EMI License in the EU: Costs, Timeline, Steps

An EMI license (electronic money institution authorisation) lets a company issue electronic money, provide payment accounts with IBANs, issue cards, and process payments across the entire EU under one authorisation. For fintech and crypto-adjacent businesses, it is the closest thing to a bank license without becoming a bank. Expect EUR 350,000 of initial capital, a 6-to-12-month end-to-end project, and a serious compliance build.

What exactly does an EMI license allow?

An authorised electronic money institution can:

issue e-money: stored value your customers hold on wallets and accounts;
open segregated payment accounts with dedicated IBANs;
issue payment cards and execute transfers, direct debits, and acquiring;
passport all of it into every EU and EEA member state from one home country.

What it does not allow: lending from customer funds, taking deposits, or paying interest. Customer money is safeguarded, not lent out. That is the structural difference from a bank, and the reason approval is faster. For the strategic comparison, see our piece on EMI vs traditional banks.

How much capital does an EMI need?

Two numbers are fixed by the E-Money Directive (Directive 2009/110/EC, Articles 4-5):

Initial capital: EUR 350,000, paid in before authorisation.
Ongoing own funds: at least 2% of average outstanding electronic money, recalculated continuously, with the initial capital as the floor.

On top of the regulatory capital, plan the operating runway: compliance staff (MLRO and compliance officer are expected to be real, local, and employed), safeguarding bank accounts, audit, and IT. Realistic first-year budgets start around EUR 500,000 all-in, scaling with the business plan you file.

Which EU country should you apply in?

Lithuania is the most common choice for first-time applicants; Ireland and the Netherlands suit later-stage companies. The license is portable everywhere, so the choice comes down to the regulator, timeline, and infrastructure.

Country	What you get	Best for
Lithuania	The EU’s best-known EMI hub: a dedicated fintech track at the Bank of Lithuania, English-language process, public register of licensed institutions (Bank of Lithuania market participants), and direct access to euro-area payment infrastructure through the regulator’s own CENTROlink service, so an EMI can issue IBANs without depending on a commercial bank	First-time applicants and crypto-adjacent groups
Ireland / Netherlands	Strong reputations and higher expectations on local substance; in our mandates, review cycles there run materially longer	Later-stage, well-capitalised companies
Malta / Cyprus	Workable regimes with English-language processes	Groups pairing payments with iGaming or investment-services entities

EU law gives the regulator 3 months to decide on a complete application (the deadline set by PSD2, Article 12, which the e-money regime follows). “Complete” is the operative word. In practice, the Q&A rounds put realistic end-to-end timelines at 6 to 12 months from kickoff to authorisation, including preparation.

What does the application actually contain?

The file the regulator reads is a description of a working institution, not a concept:

Program of operations and 3-year business plan with volume forecasts that match your capital.
Safeguarding arrangements: how customer funds are protected. EMD2, Article 7 allows two methods: segregation in an account with a credit institution (or investment in secure, low-risk assets) or an insurance policy/comparable guarantee; most applicants use segregation, and the file must show the account, the mechanics, and the reconciliation procedures.
Governance and key persons: management fit-and-proper, a resident MLRO, internal audit and risk functions.
AML/CTF framework: policies, customer risk scoring, monitoring scenarios, sanctions screening.
IT and security: architecture, incident response, outsourcing register, DORA-aligned resilience documentation.
Shareholder transparency up to the ultimate beneficial owners, with source-of-funds evidence.

Regulators reject files by stalling them: each incomplete answer restarts a question cycle. A clean first submission is the single biggest timeline saver, which is exactly the work we do inside payment services licensing mandates.

What does the application cost beyond capital?

Three budget lines beyond the EUR 350,000: a state application fee (set nationally, in Lithuania by the Bank of Lithuania fee schedule), the compliance build (policies, safeguarding setup, key-person hires), and external support for the file. Plan for the regulator to invoice supervision fees annually once authorised. The capital itself is not spent: it sits as own funds backing the institution.

Can a crypto business use an EMI license?

Yes, with limits. An EMI can serve crypto companies with accounts and processing, and an EMI group can add crypto services. But issuing e-money and providing crypto-asset services are separate regulated activities: the crypto side needs its own authorisation under MiCA licensing rules. In 2026, the workable pattern is a group with two regulated entities, an EMI for fiat rails and a CASP for crypto services, sharing compliance infrastructure. Stablecoin plans change the analysis again: significant e-money tokens under MiCA bring additional requirements, so the structure must be designed before the application, not after.

What changes next: PSD3 on the horizon

The EU is negotiating PSD3 and the Payment Services Regulation, a package expected to fold the e-money regime into the payments framework (European Commission payment services proposals). The direction is consolidation, not abolition: existing EMIs are expected to transition into the new authorisation with grandfathering windows. For anyone planning an application in 2026, the practical takeaway is simple. A license obtained now is the asset that gets grandfathered. Waiting for PSD3 means competing for regulator bandwidth later with everyone else.

FAQ

How long does it take to get an EMI license?

Plan 6 to 12 months end to end: 2-3 months building the file, a 3-month statutory review where the regulator’s clock only runs on complete applications, and question rounds in between.

Can I buy an existing EMI instead of applying?

Acquisitions of licensed EMIs happen, but the regulator approves every qualifying-holding change (the assessment anchored in EMD2, Article 3), effectively re-running fit-and-proper on the buyer. It saves less time than sellers advertise and adds legacy-liability risk.

What is the difference between an EMI and a payment institution?

A payment institution (PI) executes payments but cannot issue e-money or hold balances as stored value. If your product keeps customer money on wallets or issues cards against stored balances, you need the EMI licence, not the lighter PI authorisation.

Does a UK EMI license work in the EU?

Not anymore. Since Brexit, an FCA-licensed EMI cannot passport into the EU: groups serving both markets run one UK entity and one EU entity in parallel.