SEPA infrastructure is one of the main practical advantages of licensing in our covered jurisdictions, enabling your clients to send and receive euro payments across the EU.
Yes. All four jurisdictions require your EMI to have its registered and head office in the member state, and your management body must effectively direct operations from there. NCAs conduct substance assessments during the review. You will need at minimum a locally based MLRO and executive management who can meet with the regulator and are available to the supervisory authority on short notice. MAXCORP provides substance solutions including outsourced MLRO and compliance officer services across all four jurisdictions.
Yes. Under MiCA Regulation (EU) 2023/1114), only credit institutions and authorized EMIs may issue e-money tokens (EMTs) in the EU. Holding an EMI licence therefore provides the regulatory status required to issue stablecoins backed by a single fiat currency. However, issuing an EMT requires separate steps including preparation of a MiCA-compliant crypto-asset white paper and notification to the NCA. MAXCORP can advise on the combined EMI plus EMT structure. Contact us to discuss.
Authorized EMIs submit regular prudential and AML/CFT reports to their NCA, typically quarterly and annually. Reporting covers outstanding e-money, payment transaction volumes, own funds adequacy and AML risk assessments. NCAs may conduct on-site and off-site inspections at any time. Annual supervisory fees are charged based on the institution’s size and activity. Any material changes to the business model, key personnel or ownership structure require prior NCA notification or approval. MAXCORP provides ongoing compliance support and regulatory reporting assistance post-authorization.
Contact us through the form below or use any of our direct channels to discuss your EMI licensing project. Every project we handle is backed by our team’s hands-on expertise across all four jurisdictions and a thorough compliance process, ensuring all regulatory requirements are addressed before NCA submission. Share your business model and preferred jurisdiction and we will respond with an initial project review.
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Contact us to discuss your EMI project with our licensing team or to arrange an online meeting.
