Guidelines for Application for Electronic Money Institution Licenses Based on the PSD2 and EMD2 Regulatory Frameworks
EU countries
Application guidance
项目经验
Team Support
Application guidance
Authoritative team support
EU countries
Passport Rights Coverage
application process
Professional process optimization
Monthly cycle
Average application time
The Electronic Money Institution (EMI) license is a unified financial services license issued by the European Union, which allows licensed institutions to provide electronic money issuance and payment services throughout the European Economic Area and enjoy EU passporting rights.
Electronic Money Institution (EMI)It is a financial institution authorized under the EU's Second Payment Services Directive (PSD2), specializing in the issuance of electronic money and related payment services. The EMI license is a key financial license under the EU's unified regulatory framework.
The main difference between EMIs and traditional banks is that they focus on electronic money and payment services rather than providing credit. This makes EMIs relatively less capital-intensive, less complex to regulate, and less difficult to apply for.
✓ Electronic money issuance and redemption
✓ Prepaid cards and digital wallets
✓ Mobile payment solution
✓ Payment Account Services
✓ Payment transaction execution
✓ Acquiring Services
✓ Remittance service
| Contrast Dimensions | EMI License | banking license |
| Minimum capital requirements | € 350,000 | € 5,000,000 + |
| Application cycle | 6-12 months | 12-24 months |
| Business scope | Electronic Money + Payment Services | Comprehensive banking services |
| regulatory requirements | Relatively simplified | Strictly complex |
| capital adequacy ratio | not applicable | 8%+ (Basel III) |
| deposit insurance | Client funds isolation protection | €100,000 deposit insurance |
| Credit business | 禁止 | allow |
| EU passport | enjoy | enjoy |
After obtaining an EMI license in any EU country, you can provide services in the other 26 EU countries
Avoid the complexities and high costs of applying for licenses in each country individually
Doing business in other EU countries through notification procedure
Submit notification of doing business in other EU countries
The home country regulator forwards the notification to the target country regulator
You can start doing business in the target country after the notification takes effect
A deep dive into the regulatory basis for EMI licenses: PSD2 and EMD2 are the main frameworks, while MiCA regulations cover e-money token compliance.
Directive (EU) 2015/2366
• Payment Account Services
• Payment transaction execution services
• Payment Initiation Service (PIS)
• Account Information Service (AIS)
• Acquiring services
• Remittance services
Requires the use of at least two independent authentication factors: knowledge factor, possession factor, and inherent factor
EMI can provide more diversified payment services, including PIS and AIS services
Technical requirements such as strong customer authentication, open banking APIs, and secure communication protocols must be implemented
Stricter operational risk management, incident reporting, and customer protection requirements
Regulation (EU) 2023/1114
Stablecoin-related provisions take effect
MiCA regulations apply in full
MiCA regulations apply in full
MiCA mainly regulates crypto assets, while EMI licenses are regulated by PSD2/EMD2. The two have some overlap in the field of electronic money tokens (EMT).
If EMI wants to issue blockchain-based electronic currency tokens, it needs to comply with both EMD2 and MiCA regulations.
Traditional EMI business is still mainly regulated by PSD2, and crypto asset-related business needs to consider MiCA requirements
Issuing blockchain-based electronic currency in compliance with the MiCA framework
Combining traditional payment services with blockchain technology
Leveraging the EU's unified regulatory framework to expand digital payment services
• Crypto asset service providers are brought under regulation
• Enhanced customer due diligence requirements
• Real-name transaction records
• Expand the definition of money laundering crimes
• Strengthening criminal liability
• Cross-border cooperation mechanisms
• Legal basis for data processing
• User consent and right of withdrawal
• Right to data portability
• Right to be forgotten
• Payment data sensitivity
• Cross-border data transfer
• Data retention period
A step-by-step guide from preliminary preparation to obtaining a license to ensure your application passes regulatory review
Preliminary preparation stage
Application preparation stage
Regulatory review stage
Approved operation stage
• Business model and target market analysis
• Financial forecast and profit model
• Risk assessment and mitigation measures
• Technical architecture and system planning
• CEO/General Manager Appointment
• Compliance Officer and Risk Officer Configuration
• Technical leaders and operations team
• Composition of the Board of Directors and the Board of Supervisors
• Minimum capital €350,000
• Operating capital budget
• Proof of source of funds
Estimated time: 2-3 months
Key Outcome: Complete business plan and team configuration
• Formal application form
• Business plan
• Financial statements and forecasts
• Management resume and certificate of suitability
• AML/CTF Policy and Procedures
• Risk Management Framework
• Internal control systems and procedures
• Client funds isolation plan
• System architecture design
• Security measures and data protection
• Business Continuity Plan
Estimated time: 2-3 months
Key Outcome: Complete business plan and team configuration
• Initial review and feedback
• Supplementary material requirements
• On-site inspections and interviews
• Final decision notification
• Core system development completed
• Security testing and penetration testing
• User Acceptance Testing
• Production environment deployment
• The license officially takes effect
• The first batch of customers access
• Exercise of passport rights
Estimated time: 2-3 months
Key Outcome: Complete business plan and team configuration
The application documents are complicated and the requirements are strict, which may lead to omissions or errors.
Regulatory requirements vary from country to country, requiring a deep understanding of local requirements
The system has high security and reliability requirements and requires a professional technical team
The application documents are complicated and the requirements are strict, which may lead to omissions or errors.
Regulatory requirements vary from country to country, requiring a deep understanding of local requirements
The system has high security and reliability requirements and requires a professional technical team
Comprehensive understanding of the specific requirements for EMI license application, including detailed standards in terms of capital, personnel, systems, compliance, etc.
We have prepared detailed EMI license application requirements documents for you, covering professional guidance throughout the application process
• Initial capital requirements
• Ongoing capital requirements
• Proof of source of funds
• Comparison of differences between countries
• Executive suitability standards
• Organizational structure design
• Board composition
• Key position configuration
• Core system architecture
• Safety technical standards
• Data protection measures
• Business Continuity Plan
• AML/CTF Policy
• Risk management system
• Internal control system design
• Regulatory reporting requirements
50+
Page professional content
100%
Application process coverage
27
Applicable to EU countries
✓ Based on the latest MiCA regulations in 2026, ensuring compliance and timeliness
Full-process professional services from application preparation to operational support to ensure your EMI license application is successful and operates smoothly
• Market analysis and competition research
• Business model design
• Financial forecasting and modeling
• Risk assessment and mitigation
• Fill out the application form
• Support document organization
• Translation and notarization services
• Quality review and improvement
• Pre-application consultation
• Application process coordination
• Preparation of supplementary materials
• On-site inspection support
Pricing based on complexity
• Policy and system design
• Establishing process flow
• Staff training program
• System configuration support
• Risk identification and assessment
• Risk control measures
• Monitoring and reporting mechanisms
• Emergency Response Plan
• Three lines of defense design
• Internal audit system
• Compliance monitoring procedures
• Establishment of reporting mechanism
Ongoing compliance support
• Account management system
• Payment processing engine
• Clearing and settlement module
• Report generation tools
• Real-time transaction monitoring
• Suspicious transaction identification
• Sanctions list screening
• Automation of regulatory reporting
• Third-party payment access
• Banking connectivity services
• Authentication integration
• Data synchronization service
Based on needs assessment
Lithuanian EMI license
A fintech company specializing in cross-border payments, hoping to provide innovative payment solutions in the European market.
• Complete business plan development
• Lithuania EMI license application
• Compliance system construction
• Technical system architecture design
7 months
Obtaining a license
€2M+
monthly trading volume
Malta EMI license
A cryptocurrency exchange wants to expand its business and provide fiat-to-cryptocurrency bridging services.
• Malta EMI license application
• Encryption business compliance design
• AML/CTF system construction
• Regulatory communication and coordination
10 months
Obtaining a license
50K +
active user
partner
A seasoned financial compliance expert with extensive experience across the UK, EU, and Asian markets, he possesses profound expertise in regulatory license applications and risk management. He has successfully led multiple cross-border financial license applications, including the MiFID Investment Firm License and the VASP Virtual Asset Service Provider License.
• 100% first-time approval rate for regulatory inquiries
• 67% reduction in license rejection rate
• 12-country EU compliance case think tank
partner
He has set industry benchmarks in MiFID II compliance, CASP/VASP license applications, anti-money laundering system development, and PSD2 compliance. His strategic insights have earned him recognition as a "Leader in Fintech Regulation" by Legal 500 for five consecutive years.
• Chairman of the G100 Global Financial Leaders Alliance
• Recognized by Legal 500 for 5 consecutive years
• Development of standards for cross-border flow of digital assets
Senior Technical Consultant
With triple master's degrees in technology, engineering, and data science, he is a leading expert in fintech architecture and digital transformation. He has led the development of several core fintech platforms, including white-label banking systems, mobile banking applications, and cross-border payment gateways.
• The EU’s first AI-driven anti-money laundering system
• 500 million transactions per day network
• 42% reduction in false positives
In-depth analysis of EMI license applications, regulatory policies and industry trends, providing you with the latest and most authoritative professional information
