Electronic Money Institution Licence Advisory — UK, EU & Global
An electronic money institution licence permits firms to issue electronic money (e-money), providing digital wallets, prepaid cards, and stored-value payment products. We support e-money businesses from initial strategy through to full authorisation.
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What is a Electronic Money Institution Licence?
An electronic money institution (EMI) licence authorises firms to issue electronic money — a digital representation of monetary value stored electronically that is issued on receipt of funds for the purpose of making payment transactions. E-money products include prepaid cards, digital wallets, and stored-value accounts.
The regulatory framework for EMIs is governed by the Electronic Money Regulations 2011 in the UK and the Electronic Money Directive (EMD2) across the EU. EMIs are supervised by the same competent authorities as payment institutions — the FCA in the UK and national regulators in EU member states.
EMI authorisation is a more demanding process than PI authorisation, reflecting the additional risks associated with issuing electronic money. The key differentiator is that EMIs create a monetary liability to the customer — when a customer loads funds onto an e-money product, the EMI owes that money back to the customer. This requires higher capital requirements, more robust safeguarding arrangements, and stronger governance.
For businesses seeking to offer branded payment products, digital wallets, or multi-currency accounts, an EMI licence provides the broadest set of permissions. EMIs can provide all the same payment services as a PI, plus the ability to issue e-money. This makes the EMI licence the preferred option for many fintech business models.
Where Can You Obtain a Electronic Money Institution Licence?
We support licensing in the following jurisdictions.
FCA
United Kingdom
Capital: £350k
Timeline: 6–12 months
Full EMI or Small EMI available, UK market access
Bank of Lithuania
Lithuania
Capital: €350k
Timeline: 3–6 months
EU-wide passporting across all EEA member states
Central Bank of Ireland
Ireland
Capital: €350k
Timeline: 6–12 months
Common law, English-speaking, EU passporting
DNB
Netherlands
Capital: €350k
Timeline: 6–12 months
Strong financial infrastructure, EU passporting
MFSA
Malta
Capital: €350k
Timeline: 4–8 months
EU passporting, English-speaking, competitive costs
CSSF
Luxembourg
Capital: €350k
Timeline: 6–12 months
EU passporting, premium financial centre
BaFin
Germany
Capital: €350k
Timeline: 6–12 months
EU passporting, largest EU economy
ACPR
France
Capital: €350k
Timeline: 6–12 months
EU passporting, second-largest EU economy
Bank of Spain
Spain
Capital: €350k
Timeline: 6–12 months
EU passporting, gateway to Latin America
CBC
Cyprus
Capital: €350k
Timeline: 4–9 months
EU passporting, competitive costs, English-speaking
NBB
Belgium
Capital: €350k
Timeline: 6–12 months
EU passporting, home of EU institutions
CBUAE
United Arab Emirates
Capital: AED 5M+
Timeline: 6–12 months
Middle East gateway, stored value facility licence
MAS
Singapore
Capital: SGD 250k
Timeline: 6–12 months
Asia-Pacific gateway, world-class regulator
FINTRAC
Canada
Capital: No capital requirement
Timeline: 6–8 weeks
Fast registration, growing fintech market
CNB
Czech Republic
Capital: €350k
Timeline: 4–8 months
EU passporting, competitive costs
United Kingdom — Electronic Money Institution Licence
Overview
The FCA authorises two categories of e-money institution: Authorised EMIs (AEMIs) with no e-money issuance limits, and Small EMIs (SEMIs) with average outstanding e-money limited to €5 million.
Key Requirements
AEMIs require minimum initial capital of £350,000. SEMIs have no capital requirement but face issuance limits. All EMIs must safeguard customer funds, implement comprehensive AML programmes, and maintain fit and proper directors.
Application Process
The FCA application takes 6 to 12 months for an AEMI and 3 to 6 months for a SEMI.
Why United Kingdom?
A UK EMI licence provides access to one of the world's most mature digital payments markets. The FCA's authorisation carries significant credibility with banking partners and customers globally.
Full United Kingdom guide →Lithuania — Electronic Money Institution Licence
Overview
Lithuania is the leading EU jurisdiction for EMI licensing. The Bank of Lithuania has authorised more EMIs than almost any other EU regulator.
Key Requirements
€350,000 initial capital. Local directors, registered office, and compliance function required. Comprehensive AML framework must be implemented before authorisation.
Application Process
The Bank of Lithuania typically processes EMI applications in 3 to 6 months, one of the fastest timelines in the EU.
Why Lithuania?
Lithuania offers the optimal combination of speed, cost, and market access for EMI licensing in Europe. Full EU passporting enables continent-wide operations from a single licence.
Full Lithuania guide →Ireland — Electronic Money Institution Licence
Overview
Ireland is a premium EU jurisdiction for EMI licensing, particularly popular with firms seeking a combination of EU passporting and a common law legal framework.
Key Requirements
€350,000 initial capital. Significant local substance required. The Central Bank of Ireland has high standards for governance, compliance, and AML documentation.
Application Process
Applications typically take 6 to 12 months. The Central Bank conducts a thorough and detailed review process.
Why Ireland?
Ireland's combination of EU membership, English language, common law, and deep financial services expertise makes it a top-tier choice for EMI licensing.
Full Ireland guide →Netherlands — Electronic Money Institution Licence
Overview
The Netherlands offers EMI licensing through De Nederlandsche Bank, providing access to a world-class financial services ecosystem and full EU passporting.
Key Requirements
€350,000 capital. Local substance, comprehensive governance, and detailed AML frameworks required.
Application Process
6 to 12 months. DNB is thorough but fair in its assessment approach.
Why Netherlands?
Central European location, excellent financial infrastructure, and a sophisticated payments market.
Full Netherlands guide →Malta — Electronic Money Institution Licence
Overview
Malta provides EMI licensing through the MFSA with full EU passporting rights and a practical, engagement-focused regulatory approach.
Key Requirements
€350,000 initial capital. Local substance required. Standard EU AML/governance requirements.
Application Process
4 to 8 months typical timeline. The MFSA provides constructive engagement throughout.
Why Malta?
Malta combines EU access with competitive costs, English language, and a regulator experienced in fintech.
Full Malta guide →Luxembourg — Electronic Money Institution Licence
Overview
Luxembourg's CSSF regulates EMIs under the EMD2 framework. Luxembourg is one of Europe's most established financial centres with deep expertise in payment services and fund administration.
Key Requirements
€350,000 initial capital. Comprehensive governance, compliance, and AML documentation. Local directors and office required.
Application Process
6 to 12 months. The CSSF maintains high application standards.
Why Luxembourg?
Luxembourg offers a globally recognised financial services brand, multilingual business environment, and proximity to EU institutions.
Full Luxembourg guide →Germany — Electronic Money Institution Licence
Overview
BaFin regulates EMIs in Germany. As the EU's largest economy, Germany provides access to a significant consumer market and well-developed payments infrastructure.
Key Requirements
€350,000 capital. Robust governance and AML frameworks. German-language documentation may be required. Local substance mandatory.
Application Process
6 to 12 months. BaFin is systematic and thorough.
Why Germany?
Germany provides access to Europe's largest consumer market and a mature banking infrastructure. Frankfurt is a major European financial centre.
Full Germany guide →France — Electronic Money Institution Licence
Overview
The ACPR regulates EMIs in France. France has a growing fintech ecosystem and strong domestic demand for digital payment solutions.
Key Requirements
€350,000 capital. French-language documentation typically required. Comprehensive governance and AML arrangements expected.
Application Process
6 to 12 months. The ACPR applies rigorous standards.
Why France?
France offers a large domestic market, active regulatory support for fintech innovation, and strong connections to francophone African markets.
Full France guide →Spain — Electronic Money Institution Licence
Overview
The Bank of Spain regulates EMIs under the EMD2 framework. Spain's linguistic and cultural ties to Latin America make it a strategic base for firms with dual-hemisphere ambitions.
Key Requirements
€350,000 capital. Local substance required. Comprehensive documentation in Spanish expected.
Application Process
6 to 12 months.
Why Spain?
Spain combines EU market access with strong Latin American commercial links, making it attractive for firms targeting both European and Latin American e-money markets.
Full Spain guide →Cyprus — Electronic Money Institution Licence
Overview
The Central Bank of Cyprus regulates EMIs. Cyprus has become an increasingly popular jurisdiction for fintech licensing with competitive costs and an English-speaking business environment.
Key Requirements
€350,000 capital. Local substance including directors. AML frameworks must comply with EU directives.
Application Process
4 to 9 months. The CBC has developed significant EMI licensing experience.
Why Cyprus?
Cyprus offers EU passporting with competitive operating costs, a favourable tax environment, and an English-speaking business community.
Full Cyprus guide →Belgium — Electronic Money Institution Licence
Overview
The National Bank of Belgium regulates EMIs. Belgium's position as host to EU institutions provides unique proximity to European policymakers.
Key Requirements
€350,000 capital. Comprehensive governance and AML documentation. Local substance expected.
Application Process
6 to 12 months.
Why Belgium?
Belgium offers central European location, proximity to EU institutions, and a well-developed financial infrastructure.
Full Belgium guide →United Arab Emirates — Electronic Money Institution Licence
Overview
The CBUAE regulates stored value facilities (SVFs) including electronic money issuance. The UAE is a rapidly growing market for digital payment products.
Key Requirements
Minimum capital starts at AED 5 million for SVF licences. Local incorporation, governance, AML frameworks, and technology risk management required.
Application Process
6 to 12 months depending on the scope of SVF activities.
Why United Arab Emirates?
The UAE provides access to a high-growth digital payments market and serves as a gateway to Middle Eastern, North African, and South Asian markets.
Full United Arab Emirates guide →Singapore — Electronic Money Institution Licence
Overview
MAS regulates e-money issuance under the Payment Services Act 2019. A Major Payment Institution licence covering e-money issuance is required above certain thresholds.
Key Requirements
SGD 250,000 minimum capital. Comprehensive AML/CFT frameworks, technology risk management, and governance arrangements required. Local directors mandatory.
Application Process
6 to 12 months. MAS is thorough in its assessment.
Why Singapore?
Singapore is the premier financial centre in Asia-Pacific with a globally respected regulatory framework and access to fast-growing Asian digital payments markets.
Full Singapore guide →Canada — Electronic Money Institution Licence
Overview
Canada's FINTRAC registration covers e-money related activities. Provincial regulations may also apply depending on the specific activities undertaken.
Key Requirements
No minimum capital requirement for federal registration. AML/CFT compliance programme required. Provincial requirements may apply.
Application Process
6 to 8 weeks for federal registration.
Why Canada?
Canada offers fast registration, a growing digital payments market, and proximity to the United States.
Full Canada guide →Czech Republic — Electronic Money Institution Licence
Overview
The Czech National Bank regulates EMIs under the EMD2 framework. The Czech Republic offers a cost-effective EU base with full passporting.
Key Requirements
€350,000 capital. Local substance required. Comprehensive AML and governance documentation expected.
Application Process
4 to 8 months.
Why Czech Republic?
The Czech Republic offers EU passporting with lower operating costs than Western European jurisdictions and a growing technology sector.
Full Czech Republic guide →Supporting Services for Electronic Money Institution Firms
"The team's expertise in EMI regulation was immediately apparent. They guided us through the Lithuanian application process and we were authorised ahead of schedule."
Founder, Digital Payments Startup
"We needed both UK and EU EMI licences. Regulatory Counsel managed both applications in parallel and delivered an outstanding result."
COO, Multi-Currency Wallet Provider
Related Insights
FCA Electronic Money Institution Authorisation: What You Need to Know
Complete guide to FCA EMI authorisation — AEMI vs SEMI thresholds, capital requirements, safeguarding, business plan expectations and common application failures.
EMI Safeguarding Requirements Under PS25/12: What Has Changed
PS25/12 introduces the most significant overhaul of EMI safeguarding since PSD2 — statutory trust, daily reconciliation, annual audit and enhanced governance.
EMI vs Payment Institution Licence: Which Does Your Business Need?
Understanding the fundamental legal and commercial differences between EMI and payment institution authorisation — and how to determine which your business requires.
Frequently Asked Questions
A payment institution can provide payment services but cannot issue electronic money. An EMI can do both — provide payment services and issue e-money. E-money issuance means the firm accepts funds from customers and issues a digital store of value in return, such as a digital wallet balance or prepaid card. EMIs face higher capital requirements (€350,000 vs €20,000–€125,000) due to the additional risks of holding customer funds as e-money.
A Small EMI (SEMI) in the UK is a simplified category for firms with average outstanding e-money below €5 million. SEMIs have no minimum capital requirement and a simpler application process, but they cannot passport and face transaction volume limitations.
Full EMI authorisation requires €350,000 (or £350,000 in the UK) minimum initial capital. This must be maintained at all times and cannot be used for operational purposes. Additionally, EMIs must hold ongoing own funds calculated based on average outstanding e-money.
Yes, issuing prepaid cards is one of the core activities permitted under an EMI licence. The prepaid card is a payment instrument that stores electronic money, and issuing it requires EMI authorisation.
EMIs must safeguard 100% of outstanding e-money at all times. This means all funds received in exchange for e-money must be deposited in a segregated account at a credit institution or covered by an insurance policy. The FCA PS25/12 reforms introduce enhanced safeguarding requirements from 7 May 2026.
Timelines vary by jurisdiction. Lithuania is typically fastest at 3 to 6 months. Malta takes 4 to 8 months. The UK and Ireland typically take 6 to 12 months. These timelines assume a well-prepared, complete application.
Most jurisdictions require meaningful local substance. This typically includes at least one locally resident director, a compliance officer, a registered office, and in some cases additional operational staff.