Electronic money issuer licence in Europe is a permit released by the national financial regulator of a European Union member state to issue electronic money and offer related payment services. It allows you to officially work with electronic balance accounts, issue prepaid products, open customer accounts and make payments within the EU and EEA through service passporting mechanisms.
The existence of a valid AEMI/EMI licence forms a ready-made regulatory shell, which is why such structures are often viewed as business for sale or platform for rapid entry into the financial services market.
Choosing a region for EMI licence is not simply a matter of formal firm formation. It determines the market entry strategy, cost of capital, timing of authorisation and future economic model of the project. Understanding the differences between EU countries allows you to optimise costs, minimise regulatory risks and ensure sustainable business development.
Concept and significance of EMI licence
EMI licence grants right to:
- issue and manage electronic money;
- open and maintain electronic wallets and accounts;
- offer payment services and cross-border settlements;
- use SEPA mechanisms and other elements of payment infrastructure in the EU.
Depending on volume of business, there are two main types of licences:
- Small EMI – a limited licence with restrictions on transaction volumes and account balances, suitable for businesses operating within a single country;
- Full EMI – a full licence with the ability to freely passport across the EU and EEA; requires more capital and comprehensive operational procedures.
For 2025, practice of European regulators shows that for projects intending to scale up to several EU/EEA countries, Full EMI usually proves to be economically justified, despite greater complexity of application process.
Key criteria for choosing jurisdiction
When selecting a country in which to obtain an EMI licence, regulatory environment, financial requirements, operational context and strategic business objectives are assessed. The main groups of factors are:
Regulatory requirements and practices.
EU directives are common to all EU countries, but practical implementation varies depending on the regulator. Important factors include the regulator’s formalism, willingness to engage in dialogue in English, depth of analysis of business model and IT architecture, and requirements for local presence.
Authorised capital and financial requirements.
Minimum authorised capital for a Full EMI in the EU is set at €350,000. Depending on the country, additional capital requirements may be added depending on volume of operations, capital structure and financial stability.
Application process and review times.
Different countries have different practices for interacting with applicants, methods for submitting documents, number of rounds of questions, and typical review times. This affects launch planning and synchronisation with project funding.
Taxation and support costs.
After assessing regulatory conditions, it is important to consider corporate tax, external audit requirements, accounting support costs, and regular reporting costs – these factors affect current operating expenses.
Management and residency requirements.
Financial regulators require that management have relevant experience, impeccable business reputation, and be involved in management. Requirements vary in terms of proportion of resident directors and physical presence of management.
AML/KYC and compliance.
Anti-money laundering processes and customer identification are key elements assessed by regulators. The strictness of AML/KYC procedures affects time required to prepare documents and requirements for monitoring systems.
IT infrastructure and cybersecurity.
Modern regulatory requirements include IT system resilience, PCI DSS compliance, disaster recovery plans, and data protection.
External factors.
New regulatory trends, such as the consequences of Brexit, are increasing requirements for internal documentation, risk disclosure and model resilience to technological threats. A UK licence no longer provides automatic access to the EU market.
Regulatory features of individual countries
Practice of a number of European jurisdictions shows how these factors are implemented in practice.
Lithuania.
The Bank of Lithuania is considered one of the most active and transparent regulators in the fintech sector. It is characterised by relatively quick dossier review, dialogue in English, and clear requirements for business plans, financial statements, and descriptions of operational risks. This jurisdiction is attractive for scaling payment services across the EU.
Portugal.
The regulator pays particular attention to client fund protection models and audit procedures. Requirements for internal documentation and IT architecture are relatively high, which is reflected in the volume of documentation required.
Germany.
BaFin is considered one of the strictest regulators in Europe. It thoroughly analyses financial stability, capital sources, top management requirements and risk structure. This jurisdiction is suitable for companies focused on the corporate segment and long-term presence, but it requires significant support costs.
Czech Republic.
Czech National Bank combines moderate strictness of control with more predictable review times for well-prepared dossiers. The regulator requires some staff and office space to be located locally, but provides a clear framework for interaction.
Practical steps after choosing a jurisdiction
After selecting a country, the action plan includes:
- developing detailed business plan and financial forecasts for several years;
- preparing internal documentation;
- registering legal entity and forming management structure;
- collecting and submitting a complete set of documents to regulator;
- interacting with regulator during review process;
- after obtaining the licence – organising regular reporting, keeping processes up to date and preparing for inspections.
Choosing a jurisdiction for an EMI licence in Europe is a complex decision that must be based on strategic objectives of the project, structure of business, its financial capabilities and planned geographical scope of its activities. Formally, all EU countries operate on the basis of the same directives, but their regulatory practices vary.
In 2025, key jurisdictions such as Lithuania, Portugal, Germany, and Czech Republic remain on the market, each with its own advantages and limitations. The optimal choice is achieved by comparing regulatory requirements, financial costs, operational readiness, and scaling goals.
FAQ
What does EMI licence in Europe offer in practice?
EMI licence allows you to issue electronic money, open and maintain customer accounts, make payments and transfers, and connect to SEPA infrastructure.
How does Small EMI differ from Full EMI, and when does it make sense to obtain a full licence?
Small EMI is suitable for limited business within a single country and imposes limits on transaction volumes and customer balances. Full EMI requires more authorised capital and more complex preparation, but gives the right to scale freely within the EU. Full EMI is usually chosen for projects with international plans and investment attraction.
Is it possible to choose a country with a “simpler” licence and work throughout Europe?
Formally, yes, a licence obtained in one EU country can be passported to other countries. In practice, regulators in host countries may closely evaluate business models, AML/KYC procedures and actual management. Therefore, choosing jurisdiction with a lenient regulator does not exempt you from high compliance requirements.
How long does it take to obtain an EMI licence?
The timeframe depends on the country and the quality of the documents prepared. On average, the process takes between 9 and 12 months. The main delays arise from refinement of business plan, description of IT systems, AML procedures, and questions for management. Obtaining a licence quickly is only possible with a pre-established structure and experience working with the regulator.
