CONTENTS
EMI licence in EU
Payment and e-money firms must secure a licence in one of the EU Member States to get unrestricted access to the European market. As some jurisdictions rise and fall, a new regulatory landscape is taking shape across the EU, with detailed feedback on each jurisdiction being actively gathered and assessed.
A key insight from years of experience is that the choice of jurisdiction should be guided by operational substance - namely, where your employees, infrastructure, customers or executive presence are located - rather than by perceived application approval speed.
An additional, less obvious observation is that larger EU countries tend to have greater operational independence than smaller ones. These jurisdictions have more robust financial systems and stronger local markets, often enabling a more stress-free environment for fintechs.
Choosing the Right Jurisdiction
Selecting the right jurisdiction for your EMI licence is a strategic decision that goes far beyond tax laws or speed of approval. It hinges mainly on three factors - ease of doing business, local regulatory approach, and how welcoming the environment is for foreign fintechs (e.g. English-speaking). Historical and political events also play a critical role: for instance, Malta’s time on the FATF grey list caused a drop in international confidence, while Estonia and Czechia have recently revoked most or all of their EMI licences, raising serious concerns around regulatory stability.
Some regulators have clearly become more agile - Spain, for example, recently removed its EMI application fee in a sign of growing fintech openness. Meanwhile, Ireland has taken a more cautious approach, openly stating it has no ambition to become a post-Brexit EMI hub.
The level of regulatory burden also varies widely: Lithuania, while popular, has seen 18 EMI licences revoked over the last two years as it tightens oversight, whereas some as the Danish FSA, remains pragmatic, requiring at least two directors to establish an EMI - one of the most streamlined governance requirements in the EEA.
Fintheo has developed an evaluation methodology and created a refined shortlist of the most and least attractive jurisdictions for EMI and Payments licensing:
Recommended Jurisdictions for EMI Licences
These countries are known for their efficient licensing approach, clarity of application requirements, and pragmatic regulatory supervision:
Less Favorable Jurisdictions
These are often considered challenging due to such factors as unstable regulatory requirements, reputational concerns or unclear regulatory expectations:
Permissions of an EMI licence
There are a total of 8 permissions and 2 additional AIS & PIS permissions that stand separately. The latter two are typically not obtained unless needed by the business.
Time frames
The formal review period rarely exceeds 12 months — and is often significantly shorter if the application is submitted complete with all the latest requirements — something, that unless done by people following the regulatory landscape can rarely be achieved.
The biggest influence on the licensing timeline is often not the jurisdiction itself, but who is applying: the profile of the Ultimate Beneficial Owner (UBO), the experience of the directors, and the quality of the application play a far more decisive role than the regulator’s internal processes. It is not uncommon for two applicants in the same country to receive completely different outcomes: one might be authorised in 3 months, while another could wait 18 months.
To that end, we conduct a detailed audit of the UBO and directors prior to submission, identifying any risk factors — such as previous licensing experience, reputational concerns, or structural gaps — that could trigger delays. These are then addressed proactively to present a strong profile to the regulator.
Where jurisdictions include a pre-application interview stage, this usually adds at least 1.5 months to the timeline. Interviews typically require directors to already be identified, which means time must first be allocated for recruitment, onboarding, and vetting.
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Time frames by country
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Other time frames
Director hire: 1-2 months(See: Fintheo.Recruitment)
Safeguarding account opening: 7-8 weeks
Assigning a case-officer: 2-4 weeks
Drafting an application: 6-9 weeks
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Hiring a regulatory compliance consultant gets you a licence quicker than with your in-house team
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Final thought: The regulator sets the rules, but it's the owner’s reputation, the team, and preparation that sets the pace. A well-prepared file with a competent consultant can fly through the process. A poor one, even in a fast jurisdiction, will stall.
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Pre-Application Interview
In some European jurisdictions, regulators offer or require pre-application meetings as part of the EMI licensing process. These meetings—held either in person or via video call—aim to give regulators a clearer understanding of the applicant, guide firms toward a complete and compliant submission, and ultimately avoid unnecessary delays or rejections.
Applicants are typically expected to present at least a business plan, governance structure, and financial forecast, allowing regulators to assess the seriousness and preparedness of the project.
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As part of our structured application process, we prepare key management and beneficial owners for these meetings—ensuring they are well-versed in the business model, regulatory expectations, and their individual responsibilities ahead of the application.
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What is need to get an EMI licence in EU
- A Legal Entity - a registered company in the target country for licensing.To open a legal entity - a registered entity in a country of authorisation.
- Initial Capital Requirement - a minimum of €350,000 in own funds. We recommend exceeding that to €350,000 plus the capital required to break even which usually means at least €500,000 in total. It needs to be paid into your institution’s bank account and remain untouched for the whole period of holding a licensed status.
- At least 4 key management individuals, residents of the same country that demonstrate experience, integrity, and competence. See “Key Individuals” below.
- Source of Wealth (SoW) of the Ultimate Beneficiary Owner (UBO) for the €500,000 or higher. It needs to have a clear legal source and proof being paid on UBO’s accounts.
- Safeguarding bank account or other safeguarding arrangements before the application is submitted. See "Safeguarding Bank Account" below for details.
- Compliant Software with detailed technical documentation. See “Software” below.
- And a thorough EMI Application documentation. See next chapter for details.
Incorrectly submitted documents may lead to delays and rejections. Only trust your licence application to professionals!
Scope of work
Our work is structured in four key Stages to ensure a smooth and efficient EMI licence application process.
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What we will need from you
While we will handle the majority of the application process, your input and cooperation are essential. In particular, there are a few key matters that will need to be completed directly by you:
- Provide the Source of Wealth (SoW) for the ultimate beneficial owner (UBO), as required for regulatory due diligence.
- Recruit at least four key management individuals (e.g. directors, MLRO, CEO, etc.); we can assist with this via Fintheo.Recruitment, for an additional fee.
- Select your software provider and supply the relevant technical documentation. Alternatively, you may opt to use our software solution, which has already been successfully used in regulatory applications.
- Complete our business questionnaire, which gathers essential information about your business model, services, and future plans.
- Choose 3rd party vendors involved in operation of your business (e.g., banks, PSPs, liquidity providers, AML/CTF software, Cloud server providers).
We will guide you through each step, but your timely involvement in these areas will ensure a smooth and efficient application process.
Safeguarding Bank Account
Before submitting your EMI licence application, you must choose a method of safeguarding of customer funds. Most of the time, customers opt for a safeguarding account opened in a credit institution, and therefore must attach formal evidence of this with their application.
One of the main challenges here is that most banks are reluctant to open safeguarding accounts for unlicensed firms making this step a common bottleneck. To solve this, we introduce you to our network of trusted partner banks who are willing to support EMI applicants at the pre-licence stage. They can open all three accounts: business, safeguarding and, if required, a segregated account for individual IBANs.
At the later stages of the application process, you will also need to transfer your initial capital (recommended €500,000+) into the safeguarding account before the approval.
The same banks would provide you with access to SEPA and SWIFT networks. Upon authorisation, you are free to approach additional correspondent banks as needed:
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CENTROlink, SEPA and SWIFT
A significant development is underway in the European payments ecosystem: direct access to SEPA infrastructure — similar to the Bank of Lithuania’s CENTROlink - is expected to become available through every EEA regulator as early as 2026.
Some countries, such as Latvia, have already provided access to their SEPA systems, with others on track to follow. As this model becomes standard across the EEA, we offer support in application and technical integration to these systems.
For high volumes of SWIFT payments, you can secure direct access to SWIFT.
The Key Individuals (e.g., directors)
The most common set of EMD individuals appointed by EU EMIs includes the CEO, MLRO, CFO, and CTO. In practice, they must meet several strict, unwritten expectations:
- key individuals are generally required to be residents in a country of proposed application
- have at least four years of relevant managerial experience
- and a minimum of one year working in a EU financial or credit institution.
These informal standards make it extremely difficult to appoint key individuals from abroad, as the regulators place strong emphasis on local experience and familiarity with the EU regulatory environment.
Remember: Every director of an EMI needs to be fit and proper, but not every senior manager/executive needs to become a director.
The software requirements
There are typically three routes to solving the software challenge for an EMI:
- purchasing a Software-as-a-Service (SaaS) solution
- buying the source code
- or developing a custom platform yourself.
Whichever way you choose, you would need to make sure the IT solution has a vast set of technical documentation to accompany it, which we will use thoroughly to accompany the application.
Not sure which software to choose? Fintheo offers a robust, compliant platform that fully meets the Digital Operational Resilience Act (DORA) standards - Fintheo OS. We provide full installation, support, and ongoing upkeep - giving you a reliable, audit-ready solution from day one.
About Us
We are a team of former MLROs, compliance officers, and fintech and regtech professionals, dedicated to guiding firms through the regulatory landscape. Since 2019, our team has actively supported customers in building, scaling and expanding fintech businesses by providing a full suite of consulting services.
Our commitment to provide end-to-end support for businesses pursuing regulated activities led to the creation of Fintheo. We are a tech-driven company that strives to offer impeccable service to customers. As part of our proposition, we also offer a purpose-built e-money software platform which is fully DORA-compliant. In 2022, we expanded our services to include Fintheo.Recruitment, a division focused on sourcing fit and proper individuals for director and management roles to support clients during the licensing process.
Fintheo. Competence. Prudence. Result.
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