How to become an E-money Electronic Money Institution


In this article, we look at the process of becoming an electronic money institution (EMI).

There are two types of e-money licenses firms can apply for:


  1. Small EMI (electronic money institution)

A firm can apply to become a small EMI only if its money outstanding e-money does not success EUR 5m. The registration process is cheaper and more straightforward in comparison to an authorised EMI, but there are no passporting rights. Small EMIs may also provide unrelated payment services I.e. money remittance or payment processing, as long as their average monthly total of payment transactions does not exceed EUR 3m.

2. Authorised EMI (electronic money institution)

Authorised EMIs are subject to capital requirements (EUR 350k), safeguarding and conduct of business rules. Authorised EMIs may also passport in Europe (EEA), which enables them to operate in other European countries without requiring additional licenses or operational/physical setup. Authorised EMIs may also provide payment services that are not related to issuing e-money (unrelated payment services).


Making an Application for an authorised EMI (e-money) licence


As part of your application, you will be required to submit a number of documents, policies and procedures, including the following:

1.  A programme of operations.

2.  A business plan including a forecast budget calculation for the first three financial years.

3.  Evidence that you hold initial capital.

4.  A description of the measures taken for safeguarding electronic money service users’ funds.

5.  A description of the governance arrangements and internal control mechanisms, including risk management and accounting procedures.

6.  A description of the procedure for monitoring, handling and following up security incidents and security-related customer complaints, including an incidents reporting mechanism which takes account of the notification obligations.