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E-money License & Regulation Europe

by Alexander Malygin

5 min read


The development of a new kind of payment instrument — e-money, made it possible to provide a wider range of financial services compared to traditional payment institutions. First and foremost, we are talking about an electronic money institution (EMI) — a legal entity that has the right to issue electronic money and quasi-money, as well as to make payments related to e-money.

The E-money License issued by national financial regulators (supervisory authorities) of the European Union (EU) Member States is a prerequisite for the issuance of electronic money. It can also be considered as an alternative to a banking license in the EU since it allows to provide many banking services.

In this article, we’ll cover some key aspects of the European E-money License, how it is regulated, and where to obtain one.

Regulation Environment

The concept of a European e-money has been subject to regulation in the EU since April 2002 according to the first regulatory framework established, Electronic Money Directive 2000/46/EC (“EMD1”). Later on, with the difficulties in interpreting and applying in practice the definition of e-money, the second Electronic Money Directive 2009/110/EC (“EMD2”) was established, which repealed EMD1 and has applied since April 2011. It is a Directive that lays down certain results that must be achieved and each European Union Member State and the UK has its own version of the EMD and these versions may slightly differ from each other.

EMD2 defines e-money as follows: “electronic money” shall mean electronically, including magnetically, stored monetary value as represented by a claim on the issuer which is issued on receipt of funds to make payment transactions as defined in [the Payment Services Directive (EU) 2015/2366], and which is accepted by a natural or legal person other than the electronic money issuer.

Provision of payment services by electronic money institutions (EMIs) is regulated by the Payment Services Directive 2015/2366 (PSD2) that stipulates 8 payment services that may be provided by EMIs upon getting authorization.

Where to obtain an E-money license?

Great Britain

The procedure for obtaining a license in the UK is a complex one, as the applicant’s business is carefully scrutinized for the origin of income, legal problems, and other possible “dark facts” in the reputation. The requirements of the UK are one of the most stringent, and the cost is the most expensive.


The average duration of the license obtaining process — 9–12 months.

Baltics States

The document is issued by the national financial regulator of each country. These states attract many businesses with low requirements for the licensee, including the authorized capital and low fees for processing an application. The e-money license in Estonia, Latvia, Lithuania, allows you to carry out activities throughout the EU.

The average duration of the license obtaining process — 5–6 months.

Cyprus

The circulation of electronic money in Cyprus is controlled by the Central Bank, which also issues an e-money license in Cyprus. The licensee may be required to provide letters of recommendation from banks or reputable companies. The country has comfortable tax rates and a reputable financial and business center. An e-money license obtained in Cyprus gives the right to operate in the EU.

The average duration of the license obtaining process — 12 months.

Malta

Malta’s fintech market growing pace and low costs make it an ideal location. Obtaining an electronic money license in Malta allows you to operate in EU countries.

The average duration of the license obtaining process — 12 months.

Czech Republic

Stable, developing country with good business conditions. Obtaining a license to issue electronic money here gives you the right to operate in any of the countries of the European Union.

The average duration of the license obtaining process — 6 months.

Spain

In recent years, Spain has become a leading exporting country for financial services and has intensified its efforts to improve its financial industry. The country has tax incentives to reduce the cost of doing business.

The average duration of the license obtaining process — 9–12 months.

Ireland

Ireland has more than 40 e-money and payment services firms authorized by the Central Bank of Ireland. There is government support, including a range of services for international companies.

The average duration of the license obtaining process — 12 months.

Poland

It is one of the most promising jurisdictions for new fintech companies. There are also big business opportunities for remittance companies. Payment institutions in Poland are allowed to perform their activities only with the authorization and a license granted by the local regulator — the Polish Financial Supervision Commission.

The average duration of the license obtaining process — 12 months.

Key requirements

The main requirement for obtaining an EMI license — the initial capital of €350,000. During the authorization process, these funds must remain in the company’s bank account opened in the same jurisdiction in which the EMI license will be issued. The e-money license obtaining process is also accompanied by a thorough check of the company’s managers. In most EU countries, the regulator inspects the entire top management of the enterprise. According to the directive of the European Union, at least two heads of the organization must be residents of the countries of the European Union. As noted, each jurisdiction can set its own rules for businesses in addition to the generally accepted and required PSD2 Directive. These may include:

  • Appropriate software
  • Separate client account
  • Customer identification procedures
  • Accounting and external audit obligations
  • Certain requirements for shareholders, etc.

Therefore, before applying for a license in a particular country, be sure to familiarize yourself with its legislation and make sure that your company meets all regulatory requirements.

E-money-licensed companies at Finscanner marketplace

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  • SatchelPay — an electronic money institution founded in 2018. In 2021, this e-banking became one of the leading European EMIs, headquartered in the center of Lithuania. It offers virtual personal, business, merchant IBAN accounts, physical prepaid cards, virtual prepaid cards, currency exchange, international payments, software development, white-label solutions, and white-label card issuing.
  • KoalaPays — a small electronic money institution authorized and regulated by the Czech National Bank. It offers business multi-currency accounts with over 10 currencies, physical and virtual cards.
  • Wallter — an electronic money institution regulated by the Bank of Lithuania, subject to the regulatory framework of the European Central Bank. It offers IBAN accounts, payroll cards, virtual cards, business cards to businesses.

Find more E-Money Institutions at the Finscanner marketplace! Feel free to contact us directly today to get a consultation!


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