Language
The whole process in English
"English is an official language in Malta and the legal system has a strong Anglo-Saxon influence. Documentation, dealings with the MFSA and contracts are naturally handled in English."
EMI License in Malta
We structure your authorization as an electronic money institution before the MFSA, under the Financial Institutions Act: regulatory fit, Maltese company, capital, safeguarding of funds, AML/CFT with the FIAU, governance with effective management in Malta, DORA and a passport to the entire European Economic Area. All in English, an official language of the country.
Free consultation
We reply within 24 h
- Full EMI capital
- €350,000
- Own funds on outstanding e-money
- 2%
- Passport countries (EEA)
- 30 countries
- Maltese supervisor
- MFSA
Services
Requirements for an EMI license in Malta
Six building blocks that make up a solid, defensible application to the MFSA to operate as an electronic money institution and passport across the EU.
Regulatory fit
Full EMI, small e-money issuer or payment institution?
Before applying, we confirm which type fits: a full EMI (with a passport), a small e-money issuer (a simplified regime for low volumes) or a payment institution. That decision shapes capital, scope and timelines.
Compare jurisdictions →
Full EMISmall issuerPayment institution
Application
Application to the MFSA
We prepare the application under the Financial Institutions Act and Rule FIR/03: program of operations, policies, fit and proper assessment of directors and responses to requests for information. The process includes a pre-application stage with the regulator.
See the EMI license in Spain →
MFSACap. 376FIR/03
Company
Maltese company and effective management
Incorporation of the Maltese private limited company, with at least two directors and effective management (mind and management) in Malta, plus a real office and staff. The MFSA requires substance, not paper structures.
Learn more →
Maltese Ltd2 directors
Operations
Safeguarding, cards and prepaid
Issuance and redemption flow, segregated safeguarding accounts and card programs. Malta is an established payments and prepaid hub, with a mature ecosystem of providers and BIN sponsors.
Learn more →
SafeguardingCardsPrepaid
AML/CFT
AML/KYC and the FIAU
Risk assessment, onboarding, monitoring and reporting. Having strengthened its AML framework, Malta is particularly demanding: the FIAU and the MFSA closely review the AML/CFT component and the suitability of the MLRO.
Learn more →
FIAUMLRO
DORA
DORA and EU passport
Digital operational resilience framework (DORA, mandatory since January 2025) and passport notification to operate in the 30 EEA countries (including Spain) under the free provision of services or through a branch.
Learn more →
DORAEEA passport
Why Malta
A European payments hub that works in English
Malta combines an English-language financial framework, a single regulator (the MFSA), a track record in payments and cards and an attractive full imputation tax system. It is a classic gateway to the European market for international fintechs.
Regulator
The MFSA as a one-stop shop
"The Malta Financial Services Authority authorizes and supervises financial institutions, with a pre-application stage that lets you align the project with the regulator before filing the formal application."
Taxation
Full imputation system
"Malta applies a full imputation system which, through a refund mechanism for shareholders, can significantly reduce the effective tax burden, subject to conditions. It should be validated with a tax advisor."
Ecosystem
A track record in payments and cards
"A mature ecosystem of card programs, prepaid, safeguarding banks and specialist providers speeds up setting up the real operations of a Maltese EMI."
Why it matters
Why do EMI license applications in Malta fail?
The MFSA is accessible but rigorous, especially on substance and anti-money laundering. Most roadblocks do not come from the rules but from inconsistent applications, insufficient management in Malta or a weak AML component.
Insufficient mind and management: registering a company is not enough. Without effective management, an office and real staff in Malta (including the MLRO), the MFSA will stall the application. This is the most common reason for rejection.
Weak AML component: having strengthened its AML framework, Malta is very demanding. The FIAU and the MFSA closely examine the AML/CFT system; a generic manual or an MLRO without real availability will block the license.
Underestimating timelines and the preliminary stage: the process includes a pre-application with the regulator. An incomplete or inconsistent application triggers new requests for information and stretches the real timeline to 6–12 months.
EMI capital
€350,000
Minimum initial capital for a full EMI, plus ongoing own funds of at least 2% of average outstanding electronic money.
Small issuer
No passport
The small electronic money issuer regime (≤ €2,000,000 in average e-money) eases requirements, but it only operates in Malta and does not allow an EU passport.
Without authorization
Infringement
Issuing electronic money without a prior MFSA license is an infringement. Operations must wait until authorization is granted.
Is Malta the right jurisdiction for you?
Before incorporating the company, it is worth validating the fit (full EMI, small issuer or payment institution) and comparing Malta with Lithuania, Ireland or Spain based on your model, your tax position and your timelines.
Frequently asked questions
EMI license in Malta: common questions
How much capital do you need for an EMI in Malta?
The minimum initial capital for a full EMI is €350,000, the same as in the rest of the EU (it derives from the EMD2 directive). In addition, the institution must maintain ongoing own funds of at least 2% of average outstanding electronic money.
The small electronic money issuer regime eases requirements for low volumes, but it only operates in Malta and without a passport.
Who regulates EMIs in Malta?
The MFSA (Malta Financial Services Authority) authorizes and supervises electronic money institutions under the Financial Institutions Act (Cap. 376) and Rule FIR/03. For anti-money laundering, the FIAU (Financial Intelligence Analysis Unit) is the competent authority.
How long does it take to get an EMI license in Malta?
The EU framework provides for a decision within about 3 months of a complete application, but the Maltese process includes a pre-application stage with the MFSA. Including preparation, the full process usually takes between 6 and 12 months, depending on the complexity of the model.
How much does an EMI license in Malta cost?
The MFSA charges application fees and annual supervisory fees that depend on the license type and business volume. The real cost of the project also includes the capital, the fees for preparing the application and the local structure: company, directors, MLRO, office, technology and safeguarding bank.
It is best to budget case by case, because fees are updated periodically.
What tax advantage does Malta offer?
Malta applies a full imputation system: corporate income tax is complemented by a shareholder refund mechanism that, in certain cases, significantly reduces the effective tax burden. It depends on the shareholding structure and several conditions, so it must be validated with a tax advisor.
Do I need effective management and employees in Malta?
Yes. The MFSA requires real substance: a Maltese company with at least two directors, effective management (mind and management) in Malta, a physical office and sufficient local staff, including the compliance and anti-money laundering officers (MLRO).
Can the Maltese license be used to operate in Spain and the EU?
Yes. An EMI authorized in Malta can operate in the 30 countries of the European Economic Area through the EU passport, with a notification to the MFSA that is forwarded to the host supervisor (for example, the Bank of Spain). It can be exercised under the free provision of services or through a branch.
Why is Malta so strict on anti-money laundering?
After a period of intense international scrutiny, Malta strengthened its AML framework, and today the FIAU and the MFSA are particularly rigorous. For an EMI, this means a robust AML/CFT framework, a suitable and active MLRO and real evidence of controls. Done well, it is a guarantee of soundness for banks and partners.
People also ask
Company, buying a license and comparisons
What type of company is used in Malta?
The usual form is the Maltese private limited company (Ltd), incorporated under the Companies Act. The license then requires effective management and real substance in Malta.
Is it better to buy an already authorized Maltese EMI?
There is a market for already licensed Maltese EMIs. It speeds up go-to-market, but it requires rigorous due diligence (regulatory history, AML compliance and hidden liabilities) and MFSA approval of the change of control.
Malta or Lithuania for my EMI?
Lithuania stands out for its ecosystem, SEPA access via CENTROlink and a fast process; Malta for its imputation tax system, English and its track record in cards. Compare them on the EMI license in Lithuania page and in the European comparison.
How many directors does the MFSA require?
The MFSA expects effective local management, with at least two directors who meet the suitability (fit & proper) standard, and dual control. The Compliance Officer and the MLRO must be able to genuinely perform their roles from Malta.
What ongoing obligations does a Maltese EMI have?
Periodic reporting to the MFSA, operational AML/KYC under FIAU supervision, DORA compliance, audit, record-keeping and maintaining safeguarding and own funds. The license is the start of supervised operations.
Is there an equivalent simplified regime in Spain?
Yes, the small issuer concept is similar to that of the simplified-regime electronic money institution. We explain it on our pages on the simplified electronic money institution and the EMI license in Spain.
Options and cost
Full EMI vs small e-money issuer in Malta
Malta offers two routes. The choice depends on whether you need an EU passport from the outset or prefer to validate the product within the country with lighter requirements.
What drives the real cost
MFSA fees are only one part; most of the cost lies in the capital, the local structure and preparing the application.
- Capital
- €350,000 (full EMI). The small issuer has lighter capital requirements.
- MFSA fees
- Application + annual supervision, depending on license type and volume.
- Local structure
- Maltese company, ≥2 directors, MLRO, office, technology and safeguarding.
- Recurring
- Reporting, AML/CFT (FIAU), DORA, audit and ongoing own funds.
How we run the project
We first settle the regulatory fit and the right license type, and we coordinate the local work in Malta so that the application arrives complete and aligned with the MFSA.
- Review of the model and choice between a full EMI, a small issuer or a payment institution.
- Incorporation of the Maltese company, local substance and pre-application with the MFSA.
- Safeguarding, AML/CFT with the FIAU and passport notification to target markets.
| Feature | Full EMI | Small e-money issuer |
|---|---|---|
| Legal basis | Financial Institutions Act + FIR/03 | Simplified regime (FIR/03) |
| Minimum capital | €350,000 | Lighter requirements |
| Geographic scope | Entire EU / EEA | Malta only |
| EU passport | Yes | No |
| Average outstanding e-money limit | No specific limit | ≤ €2,000,000 |
| AML supervision | FIAU | FIAU |
| Best for | Scaling in Europe with a passport | Validating the product within Malta |
Indicative figures. The €350,000 capital derives from the EMD2 directive and is common across the EU; the fees, limits and conditions of the small issuer regime are set and updated by the MFSA, and taxation depends on each structure. This page is for information only and does not constitute legal or tax advice.
Practical guide
How to get an EMI license in Malta: a practical guide
It is not just a formality: it means building a coherent Maltese institution that can be supervised from day one. Effective management in Malta and the AML framework are the decisions that most shape the outcome.
License type first, application second
Choose between a full EMI, a small e-money issuer or a payment institution depending on whether you need a passport. Capital, scope and timelines in Malta all depend on that decision.
What the MFSA watches most closely
Effective management (mind and management), at least two directors, an office and local staff. Without credible substance in Malta, the MFSA stalls the application.
A solid AML/CFT framework from the design stage
Risk assessment, a suitable MLRO and real evidence. The FIAU and the MFSA are particularly demanding; AML cannot be a last-minute annex.
Checklist: EMI license in Malta in 10 steps
- Regulatory fit: confirm a full EMI, a small e-money issuer or a payment institution.
- Incorporation of the Maltese company (Ltd) and shareholder structure.
- Capital: deposit of the €350,000 (full EMI) or planning for the small issuer route.
- Local substance: effective management, ≥2 directors, office and staff in Malta.
- Key functions: a suitable, active Compliance Officer and MLRO.
- Pre-application with the MFSA and a three-year program of operations in English.
- Safeguarding of funds: segregated accounts and, where applicable, a card program.
- AML/CFT framework (FIAU): risk assessment, onboarding, monitoring and training.
- DORA and outsourcing: ICT risk management, continuity, SLAs and critical providers.
- Passport and ongoing compliance: notification to target markets and continuous reporting.
Not sure whether Malta is your best option? Compare in the EMI license in Europe guide, or review Lithuania or the EMI license in Spain.
The process step by step
Authorization by the MFSA
An effective EMI license in Malta is a sequence of consistent decisions (Maltese company, substance and effective management, safeguarding, AML with the FIAU and passport) that are demonstrated with a clear audit trail. Here is the real path.
1) CompanyCompany and substance: the foundation
Incorporation of the Maltese company and building real substance: effective management, two directors, an office and local staff. It is the foundation on which the MFSA assesses everything else.
- Private limited company (Ltd) and shareholders
- Mind and management in Malta
- Compliance Officer and MLRO
2) ApplicationPre-application and application
A preliminary stage with the MFSA to align the project, then the formal application under the Financial Institutions Act and FIR/03: program of operations, policies, governance and technology.
- Pre-application with the MFSA
- 3-year program of operations
- Fit and proper assessment of directors
3) SafeguardingSafeguarding and payment operations
Segregated accounts with an EEA credit institution and, where applicable, card and prepaid programs supported by the Maltese ecosystem. This is what turns the license into real operations.
- Safeguarding accounts
- Card programs / BIN sponsor
- Issuance and redemption flow
4) Passport + compliancePassport and life under supervision
After authorization, passport notification to target markets (including Spain) and ongoing compliance: AML/KYC under the FIAU, DORA, reporting and audit. Supervisors review evidence, not intentions.
Tip: plan your passport target countries from the outset; each notification adds time before you can operate there.
Quick decisionPractical map: which license type suits you?
Scaling in the EU
Full EMI: €350,000 in capital and a passport to the 30 EEA countries.
Validating a product
Small e-money issuer: lighter requirements, Malta only, ≤ €2 million and no passport.
Payments only
Payment institution: if you do not issue electronic money (transfers, payments, remittances).
Malta playbook
The Maltese license in practice
Company and substance
A Maltese company with effective management, two directors and real staff in Malta.
Articles of association, office lease, organization chart and local employment contracts.
Program of operations
A business model in English, consistent with customers, channels, technology and partners.
Detailed business plan, 3-year projections and third-party contracts.
Safeguarding and payments
Issuance and redemption flow, segregated accounts and, where applicable, a card program.
Safeguarding policy, banking agreements and BIN sponsor agreements.
AML/KYC (FIAU)
Risk assessment, onboarding, monitoring and an active MLRO in Malta.
AML/CFT manual, KYC files, alert log and MLRO appointment.
Governance and DORA
Fit and proper directors, dual control and an ICT resilience framework (DORA).
Fit and proper questionnaires, ICT risk map and incident register.
Common mistakes that delay or block the license
Spot them before filing the application with the MFSA.
- Incorporating the company without real effective management in Malta (mind and management).
- Submitting a weak AML component: the FIAU and the MFSA examine it closely.
- Skipping the pre-application stage, or reaching it without a defined project.
- An MLRO or directors who cannot demonstrate that they are fit and proper or really available in Malta.
- Choosing the small e-money issuer route without foreseeing that it allows neither a passport nor scaling beyond Malta.
Working glossary
Key concepts: EMI license in Malta
If you are structuring an EMI license in Malta, these terms come up in the application, in dealings with the MFSA and the FIAU and in day-to-day operations.
EMIBasics
Electronic Money Institution
An institution authorized to issue electronic money (wallets, prepaid cards, balances) and provide payment services. Minimum capital of €350,000 for a full EMI.
Supervisor: MFSA.
MFSASupervisor
Malta Financial Services Authority
Malta's single financial regulator. It authorizes and supervises EMIs and payment institutions, with a pre-application stage before the formal application.
Regulatory one-stop shop.
FIAUAML
Financial Intelligence Analysis Unit
Malta's anti-money laundering authority. Since the AML framework was strengthened, it has been particularly rigorous with financial institutions.
Examines the AML/CFT framework.
Cap. 376Law
Financial Institutions Act
The Maltese law that regulates financial institutions, including EMIs, supplemented by Rule FIR/03 on electronic money.
Legal basis for the license.
Small issuerLicense type
Small e-money issuer
A simplified regime for low volumes (≤ €2,000,000 in average e-money), with lighter requirements. It only operates in Malta and does not allow an EU passport.
For validating a product before scaling.
Mind & managementSubstance
Effective management
The requirement that the institution's actual management be exercised from Malta: directors present, decisions taken and effective control in the country.
Key for the MFSA.
MLROAML/CFT
Money Laundering Reporting Officer
The person responsible for anti-money laundering. They must be fit and proper and able to perform the role effectively from Malta, with evidence of their activity.
A key role for the FIAU.
PassportEEA
EU passporting
The right to operate in the 30 EEA countries with the Maltese license, after notifying the MFSA. Under the free provision of services or through a branch.
Only with a full EMI, not with the small issuer.
Full imputationTaxation
Full imputation
A Maltese tax system that combines corporate income tax with a refund mechanism for shareholders. It can reduce the effective tax burden, subject to conditions.
Always validate with a tax advisor.
Free guide
Guide: EMI license in Malta step by step
Download the guide with the full roadmap: full EMI vs small issuer, capital and own funds, substance and effective management, imputation taxation, MFSA timelines and the EU passport.
- Full EMI vs small e-money issuer: when to choose each
- Capital, MFSA fees and local structure (Ltd, MLRO)
- Imputation system, FIAU and real timelines
- EU passport: operating in Spain and the EU
Contact
Book a call
Tell us about your project and we will explain how to structure your EMI license in Malta (or whether another jurisdiction suits you better) with the shortest possible processing time.
Regulatory framework for the EMI license in Malta
Electronic money institutions in Malta are authorized and supervised by the MFSA (Malta Financial Services Authority) under the Financial Institutions Act (Cap. 376) and Rule FIR/03 on electronic money, which transpose the harmonized European framework: Directive 2009/110/EC (EMD2) and Directive (EU) 2015/2366 (PSD2). Anti-money laundering falls to the FIAU. That is why the minimum capital and the core obligations are the same as in the rest of the EU, while the language (English), the pre-application stage and taxation give Malta its own profile.
Capital and own funds
A full EMI requires €350,000 of initial capital and ongoing own funds of at least 2% of average outstanding electronic money. The small electronic money issuer regime (≤ €2,000,000 in average e-money) eases requirements, in exchange for operating only in Malta and without a passport.
Regulators: MFSA and FIAU
The MFSA is the single financial regulator and handles authorization with a pre-application stage that allows the project to be aligned before the formal application. The FIAU supervises anti-money laundering; having strengthened its AML framework, Malta is particularly demanding in this area.
Substance and governance
A Maltese company with effective management (mind and management) in Malta, at least two fit and proper directors, an office and local staff is required. Real substance is the factor that most determines the success of the application.
Taxation and ongoing obligations
Malta applies a full imputation system which, through refunds to shareholders, can reduce the effective tax burden (subject to conditions; it should be validated with a tax advisor). On top of this come, since January 2025, the DORA Regulation, periodic reporting to the MFSA, the AML/CFT framework and maintaining safeguarding and own funds.
Licenses in Europe
Fintech regulation services
Official sources
Key legislation, linked to the official text:
- Directive 2009/110/EC of September 16, 2009, on the taking up and pursuit of the business of electronic money institutionsEUR-Lex · Official Journal of the EU
- Directive (EU) 2015/2366 of November 25, 2015, on payment services in the internal market (PSD2)EUR-Lex · Official Journal of the EU
Legislation and links reviewed in .