An electronic money institution (EMI) licence lets you issue e-money, hold client funds, open IBAN accounts, run payments and, with a card scheme membership, issue cards – across the whole EEA through passporting. The capital requirement is the same everywhere: EUR 350,000. What differs is speed, the regulator’s attitude and the real cost of getting there. Here is the honest comparison, and when buying an existing EMI is the better route.
Ask us which route fits your project.
The three main jurisdictions
| Lithuania | Latvia | Ireland | |
|---|---|---|---|
| Regulator | Bank of Lithuania | Latvijas Banka (single supervisor since 2023) | Central Bank of Ireland |
| Initial capital | EUR 350,000 | EUR 350,000 | EUR 350,000 |
| Realistic timeline | 3–6 months quoted; few new licences granted | 7–10 months (3-month legal clock) | 9–14 months |
| Year-one budget, capital included | EUR 250,000–450,000 | About EUR 400,000–465,000 | EUR 350,000–600,000+ |
| Character | The EU’s largest EMI hub, now selective | Smaller, less crowded; direct access to the central bank’s EKS payment system | Demanding but prestigious; cool towards high-risk sectors |
Timelines and budgets as quoted by licensing advisers in 2026; the real figure depends on your business model and the quality of the file.
Lithuania: the hub that closed the door a little
Lithuania became Europe’s EMI capital with a fast, English-language process. It is now much more selective. In 2024 the Bank of Lithuania granted only three new EMI and payment institution licences, revoked nine, and authorised twelve acquisitions of existing institutions. Read that again: four times more people entered the Lithuanian market by buying than by applying.
Latvia: the quieter alternative
Since 2023, Latvijas Banka is the single regulator. The process is smaller and less crowded than in Lithuania, and a Latvian EMI can connect directly to the central bank’s EKS system for SEPA payments, which can make transfers dramatically cheaper. Corporate tax is 0% on retained profits.
Ireland: the prestige route
The Central Bank of Ireland is respected by banks and partners, and an Irish EMI opens doors. It is also slow and demanding: plan for more than nine months, a strong local team and a conservative business model. For more detail, see our Ireland EMI guide.
PSD3: the licence is about to change
The EU reached political agreement on the new Payment Services Directive (PSD3) and Payment Services Regulation in November 2025, and the final texts were published in April 2026. They are expected to apply around 2028. The E-Money Directive is repealed and EMIs become a category of payment institution. Existing EMIs will have a transition period to show they meet the new standards, or re-apply.
In practice: an EMI licensed today, or bought today, will have to be brought up to PSD3 standards within a few years. Factor that into your budget and into the due diligence on any EMI you buy.
Apply or buy?
Buying an existing EMI is not automatically faster. The new owner still needs the regulator’s approval of the change of control, which takes months, and a premium is paid on top of the EUR 350,000 capital. A licence with no technology, no banking relationships and no clients is rarely worth that premium.
Buying makes sense when the EMI brings what money cannot buy quickly:
- Its own technology: core banking, KYC and transaction monitoring, client portal.
- Payment access: SEPA through a bank or, better, directly through the central bank.
- A card scheme membership, such as Visa principal membership, which takes long to obtain.
- Banking relationships and a clean compliance record.
- Clients and revenue, even modest ones.
We currently have EU EMIs available, including a Latvian EMI with its own technology, direct central-bank SEPA access and a Visa principal membership. See EU EMI for sale with Visa. Prices on request: insight@fintechlex.com.
Which route for which project?
- You need to be live in months, with cards and SEPA: buy an operating EMI with real assets.
- You have time, a clean model and want prestige: apply in Ireland.
- You want a lean EU base with low payment costs: apply in Latvia, or buy there.
- You only need accounts and cards for your clients: you may not need a licence at all – see white-label banking and neobank solutions.
- Your clients are outside the EU: compare with a Swiss structure – European EMI vs Swiss fintech licence.
We help you choose, then execute: EMI applications, EMI acquisitions and the change-of-control file. Write to insight@fintechlex.com.
This article is for general information only and does not constitute legal advice.
