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Licence guide

Cyprus electronic money institution licence.

An English-speaking, common-law EU base for e-money issuers that want one authorisation passported across the EU and EEA, with the owners assessed at a pre-application stage before the formal file.

Published 16 October 2026 · Last reviewed 17 October 2026 · Reviewed against the regulator’s current publications
Central Bank (CBC)Regulator
€350,000Initial capital
€10,000Application fee
6 to 8 monthsOur realistic timeline
EU and EEAPassporting

Firms we have licensed.

Selected engagements from more than 250 licences obtained since 2013, for payment, e-money, cryptoasset and consumer credit firms.

Since 2013Advising global payment firms
60+Countries licensed in
250+Licences obtained globally
Clients
ClearBankVolkswagenStaysureOval MoneyEMQCentus
nexpayPayment Institution

Obtained Nexpay’s FCA Authorised Payment Institution licence.

dzingElectronic Money Institution

Obtained Dzing Finance’s FCA Authorised Electronic Money Institution licence.

Payment Institution

Obtained Orbital’s FCA Authorised Payment Institution licence.

What you get

6 to 8 monthsLicence granted

Our realistic timeline from submission, set against the regulator’s own published figures.

Day oneReady to trade

Safeguarding, operating and settlement accounts opened alongside the application, so you trade on authorisation.

Your teamKey people in place

Candidates introduced for independent directors and senior managers, each assessed against the regulator’s standard.

Same dayWritten proposal

A reply within three business hours and a written proposal the same day: the licence, the requirements, the cost and the timing.

How the firm obtains the licence

  1. Scoping and proposal. The capital method, the fees and the beneficial owners’ file are confirmed in writing, and the Pre-Application Document is prepared for the Central Bank’s preliminary assessment within 30 working days, or 50 with an enhanced due diligence report.
  2. Application pack. The application form, the personal questionnaires and time commitment tables, the programme of operations, the three-year business plan and the risk policies written for the business under the EBA guidelines for the Central Bank’s e-platform.
  3. Banking. The safeguarding account with a credit institution and the operating accounts are arranged through the firm’s relationships before the decision, so the account evidence is in the file the Central Bank reviews.
  4. Regulator engagement. Central Bank requests are answered by each deadline through one process with the evidence assembled, so the application stays active, until the decision within three months of a complete application.

Key people, banking and technology

You will need a board with enough independent directors, and senior managers in the key roles, each assessed by the Central Bank under its 2025 suitability rules.

Key peopleThe firm introduces candidates for independent directors and senior managers from its register of senior compliance, financial crime, risk and finance professionals, and assesses each against the regulator’s approval standard before they are put forward.
BankingSafeguarding, operating and settlement accounts, card acquiring and payment processing, arranged through the institutions that serve regulated firms, in parallel with the application.
TechnologyBespoke white-label technology for accounts, payments, wallets and card programmes, built and ready to go live with the licence.

One engagement and one timetable, from scoping to launch. Speak to an expert about the people, the banking and the technology for this licence.

The licence in detail

The regulator’s requirements, capital, timing, fees and the questions firms ask, from the regulator’s own publications.

Key takeaways
  • A Cyprus EMI issues e-money and provides every payment service across the EU and EEA on one authorisation under the Electronic Money Laws of 2012 and 2018.
  • Initial capital is €350,000 and own funds may never fall below it; ongoing own funds add the e-money and payment services calculations under the Central Bank’s directive.
  • From 3 August 2026 every application starts with a mandatory pre-application stage: a €5,000 fee and a preliminary assessment within 30 working days, or 50 where an enhanced due diligence report is commissioned.
  • The application fee is €10,000; the Central Bank publishes no annual supervisory fee.
  • The statutory period is three months from a complete application; the firm plans for six to eight months after submission.
  • The company must be incorporated in Cyprus with its registered and head office there and part of the business carried out in Cyprus; every board member and key function holder is assessed under the 2025 suitability directive.

Who needs the licence

A business issuing stored value to customers in Cyprus or, through passporting, anywhere in the EU and EEA needs authorisation from the Central Bank of Cyprus. Cyprus is a common-law, English-speaking EU jurisdiction with an established payments and investment firm sector, and since August 2026 its licensing process begins with a preliminary assessment of the owners and the project before the formal application. An EMI may provide every payment service in the Payment Services Law under the same authorisation.

What the Central Bank of Cyprus requires

  • Legal form and location. A legal person incorporated in Cyprus with its registered office and head office in Cyprus, carrying out at least part of its e-money or payment business in Cyprus.
  • Pre-application stage. From 3 August 2026 every applicant first pays a non-refundable €5,000 fee and submits a Pre-Application Document to the Licensing Section. The Central Bank of Cyprus completes its preliminary assessment within 30 working days, or 50 working days where it commissions an enhanced due diligence report on the beneficial owners at the applicant’s cost, and then meets the beneficial owners. Completion of the stage is not an approval.
  • Governance and suitability. Each proposed member of the management body and each key function holder completes the Central Bank’s personal questionnaire (October 2024 version) and a time commitment table, and is assessed under the 2025 suitability directive; major shareholders (10% or more) complete the legal person or natural person questionnaire. The Central Bank looks for an adequate number of independent board members and for internal organisation under its 2026 governance directive.
  • Safeguarding. Funds received for e-money and for payment transactions are kept separate and placed in a separate account with a credit institution or in secure, liquid, low-risk assets under the Central Bank’s 2026 directive, or covered by an insurance policy or comparable guarantee from an unaffiliated insurer or credit institution; safeguarded funds rank ahead of other creditors.
  • Application pack. The application form (May 2024 version), the €10,000 fee receipt, the questionnaires and the documents listed in the EBA guidelines on authorisation (EBA/GL/2017/09), which the Central Bank has adopted in full: programme of operations, business plan with three-year projections, group structure, governance, risk policies written for the business, outsourcing, security, anti-money laundering and the own funds calculation, submitted through the Central Bank’s e-platform. An applicant that misses a Central Bank deadline receives notice that the application will be classified as withdrawn.
  • Capital. Initial capital of €350,000 at authorisation; own funds thereafter at least the sum of the e-money calculation on e-money in circulation and the payment services calculation for unrelated payment services, under the method the Central Bank sets by directive, and never below €350,000.

Capital

RequirementAmount
Initial capital€350,000
Ongoing own fundsE-money calculation plus payment services calculation; never below €350,000
E-money elementSet by Central Bank directive; the EU floor is 2% of average outstanding e-money
Unrelated payment servicesMethod A, B or C as the Central Bank directs

The Electronic Money Laws permit a directive for issuers below an average outstanding limit, but the Central Bank publishes no small EMI regime; every issuer holds the full authorisation.

Timing

FigureValueSource
Statutory decision period3 months from a complete applicationPayment Services Law, section 12, applied to EMIs by section 4A of the Electronic Money Laws
Regulator’s published figurePreliminary assessment within 30 working days of the Pre-Application Document, or 50 working days with an enhanced due diligence report, about 1.5 to 2.5 months, before the formal applicationCentral Bank of Cyprus, pre-application exploratory stage
Application preparation6 to 8 weeksFrom instruction to submission, including banking in parallel
Our realistic timeline6 to 8 months after submissionThe firm’s own figure, from the regulator’s published data and its own applications

Figures published by the regulator are quoted as published and converted to months. The realistic timeline is the firm’s own, for a complete, well-prepared application.

Fees and costs

ItemAmountNotes
Pre-application fee€5,000Non-refundable; paid before the Pre-Application Document is submitted
Application fee€10,000Receipt attached to the application
Enhanced due diligence reportAt costWhere the Central Bank commissions a third-party report on the beneficial owners
Annual supervisory feeNot publishedThe law allows the Central Bank to charge its supervision expenses; no amount is published
Initial capital€350,000Held before authorisation
Professional feesFixed, in writingQuoted after scoping

Passporting and scope

A Cyprus EMI passports throughout the EU and EEA under the right of establishment and the freedom to provide services, by branch, agent or distributor, with notifications under Delegated Regulation (EU) 2017/2055. The Central Bank publishes a register of authorised EMIs with their branches, agents, distributors and passported states.

Why applications are delayed

The Central Bank of Cyprus publishes the errors it sees most often in applications, and in 2026 introduced the pre-application stage to settle questions of good repute before the formal file is submitted.

  1. Incomplete information on the people. Unanswered questionnaire items, the wrong questionnaire, incomplete management body information, an inadequate number of independent board members and insufficient evidence of the source of the investment funds.
  2. Generic documents. Risk policies taken from templates, a thin programme of operations and business plan, thin outsourcing detail, and information that conflicts between documents.
  3. Financials. Unsupported or optimistic projections and a missing own funds calculation. The Central Bank may not take financial need into account; suitability of the board and management is a mandatory ground of decision.

Banking

An EMI needs a safeguarding account that satisfies the regulator’s requirements, an operating account and settlement accounts in the currencies it serves. The firm arranges each through institutions that serve regulated firms in Cyprus and across the EU, during the application, so the firm trades on authorisation. See banking and payment processing.

Questions firms ask

How long does a Cyprus EMI licence take?

Three months from a complete application by statute, after the pre-application stage of 30 or 50 working days. The firm plans for six to eight months after submission.

What is the pre-application stage?

A mandatory first step since 3 August 2026: a €5,000 fee, a Pre-Application Document, a preliminary assessment by the Central Bank within 30 working days (50 with an enhanced due diligence report) and a meeting with the beneficial owners. It settles questions of good repute before the formal application.

What does a Cyprus EMI licence cost?

€5,000 at pre-application and €10,000 on application, plus the cost of any due diligence report the Central Bank commissions. The Central Bank publishes no annual supervisory fee.

Is there a small EMI regime in Cyprus?

No. The law permits one by directive but the Central Bank publishes none; every issuer holds the full authorisation.

Who must be in Cyprus?

The company is incorporated in Cyprus with its registered and head office there and carries out at least part of its business in Cyprus. Every board member and key function holder is assessed for suitability, and the Central Bank looks for an adequate number of independent directors.

References

  1. Central Bank of Cyprus: EMI application submission and assessment
  2. Electronic Money Laws of 2012 and 2018, consolidated English text
  3. Central Bank of Cyprus: common errors observed in EMI applications
  4. Central Bank of Cyprus: pre-application exploratory stage
  5. Central Bank of Cyprus: new licensing process, announcement of 31 July 2026
  6. Payment Services Laws of 2018 to 2023, consolidated English text

About Buckingham Capital Consulting

A regulatory advisory firm to payment, e-money and cryptoasset companies since 2013, with more than 250 licences obtained in more than 60 countries. The firm advises on authorisation, compliance, safeguarding, banking and transactions, and builds the white-label payment and card technology its clients launch on.

A written proposal on cost, timing and requirements, the same day: speak to an expert.

This guide is general information for firms considering authorisation and is reviewed against the regulator’s published requirements. It is not legal advice; requirements and fees change, and the regulator’s current publications take precedence.

How we work.

  • Senior-ledEvery engagement is led by the practitioners who prepare the application and attend the regulator.
  • Same dayA reply within three business hours and a written proposal the same day: the licence, the requirements, the cost and the timing, before you commit.
  • ConfidentialYour plans, your application and any listing stay private. Clients are named only with their agreement.
  • Live workspaceEvery engagement runs in a shared workspace on Hector: documents, regulator questions, messages and progress in one place, visible to your team at every stage.

Why firms choose BCC.

  • OperatorsWe have taken firms through licensing, run regulated payments and consumer credit businesses, and signed the regulatory returns ourselves.
  • BankingSafeguarding, operating and settlement accounts arranged alongside the authorisation, through the institutions that serve this market.
  • FoundersThe firm is run by founders who have built and run regulated payments businesses, so every position is given with the launch date and the cost of waiting in mind.
  • One firmLicensing, key people, banking, compliance, technology and transactions from the same team, for the life of the regulated firm.

Apply for this licence.

The requirements, the cost and the timing for your business, in a written proposal the same day.