
Arina Jermitsova
Business Development Manager
Business Development Manager, leading the mandate engagement function across crypto, FinTech, gaming, and international corporate structuring verticals.
Phone +372 53 42 2033
Book a Free Consultation
Book a Free ConsultationAn EMI license is the European authorization that lets a company issue electronic money and provide payment services. EMI stands for electronic money institution. The rules come from the EU’s Second Electronic Money Directive (EMD2), which works alongside the Payment Services Directive (PSD2).
If you are building a wallet, neobank, payment processor, or remittance service for Europe, the EMI license is the usual route to market. It also covers issuing e-money tokens (EMTs) under MiCA for stablecoin projects.
LegalBison manages the full project: jurisdiction choice, company formation, capital, compliance program, application, and banking, all through one point of contact. Book a free consultation. We will tell you whether the EMI route fits your business, or whether another structure serves you better.
Explore our EMI licensing packages tailored for payment providers, wallet operators, and Web3 businesses. Start with a free consultation to scope your project details or select full-service support for complete end-to-end setup and launch.
| Compare plans | ||
|---|---|---|
| Fit & Jurisdiction Assessment | Included | Included |
| Jurisdiction Advisory | Included | Included |
| Upfront Pricing & Timeline Scoping | Included | Included |
| Company Formation | Not included | Included |
| Capital Planning | Not included | Included |
| Compliance Program Build | Not included | Included |
| Application & Regulator Dialogue | Not included | Included |
| Banking Setup & Go-Live | Not included | Included |
| Post-Licensing Support | Not included | Included |

Arina Jermitsova
Business Development Manager
Business Development Manager, leading the mandate engagement function across crypto, FinTech, gaming, and international corporate structuring verticals.
Phone +372 53 42 2033

FinTech License
Consulting Team
Our team of experienced professionals to assist you with any question and project pertaining to FinTech projects.
Phone +44 20 4577 0974
Types of banking licenses
| EMI | Payment Institution | Bank | |
|---|---|---|---|
| Issue e-money and run e-wallets | Yes | No | Yes |
| Execute payment transactions | Yes | Yes | Yes |
| Take deposits | No | No | Yes |
| Lend | No (credit never from customer funds) | No | Yes |
| Customer funds protection | Safeguarded (segregated or insured) | Safeguarded | Deposit guarantee scheme |
| Minimum initial capital (EU baseline) | €350,000 | €20,000 - €125,000 by service | At least €5,000,000 |
A gateway to payment & banking business
An authorized EMI issues electronic money (stored value backed one-to-one by the funds customers paid in) and runs the payment services attached to it. EMD2 permits:
An EMI cannot take deposits, cannot pay interest on e-money balances, and cannot lend out customer funds. Customer money is safeguarded, not banked: e-money is not a deposit, so deposit guarantee schemes do not cover it.
More on this topic: Difference between ART vs. EMT in MiCA
A payment institution (PI) executes payments but cannot issue electronic money. A bank can do everything an EMI does, plus take deposits and lend. The EMI license sits in the middle: it stores value without being a bank.
The €350,000 figure is the flat EMD2 baseline for full EMI authorization, set in Article 4 of Directive 2009/110/EC. Payment institution capital is tiered by service under PSD2: €20,000 for money remittance, €50,000 for payment initiation, €125,000 for account-based services. Banking capital starts at €5 million under EU banking rules; most bank launches need far more.
One EMI nuance: EMD2 lets an EMI grant credit related to payment services, for up to 12 months, at market rates, and never from safeguarded customer funds (Article 6(1)(b)).
The authorization file must show the regulator:
Regulators also require ongoing own funds: at least 2% of average outstanding e-money, plus method-based capital for payment services (EMD2 Article 5).
The baseline is the same across the EEA. National regulators set application detail, fees, and tempo:
| Jurisdiction | Regulator | Capital baseline | Notes |
|---|---|---|---|
| Lithuania | Bank of Lithuania | €350,000 | State levy €1,463; assessment up to 3 months from a complete file. Restricted-activity license: no minimum capital, e-money capped at €900,000 a month, Lithuania only, levy €1,235, 2-month assessment. Details |
| United Kingdom | FCA | €350,000 | Set in the Electronic Money Regulations 2011. Small EMI registration: no €350,000 capital; monthly transaction and outstanding e-money caps; no EEA passport |
| Poland | KNF | €350,000 | EMD2 baseline; national requirements apply |
| Cyprus | CySEC | €350,000 | EMD2 baseline; national requirements apply |
| Malta | MFSA | €350,000 | EMD2 baseline; national requirements apply |
| Estonia | Estonian FSA | €350,000 | EMD2 baseline; national requirements apply |
| Ireland | Central Bank of Ireland | €350,000 | Small EMI tier: €125,000 capital, under €3m monthly transactions, registration only (no passport) |
EMD2 also allows a small-EMI route: registration instead of full authorization where average outstanding e-money stays under €5 million (Article 9). National versions differ: the UK small EMI and Lithuania’s restricted license are examples.
The rules are changing. The EU reached political agreement on its new payment package (PSD3 and the Payment Services Regulation) in November 2025, and the Council published the final texts in April 2026. Formal adoption was still pending in August 2026. The package replaces EMD2 and PSD2 and merges the EMI and payment institution regimes into a single authorization. It is expected to apply during 2028.
Firms licensed under the current regime keep operating through a transitional period of about two years, extendable to 30 months, then re-apply for authorization under the new rules. Member states may convert existing licenses automatically.
A license obtained now remains a sound basis to build on.
Core Cost Preparation Breakdown
Cost and timeline
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EMI Licensing services with us
Company formation and licensing sit under one roof at LegalBison. See our services overview for the full scope.
| Route | Regulator | Why founders choose it |
|---|---|---|
| Lithuania | Bank of Lithuania | Established EMI sector, clear assessment windows |
| United Kingdom | FCA | Mature market; separate regime since Brexit |
| Poland | KNF | Established licensing market, large local economy |
| Cyprus | CySEC | Gateway to the EU from the Middle East |
| Malta | MFSA | Established fintech framework |
| Estonia | Estonian FSA | Digital-first regulator |
Passporting is the reason one license is enough. A license from any EEA member state covers the whole EEA (the 27 EU member states plus Iceland, Liechtenstein, and Norway). The home regulator approves the license; a passport notification lets you operate in other member states without further applications. Authorized payment and e-money institutions, their agents, and branches are listed in the EBA register (a register entry confirms, but does not create, authorization).
The UK is outside this system. A UK EMI cannot passport into the EEA, and an EEA EMI cannot passport into the UK. For EEA-wide business, license in the EEA; for UK-only business, license in the UK.
| Route | Regulator | Why founders choose it |
|---|---|---|
| Lithuania | Bank of Lithuania | Established EMI sector, clear assessment windows |
| United Kingdom | FCA | Mature market; separate regime since Brexit |
| Poland | KNF | Established licensing market, large local economy |
| Cyprus | CySEC | Gateway to the EU from the Middle East |
| Malta | MFSA | Established fintech framework |
| Estonia | Estonian FSA | Digital-first regulator |
Passporting is the reason one license is enough. A license from any EEA member state covers the whole EEA (the 27 EU member states plus Iceland, Liechtenstein, and Norway). The home regulator approves the license; a passport notification lets you operate in other member states without further applications. Authorized payment and e-money institutions, their agents, and branches are listed in the EBA register (a register entry confirms, but does not create, authorization).
The UK is outside this system. A UK EMI cannot passport into the EEA, and an EEA EMI cannot passport into the UK. For EEA-wide business, license in the EEA; for UK-only business, license in the UK.
The right path forward, regardless of project stage
Get in touch with LegalBison experts for a dedicated EMI Licensing service.

Arina Jermitsova
Business Development Manager
Business Development Manager, leading the mandate engagement function across crypto, FinTech, gaming, and international corporate structuring verticals.
Phone +372 53 42 2033

FinTech License
Consulting Team
Our team of experienced professionals to assist you with any question and project pertaining to FinTech projects.
Phone +44 20 4577 0974