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Licence guide

France electronic money institution licence.

France gives e-money issuers the EU’s second-largest payments market and a regulator that commits to response times at each stage, with a simplified route for smaller issuers.

Published 16 October 2026 · Last reviewed 17 October 2026 · Reviewed against the regulator’s current publications
ACPRRegulator
€350,000Initial capital
NoneApplication 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 two managing directors based in France, 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 route, full or simplified, and the own funds are confirmed in a written proposal the same day, and the mandatory project presentation meeting with the ACPR’s authorisations directorate is requested, which the ACPR holds within two weeks.
  2. Application pack. The file in the format of the ACPR’s instruction: business plan, three-year projections with target and stressed scenarios and their formulas, the draft safeguarding agreement, internal control and the manager files, filed on the ACPR portal.
  3. Banking. The dedicated demand account for cantonnement and the operating accounts are arranged through the firm’s relationships before the decision, on account terms and transfer timing that meet the ACPR’s safeguarding points of attention.
  4. Regulator engagement. The ACPR’s clarification requests, issued within three weeks of filing, are answered through one process, and the Banque de France’s payment security opinion is supported, until the college decision and the lifting of conditions precedent.

Key people, banking and technology

You will need at least two managing directors running the business from France, with the key control roles held by your own staff rather than outsourced.

Key peopleThe firm introduces candidates for two managing directors based in France 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 French EMI issues e-money and provides payment services across the EU and EEA on one authorisation from the ACPR, backed by the Banque de France.
  • Initial capital is €350,000; own funds are 2% of average outstanding e-money.
  • There is no application fee; an annual supervision contribution applies.
  • Three months from a complete file by statute; the ACPR commits to stage-level response times under its Fintech Charter.
  • Effective management by at least two persons in France, with the central administration in France.
  • A simplified authorisation with €100,000 capital exists below €5 million of average monthly outstanding e-money, without passporting.

Who needs the licence

A business issuing stored value in France or, through passporting, across the EU and EEA needs ACPR authorisation. France is the EU’s second-largest payments market and the ACPR publishes its procedure, its points of attention and stage-level service commitments. An EMI may provide every payment service under the same authorisation.

What the ACPR requires

  • Legal form and location. A company whose central administration is in the same territory as its registered office, with effective management exercised in France by at least two persons and key functions held internally; responsibility stays in France whatever is outsourced.
  • Governance. At least two effective managers meeting the tests of honourability, knowledge, experience and competence; a documented allocation of responsibilities; risk management, internal control and an AML framework; an opinion from the Banque de France on payment security before authorisation.
  • Safeguarding. Segregation on a dedicated demand account, or an insurance contract or comparable guarantee; funds remaining at the end of the next business day moved to the dedicated account; daily safeguarding, including weekends, where instant transfers are offered; the draft safeguarding agreement in the file.
  • Application pack. A mandatory project presentation meeting with the ACPR’s authorisations directorate, then the file on the ACPR portal in the format of the ACPR’s instruction: business plan, three-year projections with target and stressed scenarios, programme of operations, governance, internal control, AML, IT and security, and the manager files.
  • Capital. Initial capital of €350,000 and own funds thereafter of 2% of average outstanding e-money; €100,000 under the simplified regime.

Capital

RequirementAmount
Initial capital€350,000
Ongoing own funds (Method D)2% of average outstanding e-money
Simplified authorisation€100,000; average monthly outstanding e-money not above €5 million

Institutions below €5 million of outstanding e-money file a reduced set of prudential returns.

Timing

FigureValueSource
Statutory decision period3 months from a complete file; silence is refusalMonetary and Financial Code
Regulator’s published figurePresentation meeting within 2 weeks; clarification requests within 3 weeks of filing; replies within 2 weeks; decision posted within 2 business daysACPR Fintech Charter
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
Application feeNonePassport notifications are also free
Annual supervision contributionSet under the monetary and financial codeAmount by institution type
Initial capital€350,000€100,000 under the simplified regime
Professional feesFixed, in writingQuoted after scoping

Simplified authorisation

An issuer whose average monthly outstanding e-money stays below €5 million, with units limited to €250, may apply for the simplified authorisation: €100,000 capital and adapted own funds and internal control, with no European passport.

Passporting and scope

A French EMI passports throughout the EU and EEA by branch, agent or distributor, or cross-border services, on notification through the ACPR portal after authorisation. The simplified regime carries no passport.

Why applications are delayed

The ACPR publishes its points of attention.

  1. Incomplete or unfinished files and slow responses to questions.
  2. Safeguarding arrangements that do not comply: account terms, timing of transfers, the terms of the dedicated account.
  3. Own funds and business plan weaknesses: ineligible capital instruments, missing three-year profit and loss, balance sheet and cash flow with target and stressed scenarios, spreadsheets without their formulas.

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 France and across the EU, during the application, so the firm trades on authorisation. See banking and payment processing.

Questions firms ask

How long does ACPR EMI authorisation take?

Three months from a complete file by statute, with silence treated as refusal. The ACPR commits to a presentation meeting within two weeks, clarification requests within three weeks of filing and replies within two weeks. The firm plans for six to eight months after submission.

Is there an application fee in France?

No. Passport notifications are also free. An annual supervision contribution applies once authorised.

What is cantonnement?

Segregation of customer funds on a dedicated demand account with a credit institution, the French safeguarding method; an insurance contract or comparable guarantee is the alternative.

Who must be in France?

At least two effective managers exercising management from France, with the central administration in the same territory as the registered office.

What is the simplified EMI regime?

An authorisation for issuers below €5 million of average monthly outstanding e-money with €100,000 capital and no passport.

References

  1. ACPR: payment institution authorisation procedure
  2. ACPR: electronic money institution authorisation procedure
  3. ACPR: points of attention in the examination of authorisation files
  4. ACPR Fintech Charter
  5. ACPR and AMF Fintech Forum 2025, payments workshop

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.