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Licence guide

Luxembourg electronic money institution licence.

Large payment and e-money groups run their EU operations from Luxembourg, where the regulator, the banks and the professional infrastructure are built for institutional applicants.

Published 16 October 2026 · Last reviewed 17 October 2026 · Reviewed against the regulator’s current publications
CSSFRegulator
€350,000Initial capital
€30,000Examination 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 directors based in Luxembourg, 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 permissions, the own funds under Method D and the methods for payment services are confirmed in a written proposal the same day, with the business plan and the fund and data flow diagrams prepared for the initial CSSF meeting.
  2. Application pack. The CSSF application form, the declarations of honour, the internal control, AML, ICT and security policy with its risk assessment, and the qualifying shareholder files, submitted through the CSSF’s secure file transfer.
  3. Banking. The segregated safeguarding account with a credit institution and the operating accounts are arranged through the firm’s relationships with Luxembourg banks before the decision, so customer funds are insulated from creditors from the first day.
  4. Regulator engagement. The CSSF examines the file by correspondence and meetings; each round is answered with the evidence assembled and the flows of funds mapped clearly, until the decision and entry in the CSSF and European registers.

Key people, banking and technology

You will need directors with senior experience in similar businesses who run the company from Luxembourg, plus supervisory board members.

Key peopleThe firm introduces candidates for directors based in Luxembourg 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 Luxembourg EMI issues e-money and provides payment services across the EU and EEA on one CSSF authorisation.
  • Initial capital is €350,000; own funds are at least 2% of average outstanding e-money, with Methods A, B or C for payment services.
  • The CSSF charges a €30,000 lump sum to examine the application and an annual fee of €30,000, rising to €40,000 above €1 billion of combined volume and reduced to €25,000 for the first three years.
  • The CSSF decides within three months of the application or of missing information, and within twelve months in any case.
  • Central administration and registered office in Luxembourg.
  • Luxembourg is the EU base of several of the largest payment groups and its regulator is accustomed to institutional-scale applications.

Who needs the licence

A business issuing stored value in Luxembourg or, through passporting, across the EU and EEA needs CSSF authorisation. Luxembourg hosts the EU operations of several of the largest payment and e-money groups, and its regulator, its banks and its professional infrastructure are built for institutional applicants. An EMI may provide every payment service under the same authorisation.

What the CSSF requires

  • Legal form and location. A company with its central administration and registered office in Luxembourg, providing at least part of its business there.
  • Governance. Members of the administrative, management and supervisory bodies evidence professional standing; those responsible for management are competent to direct the business with adequate experience at a high level in similar activities; qualifying shareholders identified and assessed; a statutory auditor; internal control, anti-money laundering controls, ICT and a security policy with risk assessment in the file.
  • Safeguarding. No commingling; funds still held at the end of the next business day placed in a separate account with a credit institution or central bank, or invested in secure low-risk assets, insulated from creditors; or an insurance policy or comparable guarantee from outside the group.
  • Application pack. An initial meeting at the CSSF with the business plan and fund and data flow diagrams, then the CSSF application form and declarations of honour submitted through its secure file transfer; examination by correspondence and meetings; publication in the CSSF and European registers.
  • Capital. Initial capital of €350,000 and own funds thereafter under Method D (2% of average outstanding e-money) for e-money and Methods A, B or C for payment services as the CSSF determines.

Capital

RequirementAmount
Initial capital€350,000
Ongoing own funds (Method D)At least 2% of average outstanding e-money
Payment servicesMethod A, B or C as determined

The law contains no small e-money regime; every issuer holds the full authorisation.

Timing

FigureValueSource
Statutory decision period3 months from the application or from missing information; 12 months at mostLaw of 10 November 2009
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
Examination fee€30,000Single lump sum for a new authorisation; €6,000 to extend to additional payment services
Annual fee€30,000€40,000 where combined payment and e-money volume exceeds €1 billion; €25,000 for institutions authorised three years or less below that volume
Initial capital€350,000Held before authorisation
Professional feesFixed, in writingQuoted after scoping

Passporting and scope

A Luxembourg EMI passports throughout the EU and EEA by branch, agent or distributor, or cross-border services, on notification to the CSSF.

Why applications are delayed

The CSSF publishes no list of causes of delay. In the firm’s experience the causes are the same as in every EU regime: incomplete files, insufficient substance in Luxembourg, and flows of funds that are not clearly mapped.

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 Luxembourg 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 CSSF EMI authorisation take?

Three months from the application or from the missing information, and twelve months at most, after which silence is a deemed refusal. The firm plans for six to eight months after submission.

What are the CSSF fees?

A €30,000 examination fee on application and an annual fee of €30,000, €40,000 above €1 billion of volume, reduced to €25,000 for the first three years.

Who must be in Luxembourg?

The central administration and registered office, with the people responsible for management competent to direct the business from there.

Is there a small EMI regime?

No. Every issuer holds the full authorisation.

Why do large groups choose Luxembourg?

A regulator and banking sector accustomed to institutional scale, a stable legal environment, and a position at the centre of the EU.

References

  1. CSSF: authorisation procedure for payment institutions and electronic money institutions
  2. Law of 10 November 2009 on payment services (consolidated, English)
  3. Grand-Ducal Regulation of 23 December 2022 on CSSF fees
  4. CSSF: law of 10 November 2009
  5. Law of 20 May 2011 inserting the EMI chapter (Mémorial A 104)

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.