Full EU passporting under PSD2

EMI license in Latvia

Latvia is one of the fastest and most cost-effective gateways into Europe's payments ecosystem, with full passporting across 27 EU member states and 3 EFTA countries under PSD2.

What this enables

Fiat

Fiat payment activities

Issue e-money and multi-currency wallets
Open IBAN payment accounts for clients
Issue branded debit and prepaid cards
Acquire card payments for merchants
Facilitate international money remittance
Provide open banking services (PIS and AIS)
Offer white-label banking-as-a-service

CASP

Crypto activities — available via CASP registration (add-on)

Crypto custody and wallet services
Exchange between crypto assets
Exchange between crypto and fiat
Token issuance

Whis this is for

This structure is suited to:

Payment institutions seeking EU market access without establishing in a high-cost jurisdiction

Crypto businesses that want to combine fiat and digital asset operations under one regulatory framework

Fintech companies building e-money, card, or remittance products

Companies that need EU passporting to serve clients across multiple member states

Who this is for

This is not the right fit if:

Capital Commitment

You are not prepared to commit the required share capital (€350,000 for EMI)

Crypto-Only Models

Your primary model is crypto-only and does not require fiat payment services — a standalone CASP registration may be more appropriate

Banking Expectations

You need operational banking in place before the license is granted

Registration process

01

Corporate setup
Latvian entity incorporated, office premises sourced, shareholders and UBO due diligence completed, board and MLRO identified.
Your responsibility: provide corporate documentation, ownership structure, and business plan inputs.
Compliance documentation
Full regulatory package prepared: business plan, AML/CTF framework, safeguarding policies, cybersecurity and data protection documentation.
Your responsibility: review and approve documentation, confirm operational model details.

02

03

Compliance staffing
MLRO and compliance specialists sourced. Software and infrastructure introductions arranged where needed.
Your responsibility: interview and confirm key compliance hires.
Application and Bank of Latvia interaction
Full application submitted. DM Strategy manages all communication and requests throughout the review period.
Your responsibility: availability for regulatory queries.

04

Total timeline: confirmed at the preliminary assessment, subject to case complexity and Bank of Latvia review period.
What is included

Included in scope

Shareholder and UBO due diligence and business outline preparation
Latvian entity incorporation
Office premises sourcing
Bank account opening assistance
Compliance documentation: business plan, AML/CTF framework, safeguarding, cybersecurity and data protection
MLRO and compliance staff sourcing (salaries not included)
Software and infrastructure introductions
Bank of Latvia application preparation and submission
Ongoing communication with the Bank of Latvia throughout the review process
All legal fees within scope

Not included

Share capital, state application and annual supervision fees, staff salaries, third-party software costs.

Optional add-on

CASP registration can be structured alongside the EMI application for businesses that also require crypto asset services.

Costs and regulatory requirements  

EMI License

Item
Amount / detail
Share capital
€350,000 — retained within the licensed entity, not a fee payable to DM Strategy
Application fee
€5,000 (Bank of Latvia)
Annual supervision fee
€7,000 plus up to 1.4% of gross EMI income, capped at €100,000 per year

CASP add-on (if applicable)

Item
Amount / detail
Share capital
€50,000 (Class I) · €125,000 (Class II) · €150,000 (Class III)
Application fee
€2,500
Annual supervision fee
Minimum €3,000 plus up to 0.6% of gross crypto revenue
Common queries

Frequently asked questions

Can I combine the EMI and CASP registrations?

Yes. Latvia's regulatory framework allows a single entity to hold both. The applications can be structured and submitted concurrently, which is the more efficient path for businesses operating at the intersection of fiat payment services and crypto asset services.

Does the license give me access to all EU member states immediately?

The EMI license provides full passporting rights under PSD2 across 27 EU member states and 3 EFTA countries. Passporting requires notification to the relevant host country regulators. DM Strategy handles this as part of the engagement.

What is the minimum share capital required?

The EMI license requires €350,000 in share capital. For a CASP add-on, the requirement depends on the class: €50,000 for Class I, €125,000 for Class II, and €150,000 for Class III. Share capital is retained within the licensed entity.

Do I need to be physically present in Latvia?

A registered office and local compliance presence are required by the regulator. DM Strategy assists with both. Permanent physical presence of the founding team is not required.

What are the ongoing obligations after the license is granted?

Annual supervision fees, AML/CTF reporting, and ongoing compliance with Bank of Latvia requirements. DM Strategy can provide post-licensing compliance support as a separate engagement.

Understand your regulatory path before starting

The initial call covers your business model, licensing objectives, and whether the EMI structure is the right path before you commit to the engagement.

Get in Touch
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