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Procedure to Obtaining the E-money Electronic Money License in Estonia


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

Finantsinspektsioon (Estonian Financial Supervision and Resolution Authority), is Estonia's regulator. It is responsible for financial services businesses and financial markets.

Finantsinspektsioon (Estonian Financial Supervision and Resolution Authority) regulates firms that provide regulated services, including, consumer credit, payment services, electronic money, lending, insurance and investment services.

If you wish to issue electronic money services in Estonia, such as prepaid cards or electronic wallets, you will require an Authorised Electronic Money Institution license from Finantsinspektsioon (Estonian Financial Supervision and Resolution Authority).

When seeking a license, planning is key. It is important that you match the financial service you intend to provide with Finantsinspektsioon's (Estonian Financial Supervision and Resolution Authority) list of regulated activities.

Another important thing you must do before making an application is to ensure you meet the regulator's conditions. For example, you will need to ensure that your management and people such as directors, must be located in Estonia. You will need to demonstrate through your application that you have appropriate resources to operate your business. This includes having sufficient financial, management, staff, and systems to manage your business.

Finantsinspektsioon (Estonian Financial Supervision and Resolution Authority) expects firms to meet a range of requirements before it allows them to provide regulated financial services. When an applicant firm submits an application seeking authorisation, Finantsinspektsioon (Estonian Financial Supervision and Resolution Authority) reviews their business plans, risks, resources, systems, controls and people.

Initial Capital Requirement

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) license in Estonia

We will initially spend time with you and discuss your suitability, including assessing your business plan, resources and operations. As part of your application, you will be required to submit a number of documents, policies and procedures, including the following:

To make a successful application the E-money license, you must submit the following documents and data to Finantsinspektsioon:

- A copy of the statutes for a business that is operating, any decision by the general meeting to amend the statutes, and the amended text of the statutes;

- A notarized copy of the foundation contract or decision for a business being founded;

- Documentation proving the existence of share or equity capital paid in or to be paid in;

- An operating plan describing above all the planned payment or e-money services;

- A business plan that meets the requirements of MERAS;

- The initial balance of the applicant and a review of income and expenses or the balance and profit report as at the end of the month prior to the application for an operating business, and annual reports for the past three years if they exist;

- A description of how the general requirements of MERAS for holding client assets and client protection will be applied;

- The internal rules and internal bookkeeping rules in accordance with MERAS, or proposals for them;

- Data on the information technology and other technological equipment and systems, security systems, and control mechanisms and systems that will be needed for the provision of the planned services.A description of internal controls and measures to ensure compliance with anti-money laundering and terrorist financing obligations and obligations for information about the payer to be sent when transferring money;

- A description of the organisational structure of the applicant, covering where necessary the use of agents or branches or the procedures for transferring services, and its participation in domestic and international payment systems;

- A list of the shareholders of the applicant showing the name of each shareholder or member, their registry code or ID code, or date of birth if they have none, and details on the share or equity holdings of each shareholder and the voting weight given to them;

- The data listed in MERAS on the major shareholders of the applicant;

- Information on the managers or the applicant, including their first and family names, personal ID codes or date of birth if they have no ID code, place of residence, description of education, full list of jobs and positions held, and for members of the management board a list of their areas of responsibility, together with any documentation that the applicant considers relevant for demonstrating their trustworthiness and compliance with the requirements;

- Data on any business that the applicant or its management holds more than 20% of, where those data include the size of its equity, a list of its areas of activity, and the size of the holding of the applicant and each manager;

- Information on the auditor and internal auditor of the applicant, giving their names, places of residence or locations of operations, and personal ID codes or dates of birth or registry code if there is no ID code;

- Documentation certifying the value of own funds for a business that is already operating, together with the auditor’s report;

- The technical, economic and legal principles approved by Eesti Pank for the functioning of the payment system and the draft of the rules organising the work of this system if the applicant intends to engage in managing payment systems.

As part of our service, we will help you prepare the above documents, policies and procedures as part of your application.

How long does it take?

Finantsinspektsioon (Estonian Financial Supervision and Resolution Authority)must make a decision within three months of receiving a complete application. In reality, it takes around 4 months to obtain the license.

Next Steps

Buckingham Capital Consulting is a leading international consulting firm, specialising in payment services, electronic money, banking and investment services. We are able to advise you on the best course of action and strategy based upon your business plan and financial product or service. We can help you with licencing, compliance, operational setup and related services, including, obtaining banking facilities. For more information, visit our website on

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