EMI Licence and EMI Acquisition

EMI Licence

EMI Licence and EMI Acquisition

Behind most fintech accounts, wallets and cards there is an electronic money institution (EMI). It is the licence that lets you hold client money as e-money, give clients accounts with IBANs, issue cards and move payments, and, in the European Union, passport all of it from one country to the rest of the European Economic Area. There are three ways to get there: apply for your own licence, buy an EMI that already has one, or start under someone else’s licence. We do all three, and we tell you which one makes sense before you spend a franc.

The licence

What an EMI can do, and what it cannot

An EMI issues electronic money, runs payment accounts, issues cards and executes payments. It can also issue e-money tokens, the stablecoins regulated under MiCA. What it cannot do is lend your clients’ money or pay interest on it: e-money is not a deposit, and client funds must be safeguarded, separated from the EMI’s own money. The regulator will want at least EUR 350,000 of initial capital, fit and proper managers, a real AML set-up and real people in the country of licence. A website and a nominee director no longer impress anybody.

Three routes

Apply, buy, or start without your own licence

01

Apply for a new licence

The country matters: Lithuania, Ireland, France, Liechtenstein and others each have their own pace, demands and reputation with banks. Regulators have become slower and stricter, so count in quarters, not weeks, and often a year or more from the first draft to the licence.

02

Buy a licensed EMI

Faster in theory, as long as the regulator approves you as the new owner before closing. The real work is the due diligence: safeguarding, agents, banking and card partners, past findings of the regulator. An EMI for sale without a banking partner is a licence without plumbing. We regularly have EMIs for sale in our Marketplace.

03

Start without your own licence

As an agent or distributor of a licensed EMI, or through a white-label programme, you can launch in weeks. You pay per use and you control less, but you test the market before buying the shop.

The reform

What PSD3 changes

The European Union is rewriting its payment rules. The new Payment Services Directive (PSD3) and the Payment Services Regulation were politically agreed in November 2025 and are expected to apply from around late 2027. EMIs then become a sub-category of payment institutions and must be re-authorised under the new regime, with transitional periods. If you buy an EMI today, check that it can pass that re-authorisation; we do. The United Kingdom runs its own regime under the FCA, and since Brexit a UK EMI gives you no passport into the European Union, and the reverse is equally true.

What we do

What we do for you

01

Choose the route and the country: apply, buy, or start as agent or white label

02

Prepare the licence application: business plan, AML and safeguarding framework, governance

03

Source EMIs for sale, run the due diligence and the change-of-control file up to closing

04

Set up the card programme: Visa or Mastercard principal membership, or BIN sponsorship

05

Arrange banking and safeguarding partners, so the licence actually works

Frequently asked questions

Frequently Asked Questions

How much capital does an EMI need?

At least EUR 350,000 of initial capital in the EU and the same euro amount in the UK, plus own funds that grow with the business. Our fees are quoted on request.

How long does it take?

A new application usually takes a year or more. Buying an EMI depends on the regulator’s approval of the new owner, which takes several months. An agent or white-label launch can be done in weeks.

Can a founder from outside Europe own an EMI?

Yes. The regulator looks at who you are, where your money comes from and whether the business is really run from the country of licence, not at your passport.

EMI or payment institution?

An EMI if you hold client balances as e-money; a payment institution if you only move payments. Under PSD3 the two regimes merge, which is one more reason to check the licence you buy.

Can an EMI do crypto?

An EMI may issue e-money tokens under MiCA. Crypto services such as exchange or custody need a separate MiCA authorisation, and we advise running them in a separate company.

Request your EMI roadmap

Tell us what you want to offer and to whom. We will tell you whether to apply, buy or start under someone else’s licence, in which country, and what it really takes. Write to insight@fintechlex.com or WhatsApp +41 787 983 770.

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