We structure your authorization as an electronic money institution (EMI) or a payment institution (PI) in the right European jurisdiction (Lithuania, Malta, Ireland or others), with a passport to the entire European Economic Area: jurisdiction selection, regulatory fit, the application to the supervisor, safeguarding of funds, AML/CFT, corporate governance and DORA.
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Six building blocks that structure an EMI or payment institution license project in any EEA State, from choosing the jurisdiction to ongoing compliance and the EU passport.
We analyze where your model fits best (Lithuania, Malta, Ireland, Spain or another EEA State) based on services, timelines, the language of the process, substance requirements, taxation and banking relationships. That choice shapes the entire project.
We confirm whether your activity requires an EMI license (issuing electronic money), a payment institution license, PISP/AISP registration for open banking or a different type of entity. Capital, scope and the supervisor all depend on that.
Incorporation of the company (a UAB in Lithuania, a Ltd in Malta…), fit and proper directors, key functions, internal control and the real operational substance (office and staff) that each European regulator requires.
Design of the electronic money issuance and redemption flow, segregated accounts, reconciliations, incident management and the safeguarding method required by EMD2 (segregation or insurance/guarantee).
We implement the anti-money laundering framework: risk assessment, onboarding, monitoring, screening, reporting to the supervisor and to the financial intelligence unit, and evidence that holds up in inspections.
Digital operational resilience framework (DORA), outsourcing and SLAs, plus the passport notification to operate in the other EEA States under the free provision of services or through a branch.
Wallets, prepaid platforms, neobanks, BaaS providers or fintechs that want their own license with pan-European reach: the right jurisdiction depends on your model, your timelines and how much substance you are willing to build.
“The Bank of Lithuania has the largest number of EMIs in the Union, an English-language process, a newcomer program and short statutory deadlines. It is often the first choice for scaling quickly across the EEA.”
“The MFSA regulates EMIs under the Financial Institutions Act, with a full imputation tax system and strong experience in payments, crypto and iGaming. It requires two directors and real substance on the island.”
“The Central Bank of Ireland brings prestige and a large tech ecosystem, in exchange for a longer and more demanding process. Other options (the Netherlands, Cyprus) suit specific profiles.”
“If your business is mainly Spanish, the Bank of Spain may be the natural choice. We help you compare a local license with getting licensed abroad and passporting into Spain.”
Choosing the wrong jurisdiction, underestimating the substance required or improvising the application can block authorization, multiply the supervisor’s requests for information and delay your entry into the European market by months.
The most expensive mistake: choosing a country because it is trendy or looks cheap, without analyzing the model. A "cheap" jurisdiction with insufficient substance ends up costing more when the supervisor halts the application or requires the project to be redone.
Capital and substance are non-negotiable: the minimum capital of an EMI is €350,000 throughout the EU, and European regulators require effective management, a real office and real staff in the licensing country.
The passport is not automatic: the license covers the whole EEA, but each host country requires a passporting notification, which adds time and requires your operations to be ready.
Issuing electronic money or providing payment services without authorization in any EEA State can lead to the immediate shutdown of the business.
Without an active license and a safeguarding account at an EEA credit institution, there is no BIN sponsor, no IBAN and no card scheme integration.
The PSD3/PSR package will merge payment institutions and electronic money institutions. Designing the project with that transition in mind avoids having to rebuild the structure in the short term.
Before filing the application, it pays to compare jurisdictions, validate the regulatory fit (EMI, PI, PISP/AISP) and size capital, substance and timelines to your actual business model.
The Bank of Lithuania has the largest number of electronic money institutions in the EU. The reasons are practical: the entire process is handled in English, there is a newcomer program and a regulatory sandbox, and the statutory decision period is 3 months from a complete application (2 months for a restricted EMI), one of the shortest in the Union.
In practice, the full project usually takes 6 to 12 months, including the preparation before filing.
Minimum capital is harmonized across the EU because it derives from the same directives (EMD2 and PSD2):
In addition, an EMI must maintain ongoing own funds of at least 2% of its average outstanding electronic money, or the minimum capital if higher.
There is no single answer: it depends on the model, the timelines, taxation and the kind of substance you are willing to set up.
We help you score both against your specific case before you commit structure or capital.
Yes. An EMI or payment institution authorized in any EEA State can operate in the 30 countries of the European Economic Area through the EU passport, without applying for a new authorization in each country.
All it takes is a passporting notification to the home supervisor, which forwards it to the host supervisor (for example, the Bank of Spain). The passport can be exercised under the free provision of services or through a branch.
Yes. Although the company can be incorporated remotely, European regulators require real substance: effective management ("mind and management") in the country, a physical office and enough local staff, including compliance and anti-money laundering officers.
A structure that exists only on paper is one of the most common reasons for an application to be blocked or refused.
The statutory period is 3 months from a complete application; the actual process, including preparation, takes around 6–12 months. A completeness check in the first few days makes the timeline predictable.
The state fee for a full EMI application is about €1,463 (€1,235 for a restricted EMI). On top of that come the capital, legal preparation costs and the local structure (director, MLRO, office and technology).
These are simplified regimes for low volumes:
They are useful for validating a product, but scaling later requires becoming a full EMI.
DORA has applied since January 17, 2025 to all EMIs and payment institutions in the EU: it requires ICT risk management, business continuity, incident reporting and oversight of critical providers.
MiCA allows an EMI to issue e-money tokens (EMTs), with additional requirements on reserves, governance and the white paper.
PSD3/PSR, on which a provisional agreement was reached in late 2025, will merge payment institutions and electronic money institutions into a single category; it is expected to apply around 2027, with a transitional period for existing authorizations.
Yes. An EMI can offer accounts with an IBAN, digital wallets and physical and virtual prepaid cards (as an affiliate or principal member of Visa/Mastercard), always within the scope of its authorized services. It does not take deposits or grant credit the way a bank does.
If you need speed, there is a market for already licensed institutions (with a passport, banking relationships and sometimes card scheme access). It speeds up go-to-market, but it requires rigorous due diligence: regulatory history, compliance, hidden liabilities and the supervisor’s approval of the change of control.
At least two people who effectively direct the institution, who are suitable and experienced (fit & proper). In Malta, the MFSA requires at least two directors managing from the island; in Lithuania, the Bank of Lithuania looks for effective local management. The Compliance Officer and the MLRO are key roles.
A neobank operates either with its own banking license or by relying on an EMI/payment institution. An EMI does not take deposits from the public or lend out client funds: those funds must remain safeguarded. A bank can take deposits and grant credit.
The company can usually be incorporated remotely (for example, a Lithuanian UAB). Substance is another matter: for the license, the regulator expects real operations in the country, not just a registered company. We coordinate the local side with law firms in the chosen country.
Existing authorizations are expected to remain valid for a transitional period (around 24 months, extendable) after PSD3 enters into force, migrating to the unified category of payment institution authorized to issue electronic money. Designing the project with that transition in mind reduces later work.
Minimum capital is harmonized across the EU; what varies between countries is the real timeline, the language of the process, the substance required, taxation, the ecosystem and banking relationships. We help you choose before you start.
The cost and success of a European authorization do not depend only on regulatory capital, but on how well the model fits and on the quality of the application. These are the factors that weigh most.
Before committing fees and capital, we settle the regulatory fit and the jurisdiction. That way you avoid paying for structure you do not need, and you get realistic timelines.
| Jurisdiction | Supervisor | EMI capital | Realistic timeline | Language | Key strength |
|---|---|---|---|---|---|
| Lithuania | Bank of Lithuania | €350,000 | 6–12 months | English | Largest EMI hub in the EU, agile regulator, sandbox |
| Malta | MFSA + FIAU | €350,000 | ≈ 6–12 months | English | Attractive taxation; strong in payments, crypto and iGaming |
| Ireland | Central Bank of Ireland | €350,000 | 12–24 months | English | Top reputation and a major tech hub |
| Estonia | Finantsinspektsioon | €350,000 | Variable | English | Digital, but a stricter supervisor since AML was tightened |
| Spain | Bank of Spain | €350,000 | 6–12 months | Spanish | Local market and an established supervisor |
Indicative figures for comparison purposes. Minimum capital (€350,000 for an EMI; €20,000–€125,000 for a payment institution) is harmonized by the EMD2 and PSD2 directives, but fees, real timelines and substance requirements vary and change over time, so they should be validated case by case. This page is for information only and does not constitute legal advice.
Getting a license in Lithuania, Malta or another EEA State is not a formality: it means building a coherent institution that can be supervised from day one. The choice of jurisdiction and substance are the decisions that most shape the outcome.
Before drafting anything, decide on the jurisdiction based on services, timelines, taxation, language and substance. A good choice saves months; a bad one forces you to redo the project.
A real office, effective management and local staff (compliance, MLRO). Without credible substance, the regulator halts the application, however correct the documentation may look.
Operational AML/KYC, DORA, periodic reporting to the supervisor and audits must be sustained over time, not just get you through the initial authorization. And the passport requires your operations to be ready.
Is your business mainly in Spain? Compare the local license first: see the EMI license in Spain and the payment institution license, or our fintech regulation services.
An effective European EMI or payment institution license is not a dossier: it is a sequence of coherent decisions (jurisdiction, substance, safeguarding, AML/KYC and passport) demonstrated with traceability. Here is a visual panel to show how it works in practice.
1) JurisdictionLithuania, Malta, Ireland and Spain are not interchangeable. Timelines, language, taxation, banking and substance change the whole project. The decision is made before drafting the application.
2) ApplicationThe supervisor checks consistency. The program of operations, policies, governance, technology and outsourcing must fit together without contradictions, in the language of the chosen country.
3) SafeguardingIssuance and redemption flow, segregated accounts at an EEA credit institution or equivalent insurance/guarantee. Finding a safeguarding bank is a common bottleneck.
4) Passport + complianceAfter authorization, a passporting notification for each host country and ongoing compliance: operational AML/KYC, DORA, reporting and audits. A license without real operations will not survive an inspection.
Quick decisionEMI license: you issue electronic money (stored balance, prepaid card). Minimum capital: €350,000.
Payment institution license: transfers, payments or remittances without issuing electronic money (€20,000–€125,000).
PISP/AISP registration: you initiate payments or aggregate accounts without handling client funds.
A justified choice of country (Lithuania, Malta, Ireland, Spain…) based on services, timelines, taxation and substance.
Comparative analysis of jurisdictions and a memo on the chosen option.
Confirmation that the activity requires an EMI and not another type of entity (PI, PISP/AISP or an unregulated activity).
Regulatory fit report and description of the actual electronic money service.
Local office and staff, effective management in the country and fit and proper directors.
Office lease, organization chart, appointments and fit & proper questionnaires.
Issuance and redemption flow, segregated accounts at an EEA credit institution or equivalent insurance.
Safeguarding policy, bank agreements and reconciliation procedures.
Risk assessment, onboarding, monitoring and reporting proportionate to the profile.
AML/CFT manual, KYC files, alert log and training evidence.
Spot them before filing the application to avoid costly requests for information.
If you are comparing jurisdictions for an EMI or payment institution license, these terms come up in the application, in internal policies and in dealings with the supervisor.
An institution authorized to issue electronic money (wallets, prepaid cards, balances) and provide payment services. Minimum capital of €350,000 across the EU.
Provides payment services without issuing electronic money. Minimum capital of €20,000, €50,000 or €125,000 depending on services. Regulated by PSD2.
The right to operate in the 30 countries of the European Economic Area with a single authorization, after notifying the home supervisor. Under the free provision of services or through a branch.
The obligation to protect client funds through segregated accounts at an EEA credit institution or equivalent insurance/guarantee. A central part of the application.
Effective management, a real office and real staff in the licensing country. European regulators do not authorize structures that exist only on paper.
In Lithuania, an EMI with no minimum capital, limited to operating within the country (cap of €900,000 in average e-money). In Malta, a "small issuer" of up to €2,000,000. No EU passport.
Regulation (EU) 2022/2554, applicable since January 2025: ICT risk management, business continuity, incident reporting and oversight of critical providers.
Under MiCA, only credit institutions and EMIs can issue EMTs (e-money tokens), with additional requirements on reserves, governance and the white paper.
A European package, provisionally agreed in late 2025, that will merge payment institutions and electronic money institutions into a single category. Expected to apply around 2027.
Download the comparison guide: capital and entity types (EMI vs payment institution), Lithuania vs Malta vs Ireland, required substance, real timelines, the EU passport and the impact of DORA, MiCA and PSD3.
Tell us about your project and we will help you choose between Lithuania, Malta, Spain or another jurisdiction, and structure the license in the most operational and fastest way possible.
Electronic money institutions and payment institutions operate in the EU under a harmonized framework: Directive 2009/110/EC (EMD2) for electronic money and Directive (EU) 2015/2366 (PSD2) for payment services. That is why minimum capital and core obligations are equivalent in Lithuania, Malta, Ireland or Spain; what changes is the national supervisor, the timeline, the language of the process and the practical substance requirements.
An EMI requires €350,000 of initial capital and ongoing own funds of at least 2% of average outstanding electronic money. A payment institution requires between €20,000 and €125,000 depending on services. These thresholds are common to all Member States because they derive directly from the European directives.
The Bank of Lithuania (Lietuvos bankas) has the largest number of EMIs in the EU. It stands out for its English-language process, its newcomer program and its sandbox, and for a statutory decision period of 3 months from a complete application. There is also the restricted-activity EMI, with no minimum capital but limited to Lithuanian territory and without an EU passport.
In Malta, EMIs are authorized under the Financial Institutions Act (Cap. 376) and the MFSA rules (FIR/03), with AML supervision by the FIAU. At least two directors must run the business from Malta, and local substance is required. The full imputation tax system is attractive for many international groups.
DORA has been mandatory since January 2025 for all EMIs and payment institutions in the EU. MiCA allows an EMI to issue e-money tokens with additional requirements. The PSD3/PSR package, on which a provisional agreement was reached in late 2025, will merge payment institutions and electronic money institutions and is expected to apply around 2027, with a transitional period for existing authorizations.
Key legislation, linked to the official text:
Legislation and links reviewed in .