A PI licence authorizes your company to provide the full range of PSD2 payment services including credit transfers, card acquiring, money remittance, payment initiation and account information services, from a single EU-authorized entity. Authorized by the national competent authority in your chosen member state, your PI can serve clients across the entire EU and EEA via passporting without per-country licensing.
A PI licence provides a lower-capital, faster EU authorization than an EMI, covering all PSD2 payment services without e-money issuance or stored-value requirements. Our team assesses your business model, identifies the optimal jurisdiction and builds your application file. Every PI authorization we handle is backed by our in-house legal team’s expertise across Malta, Cyprus, Lithuania and Latvia, ensuring all PSD2 substance and documentation requirements are addressed before NCA submission.
A PI licence is the right EU authorization for companies that execute payment transactions on behalf of clients without issuing electronic money or holding client funds as stored value. Below are the four business types most commonly served by a PI licence. If your model also requires e-money issuance or stored client balances, an EMI licence is the appropriate upgrade.
A PI licence is the most capital-efficient route to full EU payment services: one authorization covers transfers, card issuing, merchant acquiring, remittance, PIS and AIS across 30 EU/EEA countries. Unlike a Canada MSB or Swiss SRO, a PI gives you individual client payment accounts and IBAN issuance. Unlike a MiCA CASP, it covers fiat payment infrastructure, not just crypto-asset services. The PI sits at the crossroads of both: fintechs, crypto platforms and payment companies use it to add regulated fiat rails without the capital burden of a full banking licence. Our legal team assesses your business model, recommends the optimal jurisdiction and manages the full authorization process from preparation to NCA go-live.
PSD2 provides three authorization levels for non-bank payment service providers, each suited to a different business model and capital position. The full PI covers all PSD2 services with EU passporting. The EMI adds e-money issuance on top. The Small PI (Lithuania and Latvia only) is a domestic-only sandbox entry with no capital requirement and a 3-4 month authorization track.
| Criteria | Payment Institution (PI) | Electronic Money Institution (EMI) | Small PI (Restricted) |
|---|---|---|---|
| Regulating directive | PSD2 | PSD2 | PSD2 (limited scope) |
| Min. initial capital | €20,000 – €125,000 | €350,000 | None required |
| Issue electronic money | Not permitted | Yes, core permission | Not permitted |
| Hold client balances | No stored balances | Yes, as e-money | No stored balances |
| Credit transfers / SEPA | Yes | Yes | Limited |
| Card issuing | Yes (payment instrument) | Yes | No |
| PIS / AIS (open banking) | Yes | Yes | No |
| EU/EEA passporting | Yes, 30 EU/EEA countries | Yes, 30 EU/EEA countries | No, domestic only |
| MiCA e-money token | Not permitted | Yes, under MiCA | Not permitted |
| Typical timeline | 6-9 months | 9-12 months | 3-4 months |
| Packages from | From €60,000 | From €80,000 » | On request |
Informational only. Capital requirements vary by services provided. Small PI available in Lithuania and Latvia (domestic only, no passporting). Contact us for a tailored licence recommendation.
We cover the four leading EU member states for PI authorization, each offering full PSD2 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 PI 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 PI 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 PI 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. Our team 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. Our team 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 recommend whether a full PI, small PI or EMI is the right structure. We produce a written readiness report with a clear project roadmap.
We incorporate your PI entity in the chosen jurisdiction, arrange the registered office and local directorship, and coordinate the initial capital injection (from €20,000 to €125,000 depending on services) into a designated EU credit institution account.
Our team prepares the full PSD2 documentation package including programme of operations, AML/CFT policies, governance structure, MLRO appointment, safeguarding arrangements and business plan, and files the completed application with the NCA.
Once the NCA grants authorization, your PI 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.
A Payment Institution (PI) licence is an EU authorization issued under PSD2 (Directive 2015/2366/EC) by a national competent authority. It permits your company to provide the full range of PSD2 payment services including credit transfers, direct debits, card acquiring, money remittance, currency exchange, payment initiation and account information services, and to passport those activities across 30 EU/EEA countries from a single authorization. A PI cannot issue electronic money or hold client balances as stored e-money value.
The key difference is e-money issuance. An EMI can issue electronic money and hold client funds as stored e-money balances. A PI provides all the same PSD2 payment services but cannot issue e-money or maintain stored-value accounts. A PI requires lower initial capital (€20,000 to €125,000 vs €350,000 for an EMI) and typically authorizes faster. If your model does not require stored client balances or e-money wallets, a PI is the more capital-efficient route.
PSD2 sets three capital tiers based on services. Money remittance only: €20,000 minimum. Payment initiation services only: €50,000 minimum. All other PSD2 services (credit transfers, direct debits, card acquiring, FX): €125,000 minimum. NCAs also assess ongoing capital adequacy using one of three methods: fixed overhead requirement, transaction volume percentage, or relevant indicator with a scaling factor. Regulators expect capital above the minimum at application stage. Contact us for a capital planning assessment.
All four NCAs conduct a fit-and-proper assessment of directors, shareholders holding 10% or more of voting rights and key function holders. Your management body must have adequate education and experience. You will need a dedicated MLRO, an information security officer and a compliance function. The four eyes principle applies: at least two persons must effectively direct the business. NCAs assess management time commitment and local availability during the review process.
A complete PI application includes: programme of operations, business plan with three-year financial projections, AML/CFT policies and procedures, safeguarding arrangements description, governance structure and management body questionnaires, IT security and business continuity plan, organisational chart, shareholder and UBO documentation with source of funds, evidence of initial capital, and professional indemnity insurance where required. Incomplete submissions pause the NCA review clock. Contact us for a full document checklist.
Under PSD2, NCAs must decide within 3 months of a complete application. In practice the clock pauses when the regulator issues supplementary information requests. The full process from pre-application meeting to receiving the licence typically takes 6-9 months for a PI, which is faster than an EMI (9-12 months). Lithuania and Latvia tend to be the most efficient of our four jurisdictions. All NCAs strongly encourage a pre-application meeting before formal submission.
A PI must safeguard client funds received in connection with payment transactions. Options under PSD2 include segregating client funds in a dedicated account at an EU credit institution, separate from the PI’s own funds, or covering them with an insurance policy or comparable guarantee. Unlike an EMI, a PI does not hold client funds as stored e-money; funds must be safeguarded only for the duration of payment execution and remitted to the payee promptly. We assist with bank introductions for PI safeguarding accounts.
All four NCAs encourage a pre-application meeting before formal submission. At this stage your company does not need to be incorporated yet. The NCA reviews your planned business model, services and structure, and advises on documents and common deficiencies. This meeting typically reduces supplementary information queries during formal review and can shorten the overall timeline. We coordinate pre-application meetings as part of the Platinum and Custom packages.
Yes. A licensed PI can open and maintain payment accounts and facilitate SEPA transactions for clients. Access to SEPA credit transfers and SEPA Instant depends on the PI’s banking arrangements. Lithuania’s CENTROlink and Latvia’s EKS provide direct SEPA access for licensed payment institutions. Card-based payment accounts may also be offered under a PI licence. Note that a PI cannot hold funds as stored e-money balances; client funds pass through to designated payee accounts.
Yes. All four jurisdictions require your PI to have its registered and head office in the member state, and management must effectively direct operations from there. You need at minimum a locally based MLRO and senior management available to the NCA. NCAs conduct substance assessments during the application review and may interview key personnel. We provide substance solutions including outsourced MLRO and compliance officer services across all four jurisdictions.
A Small PI (restricted activity licence) is available in Lithuania and Latvia as a sandbox entry point. It has no minimum capital requirement, faster authorization (3-4 months) and simplified governance requirements. However, it is limited to domestic operations only (no EU passporting), has restricted service scope (no PIS or AIS) and imposes transaction volume limits. It is designed for startups testing a business model before upgrading to a full PI with EU passporting rights. Contact us to assess which tier fits your stage.
Authorized PIs must maintain an active MLRO and compliance function, submit regular prudential and AML/CFT reports to the NCA (typically quarterly and annually), maintain ongoing capital adequacy and conduct annual AML/CFT risk assessments. Any material changes to business model, key personnel or ownership structure require prior NCA notification or approval. Annual supervisory fees are charged based on the PI’s transaction volumes. We provide 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 PI 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 PSD2 requirements are addressed before NCA submission. Share your business model, target services and preferred jurisdiction and we will respond with an initial project review.
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Contact us to discuss your PI project with our licensing team or to arrange an online meeting.
