We structure and defend your electronic money institution project before the Bank of Spain to secure your EMI license in Spain: regulatory fit analysis, programme of operations, complete application file, safeguarding of funds, AML/CFT, corporate governance and ongoing compliance.
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Six building blocks that make up a solid, consistent and defensible application to the Bank of Spain to operate as an electronic money institution.
We analyze whether your model must apply for an EMI license, whether it fits another financial license (PI, PISP, AISP) or whether it needs a different contractual structure before you start issuing electronic money.
We prepare the key documents of the EMI application file: programme of operations, policies, annexes, key functions, evidence and responses to information requests, for a stronger authorization process.
We design a defensible organization for the EMI: directors, key functions, segregation of duties, reporting and a risk map proportionate to the e-money business.
We review the issuance and redemption flow for electronic money, reconciliations, incident handling, critical providers and safeguarding measures so the model stands up to real supervision.
We implement an anti-money laundering framework tailored to the EMI: risk assessment, onboarding, monitoring, training, reporting and operational evidence.
We put outsourcing, SLAs, business continuity and DORA compliance in order so that your EMI license works in practice, not just on paper.
Wallets, prepaid platforms, fintechs issuing electronic money or operators seeking their own license: each project has its own regulatory fit and its own specific requirements.
"Before opening the application file, you need to confirm whether your model really qualifies as an EMI and what kind of e-money issuance you carry out. That decision shapes everything else."
"An EMI license is not won with nice-looking documents: you need consistency between business, governance, policies, technology, third parties and evidence of issuance and redemption."
"The operating structure must hold up in practice: funds, issuance flow, redemption, reconciliations, incidents, customer service and controls that stand up to review."
"Authorization is not the end. An EMI needs working AML/KYC, internal control, reporting, training and constant monitoring from the first day of issuance."
Operating without a license, filing an inconsistent application or improvising ongoing compliance can block the operations, investment and banking relationships of your e-money fintech.
The most common mistake: launching a wallet or prepaid solution without first establishing whether the activity requires an EMI license. The confusion surfaces once the product is already built, and the cost of fixing it skyrockets.
The Bank of Spain reviews consistency, not just documents: if business, policies, governance, AML/KYC and outsourcing do not fit together, the application loses strength and information requests multiply.
Safeguarding and internal control cannot be left until the end: they are central to making the EMI license defensible and to letting the institution scale its e-money issuance safely.
Issuing electronic money or providing payment services without prior authorization can lead to the immediate shutdown of the business.
Fines and personal liability for directors for issuing electronic money or providing financial services without a license.
Banks and financial partners require an active EMI license before integrating a fintech into their ecosystem: without one, agreements stall indefinitely.
Before opening the application file, it pays to validate the regulatory perimeter, get the business in order and check whether your structure can meet the requirements for authorization, issuance, safeguarding, AML/CFT and ongoing control.
An EMI license is the authorization to operate as an electronic money institution. It allows you to issue electronic money (wallets, prepaid cards, stored balances) and to provide certain payment services within the regulatory framework applicable in Spain.
The key is not just obtaining the license, but being able to run an institution that can be supervised from day one: controlled issuance, guaranteed redemption, controls that are actually performed and compliance that works in real life.
When the business model involves issuing electronic money, holding user balances within its own structure, or offering a financial product that goes beyond being a mere technology provider.
The usual mistake is launching a wallet, payment account or prepaid solution without first establishing whether the activity falls under electronic money or another license type. That confusion tends to break the project when product, partners and investment are already committed.
Each license type has a different regulatory perimeter and its own requirements, depending on the service you want to provide:
Choosing the wrong license type at the outset delays the whole process and may force you to restructure your business model.
It checks whether the application is consistent, complete and defensible: programme of operations, corporate structure, directors, key functions, internal policies, control system, issuance and redemption flow, third parties, technology and real capacity to operate.
The supervisor looks at whether the business described can be sustained by people, processes, contracts, controls and evidence that make sense together. Document consistency matters as much as the legal content.
Safeguarding of funds and the AML/CFT framework are two central pieces of an electronic money institution, not secondary annexes. They affect the quality of the application, the relationship with banking partners and the future strength of the institution.
They force you to pin down issuance, redemption, reconciliations, onboarding, monitoring, reporting, internal roles and evidence. When they are improvised, the supervisor notices quickly.
The statutory deadline for a decision is 3 months from submission of the complete application, although in practice the process can take 6-12 months depending on the complexity of the model and the quality of the application.
What makes an EMI license more expensive and slower is usually not drafting it but fixing it: redoing annexes, clarifying contradictions, answering information requests or redesigning parts of the business that had not been properly settled.
As a general rule, no. Issuing electronic money without prior authorization is a very serious infringement.
Only a few limited exceptions exist, and they must be analyzed case by case (Spain has not implemented the optional exemption regime for very small e-money volumes that EU law allows). The usual alternative while your own license is being processed is to operate under the umbrella of an already authorized institution through an agent or regulated distribution agreement.
The most important phase begins: operating as a supervised institution with ongoing compliance, internal control, incident follow-up, third-party oversight, training and reporting.
The EMI license is not the end of the project: it is the starting point of supervised e-money operations.
Yes. Once authorized by the Bank of Spain, an EMI can operate in the 30 countries of the European Economic Area through the EU passport: a passporting notification is enough, with no need for a new local authorization in each country.
Yes. An electronic money institution can offer accounts with their own IBAN, digital wallets, physical and virtual prepaid cards and domestic and international transfers, always within the scope of its authorized services.
A neobank usually operates with its own banking license or relies on an EMI or a payment institution. The key difference is that an EMI does not take deposits from the public or grant credit with its clients' funds: those funds must be safeguarded. A bank, by contrast, can take deposits and lend.
It is the mechanism that allows an EMI authorized in Spain to provide services in the rest of the EEA (under the freedom to provide services or through a branch) by notifying the supervisor, without applying for a new authorization in each Member State. It is one of the main attractions of this license.
The E-Money Directive (EMD2) lets Member States create an optional regime for small issuers (average outstanding electronic money of up to €5 million) operating domestically, with lighter requirements but no EU passport. Spain has not implemented this regime, so there is no "small EMI" license in Spain: issuing electronic money requires a full EMI authorization from the Bank of Spain.
MiCA is already in force: its rules on e-money tokens (EMTs) have applied since June 2024 and affect EMIs that issue them, with additional reserve and governance requirements. In Spain, EMTs are supervised by the Bank of Spain (the CNMV supervises other crypto-assets and CASPs). On PSD3 and the new Payment Services Regulation (PSR), the European Parliament and the Council reached an agreement at the end of 2025; the new rules are set to merge payment institutions and electronic money institutions into a single category, with application expected around 2027-2028. It makes sense to design your project with this horizon in mind.
There is no single fee: the cost depends on the regulatory capital required and the complexity of the application. We help you size it before you start.
The total cost of launching an electronic money institution combines two elements: the regulatory capital required by law and the cost of structuring the project and the application.
Before committing to fees, we settle the regulatory fit and the real scope of the project. That way you avoid paying for work you don't need and get a realistic estimate of effort and timelines.
| License type | EMI · electronic money | Payment institution (PI) | Bank | PISP / AISP |
|---|---|---|---|---|
| Minimum capital | €350,000 | From €20,000 | €18M minimum in Spain | AISP: no capital · PISP: €50,000 |
| Issues electronic money | Yes | No | Yes (and more) | No |
| Takes deposits from the public | No | No | Yes | No |
| Holds client funds | Yes, with safeguarding | Yes, with safeguarding | Yes | No |
| Supervisor | Bank of Spain | Bank of Spain | ECB / Bank of Spain | Bank of Spain |
| Typical use case | Wallets, prepaid, stored balances | Transfers, payments, remittances | Deposits, lending, banking | Open banking: payment initiation or account aggregation |
Indicative figures for comparison purposes. The exact capital and regulatory fit depend on the specific services the institution will provide; they should be validated case by case before starting the application.
An EMI license is not just a formality: it is a system that must show consistency between business model, issuance, operations, controls and evidence. The key is to build, from the outset, an institution that can withstand real supervision.
The Bank of Spain does not just review the business idea. It analyzes whether the structure can support it: fit and proper directors, key functions, consistent policies, workable controls and evidence of real operational capacity to issue electronic money.
The issuance and redemption flow, reconciliations, account segregation and incident management must be designed before the application, not as an appendix. A failure here blocks EMI authorization.
Working AML/KYC, DORA, reporting, audits and the handling of supervisory information requests must be designed to last over time, not just to get the initial EMI application through.
If you want to structure your EMI application from scratch or review the current status of your project, see our fintech regulation services or our dedicated fintech compliance practice.
An effective EMI license is not a dossier: it is a set of consistent decisions (regulatory fit, issuance and redemption, AML/KYC, governance and outsourcing) backed by traceability. Here is a visual panel to show how it works in practice.
1) FitThe goal is not to "get the EMI license faster": it is to make sure the model needs one, of what type and with what issuance perimeter. That decision shapes the whole application.
2) ApplicationThe supervisor reviews consistency. Programme of operations, policies, governance, technology and outsourcing must fit together, with no internal contradictions in the e-money model.
3) SafeguardingIssuance and redemption flow, segregated accounts, reconciliations and incidents. When it is designed late, it blocks authorization or creates structural gaps once the EMI license has been granted.
4) ComplianceWorking AML/KYC, DORA, audits and reporting turn the EMI into a real institution: follow-up, corrections and up-to-date evidence from the first day of issuance.
Quick decisionEMI license: you issue electronic money (stored balance, prepaid card). Minimum capital €350,000.
PI license: transfers, direct debits, card payments or remittances without issuing electronic money.
PISP/AISP registration: you initiate payments or aggregate bank accounts without handling client funds.
A reasoned analysis showing that the actual activity requires an EMI license and not another license type (PI, PISP, unregulated activity).
Regulatory fit report, description of the actual service and comparison of e-money license types.
A consistent description of the business, issuance, clients, channels, technology and partners that supports the supervisor's review.
Detailed business report, projections, third-party contracts and the EMI's functional organization chart.
A clear issuance and redemption flow for electronic money, account segregation, reconciliations and properly managed incidents.
Safeguarding policy, description of the flow, banking agreements and reconciliation procedures.
Risk assessment, onboarding, monitoring and reporting proportionate to the EMI's risk profile.
AML/CFT manual, KYC files, alert log and evidence of staff training.
Fit and proper directors, key functions, segregation of responsibilities and an internal control system for the EMI.
Board minutes, appointments, conflicts of interest policy, risk map and annual audit plan.
Spot them before filing your application to avoid costly information requests.
If you are structuring an EMI license, these terms come up in the application, in your internal policies and in your dealings with the supervisor. Understanding them well helps you build a consistent project.
An institution authorized to issue electronic money (wallets, prepaid cards, stored balances) and to provide related payment services. Minimum capital of €350,000.
Monetary value stored electronically, issued on receipt of funds, accepted as a means of payment by persons other than the issuer and redeemable at any time at par value.
The obligation to keep the funds received in exchange for electronic money segregated and protected against the institution's possible insolvency. A central piece of the EMI application.
The right of the e-money holder to request, at any time, redemption at par value of the funds in circulation. It must be guaranteed both contractually and operationally.
PSD2 license types for open banking: the PISP initiates payments from third-party accounts and the AISP aggregates banking information, without handling client funds or issuing electronic money.
EU regulation applicable since January 2025 that requires an ICT risk management framework, business continuity, incident reporting and oversight of critical providers.
The core document of the application: it describes the services to be provided, the issuance model, the operating structure, the clients and the partners of the future electronic money institution.
The heads of compliance, internal audit, risk and AML, who must be identified, be fit and proper and have real capacity to perform their role in the EMI.
Technology or essential service providers must be documented: contracts, SLAs, security, continuity and an exit plan for contingencies.
Download our guide covering the full process: entry requirements, the path to authorization, the pillars of the application, the full EMI compared with the EU "small EMI" regime, and the impact of MiCA and PSD3.
Electronic money institutions in Spain are mainly governed by Law 21/2011 of 26 July on electronic money, which transposes Directive 2009/110/EC (EMD2), and, on a supplementary basis, by Royal Decree-law 19/2018 on payment services. Authorization and supervision fall to the Bank of Spain, which assesses the suitability of the project, the governance structure, the robustness of the application and the real operational capacity of the future institution.
The minimum capital required for an EMI license is €350,000, significantly higher than for a payment institution. In addition, the institution must maintain sufficient own funds based on the volume of electronic money in circulation. This higher requirement reflects the greater risk of issuing electronic money compared with merely intermediating payments.
One of the most critical obligations of an EMI is to guarantee e-money holders' right of redemption at par value and at any time. Funds received in exchange for issuing electronic money must be held in segregated accounts at credit institutions or invested in secure, liquid assets. Compliance with this safeguarding obligation is subject to direct supervision.
The E-Money Directive (EMD2) allows Member States to provide an exemption regime for institutions whose average outstanding electronic money does not exceed €5 million, with lighter capital and documentation requirements but a narrower operating scope and no EU passport. Spain has not implemented this regime, so it is not an alternative to the full license: issuing electronic money in Spain requires a full EMI authorization from the Bank of Spain.
Since January 2025, the DORA Regulation has applied to all electronic money institutions authorized in the EU. It requires an ICT risk management framework, a business continuity policy, incident logging and reporting, digital operational resilience testing and oversight of critical technology providers.