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EU Payment Institution and EMI Licensing 2026: Which Jurisdiction Should You Choose?

Published 1 July 2026 · Last reviewed 17 October 2026 · Buckingham Capital Consulting
Contents
  1. EU payment and e-money jurisdictions at a glance
  2. Payment institution or EMI: settle the permission first
  3. Can one EU licence cover the whole European market?
  4. Substance: the business must be run from the home state
  5. Lithuania
  6. Ireland
  7. Malta
  8. The Netherlands
  9. Luxembourg
  10. France
  11. Germany
  12. Spain, Estonia and other Member States
  13. How long it takes in each jurisdiction
  14. Banking and safeguarding can matter as much as the regulator
  15. What it costs: beyond the application fee
  16. Initial capital is harmonised across the EU
  17. Management location and customer market
  18. Setting up a fintech in Europe: five decisions before you apply
  19. What about the United Kingdom after Brexit?
  20. PSD3 and the future licensing framework
  21. Should you buy an existing EU PI or EMI instead?
  22. A practical jurisdiction-selection process
  23. Frequently asked questions
Key takeaways
  • Initial capital is harmonised across the EU: €350,000 for a full electronic money institution (EMI) and €20,000, €50,000 or €125,000 for a payment institution, so the choice of country turns on substance, supervision and infrastructure, not capital.
  • Regulator application fees range from nil in Ireland, France and Spain to €1,463 for an EMI in Lithuania, €10,400 in the Netherlands, €10,000 to €15,000 in Malta and €30,000 in Luxembourg.
  • Every regulator must decide a complete application within 3 months; the Central Bank of Ireland's own standard is 90 business days, and the firm plans authorisation at 6 to 8 months from submission.
  • PSD2 requires the head office in the licensing Member State and part of the payment business carried out there, so the home state should be where directors, the MLRO and key decisions sit.
  • A licence from any one Member State passports to all 30 EEA countries but not to the UK, which has required separate FCA authorisation since 31 December 2020.
  • PSD3 will fold EMIs into the payment institution regime; it was agreed politically on 27 November 2025 but, as at 17 October 2026, is not adopted or published in the Official Journal.

EU payment and e-money jurisdictions at a glance

Choosing the home regulator is one of the most consequential decisions in a European payments business. The authorisation passports across the European Economic Area (EEA), but the jurisdictions are not interchangeable: they share the PSD2 and Electronic Money Directive framework, yet differ in supervisory approach, local presence expected, fees, ecosystem and banking access.

The right home state is where the business will genuinely be managed, where its decision-makers sit and where it can build banking, safeguarding and staff for the long term. The question is which jurisdiction gives the strongest base for the business you intend to run.

JurisdictionRegulatorBest suited to
LithuaniaBank of LithuaniaPan-European fintechs willing to build a Vilnius team; direct SEPA access through CENTROlink
IrelandCentral Bank of IrelandInternational and US-linked groups wanting an English-speaking financial centre
MaltaMalta Financial Services Authority (MFSA)Groups wanting an English-speaking base, often alongside other Maltese licences
NetherlandsDe Nederlandsche Bank (DNB)Larger fintechs and B2B payment models focused on northern Europe
LuxembourgCSSFCorporate, wealth and fund-adjacent payment models
FranceACPRFirms whose main market and management are French
GermanyBaFinFirms serving German-speaking consumers and merchants from a German team
SpainBanco de EspañaFirms serving Spanish-speaking markets with management in Spain
JurisdictionApplication feePublished decision standard
LithuaniaEMI €1,463; PI €8983 months from a complete file; completeness check in 5 business days
IrelandNone3 months from a complete file; 90% of assessments within 90 business days
Malta€10,000; €15,000 for e-money with payment services3 months from receipt
Netherlands€10,4003 months from a complete file
Luxembourg€30,0003 months; 12 months at most
FranceNone3 months from a complete file
GermanyCharged by time spent3 months; 12 months at most
SpainNone3 months from a complete file

No jurisdiction is best for every firm. The best one for you is where you can show credible central administration, senior management and a genuine reason to be there, and where you can operate commercially after authorisation.

Payment institution or EMI: settle the permission first

Decide which licence the product needs before comparing countries. The permission analysis sets the capital, the safeguarding model and the regulator's line of questioning everywhere.

Payment institution

A payment institution is authorised under PSD2 (Directive (EU) 2015/2366) and national law for one or more payment services: payment accounts, credit transfers and direct debits, card issuing, merchant acquiring, money remittance, payment initiation and account information. Initial capital is €20,000 for money remittance, €50,000 for payment initiation and €125,000 for the core services. A payment institution cannot issue electronic money.

Electronic money institution

An EMI issues electronic money, meaning a stored monetary value issued on receipt of funds and accepted for payment, and may also provide payment services. It is authorised under the Second Electronic Money Directive (Directive 2009/110/EC). The EMI licence fits stored-value wallets, e-money funded accounts, prepaid products, multi-currency accounts and e-money linked cards. A full EMI needs €350,000 of initial capital and own funds of at least 2% of average outstanding e-money.

Choosing between them

Let the product decide. A firm that only moves money from payer to payee does not need an EMI, and a payment institution is more proportionate. A firm whose customers hold a balance for later use needs an EMI, and should not reshape the product to fit a payment institution licence because the capital is lower. Our guide to the EU payment institution licence sets out the eight services and the capital rules in full.

E-money tokens under MiCA

Under the Markets in Crypto-Assets Regulation (MiCA, Regulation (EU) 2023/1114), only a credit institution or an EMI may issue an e-money token, meaning a stablecoin that references one official currency. A firm planning a euro or dollar stablecoin for the EU therefore needs an EMI licence, plus the MiCA notification and white paper, and should choose its jurisdiction with both regimes in mind.

Smaller national regimes

Several Member States offer a restricted or small institution route for low volumes, valid in that country only. Lithuania's restricted EMI licence has no minimum capital where average outstanding e-money stays below €900,000, and a 2-month decision period; France offers a simplified EMI at €100,000 of capital. These routes cannot be passported, so they suit a domestic launch rather than a European business.

JurisdictionSmall or restricted routeLimit
LithuaniaRestricted EMI, no minimum capital, €1,235 levyAverage outstanding e-money up to €900,000
LithuaniaRestricted payment institution, €682 levyUp to €3 million a month
FranceSimplified EMI at €100,000; simplified PI at €40,000Set by the Monetary and Financial Code
NetherlandsE-money exemption, registered not supervisedOutstanding e-money up to €5 million
EstoniaE-money exemptionAverage outstanding e-money up to €500,000
Germany, Luxembourg, MaltaNo small regimeFull authorisation only

Can one EU licence cover the whole European market?

Yes. An authorised payment institution or EMI can offer its services in the other 29 EEA countries through passporting, either cross-border under the freedom to provide services or through a branch, agents or (for EMIs) distributors under the freedom of establishment. The firm notifies its home regulator, which forwards the notification to the host regulator within one month.

Passporting does not create 30 licences. The home regulator remains responsible for authorisation and prudential supervision: capital, safeguarding, governance, qualifying holdings, outsourcing and material changes. Host regulators keep defined powers, mainly for conduct and anti-money laundering rules applying to branches and agents. Choose a home regulator you can work with for many years, because the relationship continues long after the licence is granted.

Substance: the business must be run from the home state

PSD2 Article 11 requires an authorised payment institution to have its head office in the Member State that licenses it and to carry out at least part of its payment business there. The same principle applies to EMIs. Regulators test whether central administration and decision-making actually happen in the home state.

The European Banking Authority's 2023 peer review of authorisation under PSD2 found that national regulators had interpreted substance differently and asked them to converge on a consistent, demanding standard. Since then, regulators have tested substance more closely.

In practice, regulators look for:

  • directors who live in or regularly work from the home state and take the key decisions there;
  • a compliance officer and an MLRO (money laundering reporting officer) based locally, with real authority;
  • risk management, finance and financial crime functions run from a real office;
  • outsourcing to the group documented and overseen by the local board.
JurisdictionLocal presence the regulator expects
LithuaniaRegistered office and head office in Lithuania, with senior management and operations there
IrelandBoard decisions, financial control, compliance and risk in Ireland; at least one independent non-executive director
MaltaDirected from Malta by at least two people; compliance officer and MLRO in post
NetherlandsAt least two day-to-day managers working substantially from the Netherlands
LuxembourgCentral administration and registered office in Luxembourg
FranceTwo effective managers in France
GermanyHead office and at least two managing directors in Germany; AML officer at management level
SpainRegistered office, central administration and effective management in Spain

The substance needed scales with size and complexity. A start-up payment institution may begin with a small local team, provided the people responsible for the regulated business are genuinely there and the plan shows how the team will grow.

Lithuania

Lithuania has one of the largest specialist payment and e-money sectors in the EU. The Bank of Lithuania publishes clear guidance, runs dedicated fintech engagement and has deep experience of payment and e-money models. Authorised institutions can join CENTROlink, the central bank's payment system, for direct access to SEPA euro payments.

The Bank of Lithuania checks an application for completeness within 5 business days and decides within 3 months of a complete file. Where it asks for more information, the 3 months run again from the date the information arrives. The state levy is €1,463 for an EMI licence, €1,235 for a restricted EMI licence and €898 for a payment institution licence. The registered office and head office must be in Lithuania.

The Bank of Lithuania states that the operating plan must match the founders' ability to deliver it and that the institution must be ready to provide services safely from the day of authorisation. It publishes its decisions, including refusals, which makes its standard transparent. See our Lithuania EMI licence page for the full requirements.

When Lithuania makes commercial sense

  • The firm will build a real team in Vilnius and wants a regulator experienced with payment and e-money models.
  • The target market is pan-European rather than one dominant country.
  • The firm wants direct SEPA access and the Baltic fintech labour market, with compliance staff and service providers already concentrated there.

Is Lithuania still the fastest country for an EMI licence?

Lithuania's 3-month decision period is transparent, but it runs from a complete file. The end-to-end project also includes incorporation, appointments, the regulatory framework, capital and infrastructure. Choose Lithuania for its fit with the business; a well-prepared file there, as elsewhere, is planned at 6 to 8 months from submission to authorisation.

Ireland

Ireland is a leading base for international fintech and financial groups: an English-speaking EU state with a large multinational presence. The Central Bank of Ireland runs a structured, risk-based process with explicit standards for applicants, and charges no application fee. Authorised firms pay an annual industry funding levy with a minimum of €5,000.

The Central Bank's service standard is to complete 90% of assessments within 90 business days of a complete application, and the clock pauses where key areas are not addressed. It focuses on governance, safeguarding, outsourcing, operational and IT risk, financial crime and orderly wind-down. It expects board decision-making, financial control, compliance and risk management in Ireland, at least one independent non-executive director, and compliance and risk functions that are not outsourced.

The process runs from a Pre-Application Key Facts Document and an initial meeting through a key information check, full assessment with interviews and a "minded to authorise" letter to the grant. Detail is on our Ireland EMI licence page.

When Ireland makes commercial sense

  • US or international groups with Irish operations, management or technology already in place.
  • Firms that value a globally recognised financial centre, international professional services and technology talent.
  • Structures that investors, banks and card schemes will examine closely.

Is Ireland better than Lithuania for an EMI licence?

Neither is better in general. Lithuania offers a specialist payments sector and a regulator focused on fintech models; Ireland offers an English-speaking financial centre attractive to global groups. A Dublin team and a Vilnius team carry different cost bases, and existing group staff in either country can reverse the comparison. Decide on management location, cost, customers, banking and group structure.

Malta

Malta is a long-established international financial centre. The MFSA authorises payment institutions and EMIs under the Financial Institutions Act and its rulebook, and works in English. Its experience spans payments, e-money, investment services, insurance and digital finance, which suits groups with several regulated products.

The application fee is €10,000 for one licence category and €15,000 where e-money and payment services are combined. Annual supervisory fees start at €25,000 for a payment institution and €35,000 for an EMI, plus a variable element. The MFSA grants an in-principle approval first, with pre-licensing conditions to be met within six months, and the safeguarding bank's engagement letter must be in place before the firm starts operating.

The company must be directed from Malta by at least two people, with a compliance officer and an MLRO in place at all times. See our Malta EMI licence page.

When Malta makes commercial sense

  • Founders who will establish and manage operations in Malta and value an English-speaking environment.
  • Groups already using Malta for regulated or technology operations.
  • Models that benefit from close access to a compact network of specialist advisers, auditors and banks.

Malta or Lithuania?

Both are established fintech jurisdictions. Lithuania has a larger specialist payments ecosystem; Malta a broader international financial services environment. A team already in Malta has the stronger case there, and a Baltic-based team favours Lithuania. Compare talent, salaries, banking, office costs and travel over the life of the licence, not only the authorisation.

The Netherlands

The Netherlands has a sophisticated payments and fintech sector and a highly digital economy. DNB authorises payment institutions and EMIs under the Financial Supervision Act (Wft), and the Authority for the Financial Markets (AFM) supervises conduct. The application fee is €10,400.

DNB expects complete, well-evidenced applications and publishes the success factors it looks for. Day-to-day management must be carried out by at least two people working substantially from the Netherlands. Customer funds are typically safeguarded through a separate foundation (a stichting derdengelden), and the safeguarding account or bank commitment letter must be in place before the licence is granted. Anyone acquiring 10% or more needs a declaration of no objection, which DNB assesses in parallel.

When the Netherlands makes commercial sense

  • Founders, management, customers or technology are already in the Netherlands or Benelux.
  • The model is a sophisticated B2B or technology-led payment business serving northern Europe.
  • The firm is ready to build a real Dutch institution with substantial local management.

Luxembourg

Luxembourg is one of Europe's largest cross-border financial centres. The CSSF authorises payment institutions and EMIs under the Law of 10 November 2009 on payment services. The examination fee is €30,000 and the annual fee €30,000, rising to €40,000 for institutions above €1 billion of combined volume.

Central administration and the registered office must be in Luxembourg. The CSSF starts with an initial meeting at which the applicant presents the business plan with diagrams of fund and data flows, and decides within 3 months of a complete file and no later than 12 months.

Luxembourg suits international groups where payments or e-money sit within wider financial, investment, wealth or corporate structures, and that will benefit from the depth of its banking and fund sector.

France

France is one of Europe's largest consumer and financial services markets. The ACPR authorises payment institutions and EMIs under the Monetary and Financial Code, charges no application fee and works in French. Its Fintech Charter commits to a presentation meeting within two weeks of a request and to fixed response times during the assessment.

Two effective managers must be based in France. France also offers simplified authorisations without passporting: a payment institution at €40,000 of capital below €3 million a month, and an EMI at €100,000. France makes sense where the main customers, management or partnerships are French, with passporting to expand later.

Germany

BaFin authorises payment institutions and EMIs under the Payment Services Supervision Act (ZAG). Capital is €350,000 for an EMI and up to €125,000 for a payment institution, and BaFin generally applies own funds Method B. Fees are charged by time spent, with an annual cost allocation afterwards.

The head office must be in Germany, with at least two managing directors and an anti-money laundering officer at management level in Germany. BaFin decides within 3 months of a complete file, and an application not completed within 12 months is refused. Germany has no small payment institution regime. It suits firms whose main market is German-speaking consumers and merchants and that will build a full German team.

Spain, Estonia and other Member States

Every EU and EEA state authorises payment institutions and EMIs under the same framework, and a less discussed jurisdiction is often the right one.

  • Spain: Banco de España charges no application fee and decides within 3 months of a complete file. Documents are in Spanish, and the registered office, central administration and effective management must be in Spain.
  • Estonia: Finantsinspektsioon charges €3,000 for a payment institution application, decides within 3 months of a complete file and 6 months at most, and has accepted applications only through its online portal since 18 March 2026.
  • Belgium, Sweden, Denmark, Latvia and Cyprus: each fits a business whose management and customers are already there.

A Spanish fintech serving Spanish customers from Madrid, or a Swedish business run from Stockholm, will usually be best licensed at home. Choosing a fashionable jurisdiction instead can mean building a second management structure the business does not need.

How long it takes in each jurisdiction

Every regulator works to the same statutory period: a decision within 3 months of a complete application. The clock stops while the regulator waits for answers, so the length of the project depends mainly on how complete the file is on the day it is submitted and how quickly questions are answered.

PhaseWhat happensDuration
PreparationIncorporation, hires, business plan, policies, bank discussions4 to 8 weeks
AssessmentCompleteness check, questions, interviews4 to 6 months
ConditionsCapital paid in, safeguarding live, systems tested1 to 2 months
PassportingNotifications to host regulators1 to 3 months

The firm plans payment institution and EMI authorisations at 6 to 8 months from submission in each of the jurisdictions above. Local-language jurisdictions add translation time before submission rather than after it. The Central Bank of Ireland treats a file left without a response for 60 business days as dormant, and Malta and Luxembourg treat silence at the end of the period as a refusal, so a fast, complete response to each question shortens every timeline.

Banking and safeguarding can matter as much as the regulator

An EU licence is only as useful as the operating infrastructure behind it: safeguarding accounts for customer funds, operating accounts, scheme access and payment rails. Banks carry out their own risk assessment and decide independently whether to onboard an authorised institution.

Some business models, sectors and payment corridors take longer to bank, even with a valid licence. Investigate safeguarding and operating banks during jurisdiction selection, because Malta, the Netherlands and others expect the safeguarding arrangement agreed before the licence is granted. Cross-border banking arrangements are possible, provided the overall structure remains credible and manageable for the home regulator.

Lithuania's CENTROlink and the growing number of national central banks that let payment institutions settle directly are worth weighing: direct access reduces dependence on a correspondent bank.

What it costs: beyond the application fee

Filing fees are usually a small part of the total. The real cost of a compliant institution includes the initial capital, the directors and control functions, local staff, office, technology, advisers and banking, run for several years.

Cost itemWhat drives it
Initial capitalFixed by licence type: €350,000 for an EMI, up to €125,000 for a payment institution
Own funds above the minimumVolumes, outstanding e-money and the method the regulator applies
Local teamSalary levels and how many directors and control functions must be resident
Annual supervisory feesFrom a minimum of €5,000 in Ireland to €30,000 in Luxembourg and €35,000 for an EMI in Malta
TechnologySafeguarding reconciliation, transaction monitoring and DORA ICT controls
LanguageTranslation and local-language staff in France, Germany and Spain

A low-fee jurisdiction can cost more overall if a new management team must be recruited there, and a higher-fee jurisdiction can be efficient where staff and infrastructure already exist. Build a jurisdiction-by-jurisdiction operating budget over three years before deciding.

Initial capital is harmonised across the EU

LicenceInitial capitalOngoing own funds
EMI€350,000At least 2% of average outstanding e-money (Method D), plus a payment services calculation where relevant
Payment institution, core services€125,000Method A, B or C as the regulator directs
Payment initiation€50,000Initial capital, plus professional indemnity insurance
Money remittance only€20,000Method A, B or C with a 0.5 scaling factor
Account information onlyNoneProfessional indemnity insurance

Choosing another Member State does not reduce the €350,000 minimum for a full EMI. Regulators may vary the own funds requirement by up to 20% either way, and national practice differs on the method applied, but the real differences between jurisdictions lie in supervision, substance and process.

Management location and customer market

Start with where your people are

The simplest test is where the people responsible for the regulated business live and work. If the chief executive, compliance officer, finance lead and key functions are in one Member State, that is usually the natural home. Licensing elsewhere can mean duplicating directors, compliance staff, offices and governance.

International founders without a European base have more choice, and talent, language, cost, banking and the regulator's experience of the model then decide it.

Then the customer market

The licence need not be in the country with most customers, because passporting allows cross-border service. A dominant domestic market still shapes the choice: a fintech with 80% of its customers in France, French-language support and French partnerships will often be better based in France. A pan-European B2B business has more freedom. Map the expansion plan before applying: which countries, served remotely or through branches or agents, and what host-state rules apply.

Setting up a fintech in Europe: five decisions before you apply

The licence is one part of launching a European fintech. Five decisions shape the application and should be settled first.

  1. Your niche and advantage. Identify the segment, study what the leading firms in it do well, and define the specific advantage you offer. The regulator reads the business plan for a clear, credible proposition.
  2. The team. Cover management, operations, compliance, financial crime, technology security and finance with experienced people who share the plan. The regulator assesses the directors, the compliance officer and the MLRO individually.
  3. The technology stack. Decide what to build and what to buy: core ledger, safeguarding reconciliation, customer onboarding, transaction monitoring and card processing. Issuing cards requires principal membership of Visa or Mastercard or a sponsorship arrangement with a principal member. Every critical provider must meet DORA's contract and exit requirements.
  4. The licence. Settle the permission (payment institution or EMI) and the jurisdiction, and run the business to the licence conditions from the first day.
  5. Funding. Raise enough for the initial capital, the own funds that growth will require and at least 12 months of operating costs after authorisation. Regulators test this in the forecasts, and investors look for traction, the team and the proposition.

What about the United Kingdom after Brexit?

EU and EEA licences do not passport into the UK. Passporting between the UK and the EU ended on 31 December 2020, so a European fintech serving UK customers needs separate FCA authorisation, and an FCA-authorised payment institution or EMI needs an EU-authorised entity for EU business.

International groups often run parallel UK and EU entities. They can share technology and group resources under documented outsourcing, provided each entity has its own board, capital, MLRO, safeguarding and control.

PSD3 and the future licensing framework

Licensing in 2026 remains under PSD2 and the Electronic Money Directive. The third Payment Services Directive (PSD3) and the new Payment Services Regulation (PSR) will reshape it. The Council and Parliament reached a provisional agreement on 27 November 2025, and the Parliament's ECON committee approved the agreed texts on 5 May 2026. As at 17 October 2026, EUR-Lex lists both only as Commission proposals and the Parliament's Legislative Observatory shows them awaiting the Council's first reading position, with an indicative plenary date of 14 December 2026.

The central change for licensing is that the Electronic Money Directive is repealed and issuing e-money becomes a payment service, so EMIs become payment institutions. In the agreed text, initial capital becomes €250,000 for issuing e-money and €150,000 for the core payment services. The reform also aims to narrow differences between national regulators and strengthen fraud prevention.

Will an existing EMI licence survive PSD3?

Yes. The agreed text contains transitional arrangements that let existing EMIs and payment institutions continue, with a longer period for EMIs that used the small EMI waiver. The exact deadlines will run from entry into force, so they are fixed only once the texts are published in the Official Journal. Expect to update permissions, documentation and the safeguarding framework through the transition.

PSD3 is not a reason to delay a 2026 application. It is a reason to build governance, safeguarding and fraud controls to the agreed standard now. Our guide to PSD3 and the Payment Services Regulation sets out each change.

Should you buy an existing EU PI or EMI instead?

Acquiring an authorised company is an alternative where a suitable target exists. The buyer acquires the regulated legal entity, not a transferable licence, and the regulator must approve each new owner of 10% or more before completion.

An acquisition works where the target has the right permissions, management, banking and safeguarding already in place. It needs full regulatory due diligence: permissions, supervisory history, safeguarding, anti-money laundering, capital, reporting and third-party contracts. The firm's transactions and change of control practice supports buyers and sellers through target selection, due diligence and the qualifying holding application.

A practical jurisdiction-selection process

No EU regulator offers a lighter standard: all apply PSD2, the Electronic Money Directive and the EBA guidelines, and the EBA's peer review work is narrowing national differences further. Clear, demanding expectations give a firm a stable base for supervision after authorisation. Select the regulator that best fits the business, in three stages.

  1. Define the permissions. Payment institution or EMI, which payment services, whether e-money is issued, and any related activity such as crypto-asset services under MiCA.
  2. Map the operating model. Where management, staff, customers, technology, safeguarding, banking and group functions will sit across Europe.
  3. Shortlist two or three jurisdictions. Compare substance expected, process, total cost and infrastructure, and meet the shortlisted regulators early for novel or complex models.
FactorWhat to test
Management locationWhere the directors, compliance officer and MLRO will live and work
Customer marketShare of customers by country and the language they are served in
Banking and safeguardingWhich banks will open safeguarding and operating accounts for the model
TalentAvailability and cost of experienced compliance, risk and payments staff
Regulator experienceWhether the regulator has authorised similar models
Total costThree-year budget for team, office, fees and technology

Only then incorporate the applicant and prepare the full application. Choosing the jurisdiction first and fitting the model around it adds cost and weakens the case for being there.

Frequently asked questions

Which EU country is best for an EMI licence in 2026?

No single country is best. The right home state is where management, operations, banking, safeguarding and staff can genuinely sit; Lithuania and Ireland are the most common choices for pan-European models.

Is Lithuania still the easiest place to obtain an EMI licence?

Lithuania applies the same EU standard as other regulators. It offers a clear process, a 3-month decision period from a complete file and a €1,463 state levy, with real local substance expected.

Can an EMI authorised in Ireland passport throughout Europe?

Yes. An Irish EMI can passport to the other 29 EEA countries by notification, while the Central Bank of Ireland remains its home regulator.

How much capital does an EU EMI or payment institution need?

A full EMI needs €350,000 of initial capital. A payment institution needs €20,000, €50,000 or €125,000 depending on its services, and own funds can rise above the minimum as the firm grows.

Which EU regulator charges the lowest application fee?

Ireland, France and Spain charge no application fee. Lithuania charges €898 for a payment institution and €1,463 for an EMI; Luxembourg charges €30,000.

Does an EU EMI licence cover the UK?

No. EU licences have not passported into the UK since 31 December 2020, so UK business needs separate FCA authorisation.

Will PSD3 replace the EMI licence?

Yes, once adopted. The agreed text repeals the Electronic Money Directive and makes issuing e-money a payment service, with transitional arrangements for existing EMIs; as at 17 October 2026 it is not yet adopted.

References

  1. Directive 2009/110/EC on electronic money institutions (EMD2), EUR-Lex
  2. Directive (EU) 2015/2366 on payment services (PSD2), EUR-Lex
  3. Bank of Lithuania: authorisation of electronic money institutions
  4. Central Bank of Ireland: electronic money institutions
  5. DNB: authorisation as an electronic money institution
  6. EBA: peer review report on authorisation under PSD2 (2023)
  7. European Parliament Legislative Observatory: PSD3, 2023/0209(COD)

About Buckingham Capital Consulting

Buckingham Capital Consulting has obtained payment and e-money licences in the UK and the EU since 2013, including a Central Bank of Ireland EMI licence for Own Solutions and FCA EMI licences for Dzing Finance, Hryze and HFS. The firm compares jurisdictions against the client's operating model, prepares the full application and arranges the safeguarding and operating accounts in the chosen Member State.

Speak to an expert: WhatsApp +44 7563 115980, Telegram @buckinghamcapital or info@buckinghamcapitalconsulting.co.uk.

This article is general information, reviewed against the regulator’s published requirements on the date shown. It is not legal advice; the regulator’s current publications take precedence.