Every week, someone writes to me with more or less the same message: “I want to launch a payment app, a multi-currency account or a card for my clients. Do I need a licence?” The honest answer is that there are three doors into the payments business, and the one you choose will decide your costs, your speed and, above all, who really controls your business.
Door one: white label. You use the licence and the infrastructure of an institution that already has them. Door two: your own licence. You apply for an electronic money institution (EMI) licence and build everything yourself. Door three: buy an EMI. You take over a company that is already licensed.
I have seen founders go through all three, and I have seen each of them work and each of them fail. None of them is the right answer for everybody. The mistake is to pick a door because a salesman told you it was the fastest, the cheapest or the most prestigious.
The short version: rent, build or buy
If you want an image, think of housing. White label is renting a furnished flat: you move in next month, but the landlord keeps the keys. Your own licence is building a house: it is yours, but it takes a year or more and the budget always grows. Buying an EMI is buying a house that already stands: you move in faster than if you built it, but you had better have a surveyor look at the foundations before you sign.
Keep that image in mind. It explains almost everything that follows.
Door one: white label
How it works. A licensed institution, an EMI or a bank, provides the regulated part: the accounts, the IBANs, the card issuing, the safeguarding of client money, the compliance framework. You provide the brand, the app, the marketing and the clients. Your customers see your name on the screen and on the card. Legally, however, they are customers of the licensed institution, and you act under its licence, its rules and its supervision.
What you get. Speed and a low entry ticket. A white-label programme can go live in a few months instead of a year or more, you do not need regulatory capital of your own, and you do not have to recruit a full compliance department on day one. For a founder who wants to test a market, or for a business whose real product is something else (a travel company, an online platform, a crypto business, a community of expatriates) and which simply wants to offer accounts or cards to its own clients, it is often the sensible choice.
What you do not get. Control. The licence belongs to someone else, and so does the last word. Your supplier can change its prices, tighten its risk appetite, refuse a category of clients you were counting on, or decide that your sector no longer fits its policy. Read the termination clause before anything else: very often, the supplier can end the relationship on short notice, and your clients’ accounts go with it.
The question nobody asks: who owns the client? In a white-label set-up, the client relationship sits with the licensed institution. If you leave, can you take your clients, their data and their account history with you? In most standard contracts, not easily. I explained this in more detail in Swiss SRO or White-Label Banking: Which Model for Launching a Neobank?, where the real subject is designing your exit before you enter.
A word on the sales pitch. “Live in four weeks” usually means four weeks after your own company has passed the supplier’s onboarding, and that onboarding is a compliance review of you: who owns the company, where the money comes from, what you will really do. If your sector is considered high risk, add time, add questions, and sometimes add a refusal.
Door two: your own EMI licence
How it works. You set up a company, you build the business plan, the policies and the systems, you recruit the people the regulator wants to see, and you apply to the regulator, in the United Kingdom the Financial Conduct Authority (FCA), in the European Union the authority of the country you choose. Once licensed, the business is yours: your licence, your clients, your rules within the law.
The capital. Both the EU and the UK require an authorised EMI to have initial capital of at least 350,000 euros. That is only the entry ticket. On top of it, you must keep own funds that grow with the volume of e-money you have in circulation, and you need enough money to run the company until it breaks even. Regulators read your financial projections, and they do not like a licence holder who will be out of cash in eighteen months.
The time. In the United Kingdom, the Electronic Money Regulations give the regulator three months to decide once an application is complete, and twelve months at most from the date it was received. The word that matters is “complete”. Very few applications are complete the first time; questions come back, documents are redone, people are interviewed. In practice, count a year or more from the moment you start preparing, and do not believe anyone who guarantees you a date.
The people. A licence is granted to a business run by people the regulator trusts: directors with relevant experience, a compliance officer, a money laundering reporting officer, real substance in the country of the licence. The regulator wants to see who makes the decisions and where. A licence held by a company that is really run from somewhere else is exactly the kind of structure supervisors now look at closely, as I described in Your EMI Is Licensed in Sweden. Your 60 Employees Are in Lisbon. Is That Legal?
The rules once you are in. Holding client money is a serious responsibility, and the rules are getting stricter. In the United Kingdom, a new safeguarding regime came into force on 7 May 2026: daily reconciliation of client funds, monthly safeguarding returns to the FCA, an annual safeguarding audit and a resolution pack explaining how client money would be returned if the firm failed. None of this is optional, and all of it costs money every month.
The trap behind the trap. A licence does not give you a bank account, a card programme or a payment network. You still need a bank that will hold your safeguarded funds, access to the payment systems and, for cards, membership of Visa or Mastercard or a sponsor who will issue under its own membership. Many newly licensed EMIs discover that they still depend on third-party infrastructure for their first years. In other words, you can own the house and still rent the plumbing.
Door three: buy an existing EMI
How it works. You buy the shares of a company that already holds an EMI licence. The regulator must approve you as the new controlling shareholder before you take control, so you prepare a change of control file instead of a full licence application.
What you get. Time, mostly. The change of control process is not a formality, and you should count several months, but it is usually shorter and more predictable than a licence from scratch. A good EMI also comes with things a new licence does not have: existing banking relationships, payment infrastructure that works, a team, a track record with the regulator. Sometimes the infrastructure is worth more than the licence itself.
What can go wrong. You buy the history together with the licence. Regulatory findings, weak safeguarding, a compliance file nobody has updated, a bank that is about to close the safeguarding account, a business plan the regulator approved for an activity you have no intention of running: all of these come with the shares. Cheap EMIs are usually cheap for a reason. I listed what to check in EMI for Sale in Europe: What You Are Really Buying, What It Costs, and What Can Go Wrong, and I would not let a client sign without going through that list.
The regulator still has to like you. Buying the company does not buy you the regulator’s trust. Your source of funds, your own background and your new business plan will be examined, and if the new plan is very different from the old one, expect the questions to be as detailed as for a new licence.
Side by side
| White label | Your own EMI licence | Buy an EMI | |
|---|---|---|---|
| Time to launch | A few months, after onboarding | A year or more | Several months for regulatory approval |
| Regulatory capital | None of your own | At least 350,000 euros, then more as you grow | Already in place, to be kept at the required level |
| Control | With the supplier | Yours | Yours, after approval |
| Who owns the client | Legally, the licensed institution | You | You |
| Main risk | The supplier changes the terms or leaves | Time and money run out before the licence arrives | Hidden problems in the company you buy |
| Value for investors | Low: you own a brand and a client base | High: you own a regulated asset | High, if the due diligence is right |
How to choose: five questions before you sign anything
1. Is payments your business, or a feature of your business? If accounts and cards are a service you add to something else, white label is usually enough. If payments are the business, sooner or later you will want your own licence.
2. How much money will flow through it? Small volumes rarely justify the fixed cost of a licence. Large volumes make the supplier’s margin very expensive, and that is often the moment clients move from renting to owning.
3. Are you in a sector suppliers do not like? Crypto, gaming, adult content, certain countries: many white-label suppliers will not take you, or will take you and leave at the first problem. For these businesses, owning the licence, or at least planning to, is often the only stable answer.
4. What will your investors pay for? A white-label business is valued on its clients and its revenue. A licensed business is also valued on its licence. If you plan to raise money or sell one day, that difference matters.
5. Where are your clients and your team? The licence must sit where the business is really run, and it must cover the markets you serve. Choose the country for those reasons, not because a consultant told you one regulator is “easy”.
A path I often recommend is the one in between: start with white label to prove the business, then buy or build the licence when the volumes justify it, and negotiate the white-label contract from the start so that you can take your clients with you when that day comes. Renting first is not a weakness, provided you read the lease.
If your plans go beyond an EMI, all the way to a bank, I wrote the whole story, with real prices, timelines and failures, in my book What Nobody Tells You Before You Buy a Bank: An Insider’s Guide to Banking Licences, Due Diligence and the Real Cost of Ownership.
How FintechLex can help
We work on all three doors, which means we have no reason to push you through one of them. Through our White Label Supplier, we can set up branded accounts and cards for your clients. We prepare EMI applications in the United Kingdom and in the European Union, from the business plan to the people the regulator will want to meet. And we regularly have licensed companies for sale, such as a live EU e-money institution and an EU payment institution that is already sending money, together with a UK authorised EMI available on request.
Tell us what you want to launch, where your clients are and how much money will go through it, and we will tell you which door makes sense, and what it will really take. You can also read more on our EMI licence and acquisition page.
Write to us at insight@fintechlex.com or on WhatsApp +41 787 983 770.
Sources: Directive 2009/110/EC on electronic money (EMD2), Article 4 (initial capital); Electronic Money Regulations 2011 (UK), regulation 9 (time limits for authorisation decisions); Financial Conduct Authority, Policy Statement PS25/12, Changes to the safeguarding regime for payments and e-money firms, in force 7 May 2026.
Rene-Philippe
