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Licence guide

Luxembourg payment institution licence.

Payment institutions that want the standing of a Luxembourg authorisation, and a regulator used to institutional scale at the centre of the EU, choose the CSSF as their supervisor.

Published 16 October 2026 · Last reviewed 17 October 2026 · Reviewed against the regulator’s current publications
CSSFRegulator
€20,000–€125,000Initial 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 payment services, the capital by service and the own funds method are confirmed in a written proposal the same day, with the business plan, partners and fund and data flow diagrams prepared for the initial CSSF meeting.
  2. Application pack. The CSSF application form, the declarations of honour, the governance, internal control, AML and ICT security policies and the shareholder files, submitted by secure file transfer with the examination fee.
  3. Banking. The safeguarding account and the settlement and operating accounts are arranged through the firm’s relationships before the decision, with funds still held at the end of the next business day placed in the separate account.
  4. Regulator engagement. The CSSF’s correspondence and meetings are handled through one process, with substance in Luxembourg and the flows of funds evidenced, until the decision, which the law requires within twelve months at most.

Key people, banking and technology

You will need directors with the competence and experience to run a payment firm from Luxembourg, plus board and 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 payment institution provides any of the payment services across the EU and EEA on one CSSF authorisation.
  • Initial capital is €125,000 for account and card services, €50,000 for payment initiation and €20,000 for money remittance; account information only needs no own funds.
  • The CSSF charges €30,000 to examine the application and €30,000 a year, with the same volume and early-years adjustments as for EMIs.
  • Three months from the application or from missing information; twelve months at most.
  • Central administration and registered office in Luxembourg, with part of the business carried on there.
  • There are no volume tiers; account information is a registration.

Who needs the licence

A business providing a payment service in Luxembourg or, through passporting, in the EU and EEA needs CSSF authorisation. A business that will also hold customer balances applies for an EMI licence instead.

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 by service and own funds thereafter never below it, under Method A, B or C as the CSSF determines; no own funds requirement for account information only.

Capital

RequirementAmount
Account, card and other services (1–5)€125,000
Payment initiation only€50,000
Money remittance only€20,000
Account information onlyNone; registration
Ongoing own fundsMethod A, B or C as determined

Own funds may never fall below the initial capital.

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; €8,000 to extend the authorisation
Annual fee€30,000€40,000 above €1 billion of volume; €25,000 for institutions authorised three years or less below that volume
Initial capital€20,000 to €125,000By the highest service
Professional feesFixed, in writingQuoted after scoping

Passporting and scope

A Luxembourg payment institution passports throughout the EU and EEA on notification to the CSSF. A limited-network exclusion requires notification.

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

A payment institution 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 payment institution licence take?

Three months from the application or from missing information; twelve months at most. The firm plans for six to eight months after submission.

What capital does a Luxembourg PI need?

€125,000 for account, card and most services; €50,000 for payment initiation only; €20,000 for money remittance only.

What are the fees?

€30,000 on application and €30,000 a year, with adjustments by volume and for the first three years.

Is there a small PI regime?

No. The law sets no volume tiers.

Who must be in Luxembourg?

The central administration and registered office, with part of the business carried on there and management competent to direct it from Luxembourg.

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

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.