How to Get an EMI Licence in the EU in 2026

At a glance

1. An electronic money institution (EMI) licence is for a business that issues electronic money: stored monetary value issued against funds and accepted by someone other than the issuer. A payment institution (PI) licence may fit a product that moves money without issuing it. [1]

2. A fully licensed EU EMI needs at least EUR 350,000 in initial capital. Ongoing own funds can be higher; the electronic-money calculation is generally 2% of average outstanding e-money, alongside any applicable payment-service calculation. [1]

3. The application must show how the real product will safeguard customer funds, redeem e-money, manage financial-crime and ICT risks, and operate with credible people and controls. [1, 2, 3]

4. The often-quoted three-month decision period starts with a complete application. The EBA's 2025 peer review found a 9.5-month median from submission across the EEA sample of PI and EMI applications, excluding one outlier state. [2, 4]

5. An EMI authorised in one member state can access other EU markets through the applicable notification procedure. A national small-EMI exemption is a different route and does not carry the same passport. [1, 2]

Founders often search for the “best country for an EMI licence” before deciding what their app actually does with customer money. That reverses the useful order. The product flow determines whether an EMI licence is needed, which services to apply for, how much capital must be available, and which banking and safeguarding partners can support the model.

This guide follows the decisions in the order a serious applicant should make them. It covers the EU-wide framework under the Electronic Money Directive (EMD2) and the revised Payment Services Directive (PSD2). National implementation and supervisory expectations still matter. [1, 2]

1. Decide whether the product issues electronic money

Under EMD2, electronic money is electronically stored monetary value representing a claim on its issuer. It is issued on receipt of funds for payment transactions and accepted by a person other than the issuer. The test is about the legal and operational product, not whether the interface calls the balance a “wallet”. [1]

Map who receives the customer's funds, what claim the customer receives, where the value is stored, who accepts it, and how the customer gets it back. Then map any separate payment services. A PI may be enough for a pure payment service that does not issue e-money. If the business holds deposits as a bank, neither label by itself solves the banking-authorisation question. [1, 2]

This table is a screening tool, not a licensing conclusion. A product can combine e-money issuance, payment services, distribution, agents and outsourcing. For stablecoins, an EMI licence alone is not a complete MiCA plan. See our guide to stablecoins and EMI authorisation. [1, 2, 8]

2. Choose a home state where the business can really operate

The home member state is where the institution seeks authorisation and faces ongoing supervision. Its authority will examine ownership, management, financial forecasts, safeguarding, financial-crime controls, technology and outsourcing. The EBA's common guidelines describe the information expected, but the filing process, fees and supervisory interaction are national. [2, 3]

Compare jurisdictions against the planned operating model: where decision-makers and control staff will work, where customer funds can be safeguarded, where a workable account and payment infrastructure can be obtained, and how the regulator handles the proposed business. A low application fee has little value if the safeguarding bank or key managers cannot support the licence file.

For a concrete national example, Latvijas Banka describes a licensed EMI application with a EUR 350,000 initial-capital requirement, a completeness check and a substantive assessment. Those procedural details are Latvia-specific. Our Latvia licensing guide looks at that route in more detail. [5]

3. Build a capital plan beyond the EUR 350,000 headline

EMD2 Article 4 sets the initial-capital floor for a fully licensed EMI at EUR 350,000. Article 5 requires ongoing own funds at least equal to the higher of that floor and the calculated ongoing requirement. For issuance of electronic money, Method D is at least 2% of average outstanding e-money. Unrelated payment services may create an additional own-funds calculation. Supervisors also have specified discretion to adjust requirements. [1]

For a simplified illustration, EUR 30 million in average outstanding e-money gives a 2% figure of EUR 600,000. That exceeds the EUR 350,000 initial floor before any other applicable payment-service requirement or supervisory adjustment. An applicant forecasting growth should model when its ongoing requirement overtakes the floor, not assume it can raise the difference later. [1]

The business plan should show the source and quality of capital, three-year forecasts, loss absorption and the timing of future funding. A large cash balance in a presentation is not a substitute for evidence that the applicant meets the required capital rules. [2, 3]

4. Design safeguarding, redemption and banking before the application

Customer money received in exchange for e-money is not working capital. EMD2 Article 7 requires safeguarding, using the applicable segregation or insurance/guarantee methods. The application needs an auditable account and reconciliation model that shows when customer funds arrive, where they are held, when e-money is issued and how the protected amount is calculated. [1, 2]

EMD2 Article 11 also requires issuance and redemption at par value, subject to the directive's rules on contract terms and permitted fees. The product, ledger and partner arrangements should all support that obligation. “We will arrange a safeguarding bank after the licence” leaves a material gap in both the application and the eventual operation. [1, 3]

Ask prospective banking and safeguarding partners about permitted customer segments, currencies, geographies, settlement flows, reconciliation data and incident handling before finalising the licence scope. A partner's risk appetite can change the feasible product. Our bank-account rejection guide explains why regulated firms still struggle to obtain the accounts their models require.

5. Assemble the application around the live operating model

PSD2 Article 5 and the EBA authorisation guidelines require more than a business-plan narrative. The file should connect the programme of operations to the customer journey, money flow, responsible people, contracts, policies and systems. Each answer should describe a product the firm can actually launch. [2, 3]

DORA has applied since 17 January 2025 and adds EU-wide digital operational resilience requirements for in-scope financial entities, including most EMIs. Build ICT risk management and third-party oversight into the operating model rather than attaching a generic policy at the end. [6]

A practical pre-filing review should walk one real transaction from onboarding through funding, issuing e-money, spending, safeguarding, reconciliation, redemption, complaints and a failed-payment scenario. If the documents give different answers about where money sits or who performs a control, resolve that before submission.

6. Plan for the real authorisation timeline

PSD2 provides a decision period of three months after the authority receives a complete application or all information required for the decision. It does not promise a licence three months after the first upload. Authorities can request missing or corrected information; the preparation and completeness stages can be substantial. [2]

The EBA's December 2025 follow-up peer review found that the median process from submission was 9.5 months for payment and electronic money institutions in its EEA sample, excluding one outlier member state. The EBA identified incomplete or poor-quality applications as a recurring cause of delay. This is historical aggregate evidence, not a forecast for a particular country or applicant. [4]

As one national illustration, Latvijas Banka says it checks completeness within 15 working days, then has three months for the substantive assessment of a complete EMI application, with possible extension when further information is needed. Those are its published steps, not a uniform EU intake timetable. [5]

Work backward from the intended launch: finish the licence perimeter and partner feasibility first, then build the application, allow time for regulator questions, and schedule technology and commercial commitments around a realistic range rather than a promised approval date.

7. Separate the full EMI licence from the small-EMI and passport routes

EMD2 permits member states to offer a small-EMI exemption within the directive's conditions. Availability and thresholds depend on national implementation; the directive sets an upper limit tied to average outstanding e-money. The exemption is a domestic route with restrictions, not a shortcut to the full EU passport. [1]

A fully authorised EMI can operate in other member states through the PSD2 cross-border notification framework applied to EMIs. The home authority and host-state information process still matter. Do not assume that receiving a licence on Monday makes every product and distribution channel available across the EU on Tuesday. [1, 2]

If the roadmap includes crypto-assets or an e-money token, map the MiCA permissions separately. A licence to issue ordinary e-money does not answer every token, custody or crypto-service question. Our EMI vs CASP comparison helps separate those activities. [7]

EMI licence readiness checklist

Before committing to an application, the founding team should be able to answer these questions in one consistent operating model:

1. What regulated service does each customer-facing feature perform, and why is an EMI licence the correct route?
2. Who is the legal issuer, where is it managed, and which people will run the control functions?
3. What are the projected outstanding e-money balance, required own funds and operating runway?
4. Where are customer funds safeguarded, how are they reconciled, and how is redemption funded?
5. Which bank, processor and technology providers have reviewed the actual flows?
6. Can the application documents describe the same live product, contracts and responsibilities?
7. Which countries will be served at launch, and what notifications or extra permissions are needed?

Frequently asked questions

How much does an EMI licence cost in the EU?

EUR 350,000 is the EU initial-capital floor for a fully licensed EMI, not the total cost. National filing fees, staff, legal work, compliance, technology, assurance, banking and runway vary. Ongoing own funds can exceed the initial floor as outstanding e-money grows. [1, 5]

How long does it take to get an EMI licence?

The legal decision period is tied to a complete file, while preparation and completeness reviews add time. The EBA reported a 9.5-month median from submission in its 2025 EEA peer-review sample of PI and EMI applications, excluding one outlier member state. Individual applications can be faster or slower. [2, 4]

Can an EMI issue IBANs?

An EMI licence alone does not make the company a bank or guarantee access to a particular account-number scheme. Customer-facing account identifiers depend on the actual payment services, payment-system access and partner infrastructure. Check the proposed “IBAN” journey against the licence scope and contracts before marketing it. [1, 2]

Can an EMI provide payment services?

Yes. EMD2 permits EMIs to provide payment services, subject to the relevant rules. The application must identify those services, and unrelated payment activity may affect the own-funds calculation. [1]

Can a small EMI passport across the EU?

No standard full-EMI passport follows from the small-EMI exemption. A founder planning cross-border scale should compare the domestic exemption with full authorisation before building around it. [1]

Does an EMI licence allow a company to issue a stablecoin?

An e-money token issuer under MiCA must be an authorised credit institution or EMI, but MiCA adds token-specific obligations. The EMI licence is a necessary route for some models, not the entire launch checklist. [7]

Related DM Strategy guides

• EMI vs CASP: Which Licence Do You Need? — separate payments and crypto permissions.
• Latvia EMI and CASP Licensing Guide — examine a specific home-state route.
• Why Crypto and Payment Businesses Get Rejected by Banks — prepare the banking file.
• Stablecoins Under MiCA — understand the e-money-token overlap.

Key primary sources

Disclaimer

This article is for information only and is not legal or regulatory advice. The required permissions and prudential calculations depend on the actual product, activities and home member state. Check current law and national supervisory requirements before applying.

DM Strategy works with founders on the licence perimeter, jurisdiction, capital plan and banking arrangements behind payment products. If you are preparing an EU EMI application, contact DM Strategy to map the operating model before committing to a filing.