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Licence guide

Malta electronic money institution licence.

Malta suits e-money issuers that serve the gaming sector or want a rulebook that sets out governance in full, with one licence covering e-money and every payment service across the EU.

Published 16 October 2026 · Last reviewed 17 October 2026 · Reviewed against the regulator’s current publications
MFSARegulator
€350,000Initial capital
€15,000Application 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 two directors in Malta, a chair and an MLRO, 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 fee category and the own funds position are confirmed in a written proposal the same day, and the presentation for the MFSA’s preliminary meeting is prepared and sent ten working days ahead.
  2. Application pack. The application form with the information in the rulebook’s annex, the personal and corporate questionnaires for the board, the compliance officer and the MLRO, and the three lines of defence, submitted through the MFSA’s LH Portal.
  3. Banking. The engagement letter with a credit institution for the dedicated safeguarding account, which the MFSA requires before commencement, and the operating accounts are arranged through the firm’s relationships before the decision.
  4. Regulator engagement. Feedback is answered through one process, with the MFSA replying within 20 working days at each stage, through the in-principle approval letter, the pre-licensing conditions met within six months and the pre-commencement conditions, until the licence is issued.

Key people, banking and technology

You will need two directors based in Malta, a Malta-resident board member, an independent non-executive chair, a compliance officer and an MLRO.

Key peopleThe firm introduces candidates for two directors in Malta, a chair and an MLRO 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 Maltese EMI issues e-money and provides payment services across the EU and EEA on one licence under the Financial Institutions Act.
  • Initial capital is €350,000; own funds are the higher of that and 2% of average daily outstanding e-money.
  • The application fee is €15,000 where both e-money issuance and payment services are applied for; the fixed annual supervisory fee is €35,000 plus a variable element capped at €250,000.
  • The MFSA must decide within three months of receipt; silence is a deemed refusal.
  • A board of at least three with an independent chair and a Malta-resident member, effective direction by two individuals in Malta, and a compliance officer and MLRO at all times.
  • Malta also licenses gaming operators, which makes it a natural base for payment firms serving that sector.

Who needs the licence

A business issuing stored value to customers in Malta or, through passporting, across the EU and EEA needs an MFSA licence. Malta’s rulebook sets out governance in unusual detail, and its gaming and payments sectors are closely linked. An EMI may provide every payment service under the same licence.

What the MFSA requires

  • Legal form and location. A company with its head office and registered office in Malta, effectively directed from Malta by at least two individuals, carrying on at least part of its business in Malta with key function holders and control functions located there.
  • Governance. A board of at least three, including an independent non-executive director as chair and a Malta-resident member, meeting at least quarterly; a compliance officer independent of operations and an MLRO appointed at all times; fit and proper assessment of qualifying shareholders, the board, senior managers, the compliance officer and the MLRO; three lines of defence.
  • Safeguarding. Segregation in a separate account with a credit institution or central bank, or secure low-risk assets, by the end of the business day following receipt, or an insurance policy or guarantee from outside the group; an engagement letter with a credit institution for a dedicated safeguarding account before commencement.
  • Application pack. The application form with the information in the rulebook’s annex, a preliminary meeting with a presentation sent ten working days ahead, then the in-principle approval letter, pre-licensing conditions to be met within six months, and pre-commencement conditions; submissions through the MFSA’s licence holder portal with personal and corporate questionnaires.
  • Capital. Initial capital of €350,000 and own funds thereafter equal to the higher of that amount and 2% of average daily outstanding e-money, plus Method A, B or C capital for payment services not linked to e-money.

Capital

RequirementAmount
Initial capital€350,000
Ongoing own fundsHigher of €350,000 and 2% of average daily outstanding e-money
Unrelated payment servicesMethod A, B or C as the MFSA determines

The current rulebook contains no small EMI waiver; every e-money issuer holds the full licence.

Timing

FigureValueSource
Statutory decision period3 months from receipt; silence is a deemed refusalFinancial Institutions Act, Cap. 376
Regulator’s published figureReplies to applicant feedback within 20 working days, about 1 month, at each stageMFSA authorisation process service 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 fee€15,000E-money issuance and payment services; €10,000 for one category of activity
Annual supervisory fee€35,000 fixed plus variableVariable element: the higher of 0.02% of total assets, 0.0003% of payment transactions or 0.01% of average daily outstanding e-money, capped at €250,000
Initial capital€350,000Held before authorisation
Professional feesFixed, in writingQuoted after scoping

Passporting and scope

A Maltese EMI passports throughout the EU and EEA by branch, agent or distributor, or cross-border services, under the European passport rights regulations.

Why applications are delayed

The MFSA publishes stage-level service targets rather than a list of causes of delay. In the firm’s experience the three causes are the same as in every EU regime: incomplete submissions, insufficient substance in Malta, and business plans whose assumptions and flows of funds are not clear.

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

Questions firms ask

How long does an MFSA EMI licence take?

Three months from receipt by statute, with silence treated as refusal. Counting the in-principle approval and conditions stages, the firm plans for six to eight months after submission.

What board does the MFSA require?

At least three directors, including an independent non-executive director as chair and a Malta-resident member, meeting at least quarterly, with two individuals effectively directing the business from Malta.

What are the Maltese fees?

€15,000 on application for e-money and payment services, and a fixed annual fee of €35,000 plus a variable element capped at €250,000.

Is there a small EMI regime in Malta?

Not in the current rulebook. Every e-money issuer holds the full licence.

Can a Maltese EMI serve gaming operators?

Yes. Malta licenses gaming operators under the Malta Gaming Authority and many payment firms serving the sector are authorised there; the firm obtains both licences.

References

  1. Financial Institutions Act, Chapter 376 of the Laws of Malta
  2. MFSA Financial Institutions Rulebook, Chapter 1 (authorisation)
  3. MFSA Financial Institutions Rulebook, Chapter 3 (ongoing requirements)
  4. Financial Institutions (Fees) Regulations, S.L. 376.03
  5. Financial Institutions (Safeguarding) Regulations, S.L. 376.04
  6. European Passport Rights for Financial Institutions Regulations, S.L. 376.07

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.