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PSD3 capital requirements: initial capital and own funds for payment institutions and EMIs

By Harry Khan, Founder · Published 8 November 2026 · Last reviewed 8 November 2026

Summary
  • PSD3 sets initial capital by service: EUR 40,000 for money remittance alone, EUR 50,000 for payment initiation, EUR 150,000 for the core payment services and EUR 250,000 for issuing e-money.
  • The amounts add up where an institution provides services in more than one band, so a combined payments and e-money institution needs EUR 400,000.
  • Ongoing own funds for payment services use method B by default; methods A and C remain available.
  • Institutions issuing e-money hold at least 2% of average outstanding e-money (method D), on top of the requirement for their other payment services.
  • Existing institutions must recalculate under PSD3 and document it in the re-authorisation file.

The short answer

PSD3 changes the capital rules for EU payment institutions and electronic money institutions (EMIs) in two ways. Initial capital is set by the services the institution provides and the amounts are added together, so firms combining several services hold more than under PSD2. And because the Second E-Money Directive is repealed, e-money issuance becomes one service among others, with its own initial capital of EUR 250,000 and its own ongoing own funds method.

Most institutions already hold well above the minimum. The work is in recalculating correctly and evidencing it in the file every existing institution must submit to keep its authorisation. Our PSD3 re-authorisation guide explains that process.

Initial capital by service

Article 5 of PSD3 sets the minimum capital an institution must hold at all times, based on the services listed in Annex I.

ServicePSD2 or EMD2PSD3
Money remittance only (point 5)EUR 20,000EUR 40,000
Payment initiation (point 6)EUR 50,000EUR 50,000
Core payment services (points 1 to 5)EUR 125,000EUR 150,000
Account information only (point 7)No capital; insurance requiredNo capital; insurance required
Issuing e-money (point 8)EUR 350,000EUR 250,000

The core payment services are placing cash on and withdrawing cash from an account, executing payment transactions, issuing payment instruments, acquiring payment transactions and money remittance, where money remittance is not the only service.

How the amounts add up

Under PSD2, an institution's initial capital was the highest amount required for any of its services. Under PSD3, the amounts are cumulative where the institution provides services in more than one band. That is a change in principle, though in most cases the effect is modest.

Business modelPSD3 initial capital
Money remittance onlyEUR 40,000
Payment initiation onlyEUR 50,000
Cards and transfersEUR 150,000
Cards and transfers plus payment initiationEUR 200,000
E-money onlyEUR 250,000
E-money plus remittance onlyEUR 290,000
E-money plus payment initiationEUR 300,000
E-money plus cards, transfers or acquiringEUR 400,000
E-money, core services and payment initiationEUR 450,000

A typical EMI today, issuing e-money and providing related cards and transfers, holds EUR 350,000 under EMD2 and will need EUR 400,000 under PSD3. An EMI that issues e-money only will need less than today.

Ongoing own funds for payment services

Initial capital is a floor. The ongoing requirement, own funds, depends on the size of the business. Article 7 of PSD3 keeps the three PSD2 methods and makes method B the default.

  • Method A requires own funds of at least 10% of the previous year's fixed overheads.
  • Method B applies a sliding scale to payment volume, starting at 4% of the first EUR 5 million and falling to 0.25% above EUR 250 million, multiplied by a factor that depends on the services provided.
  • Method C applies a scale starting at 10% to a relevant indicator based on interest, commission and other operating income.

An institution's own funds must never fall below its initial capital. Regulators can require a different method in some cases and can adjust the result within limits based on the institution's risk profile.

Own funds for e-money: method D

Article 8 of PSD3 sets the ongoing requirement for e-money issuance at 2% or more of average outstanding e-money, the same as EMD2 method D. An institution that issues e-money and also provides payment services not linked to e-money holds own funds for both: method D for the e-money and the applicable method for the payment services.

For EMIs with large e-money balances, method D will usually be the bigger figure. An EMI with average outstanding e-money of EUR 50 million needs at least EUR 1 million of own funds for that activity, well above the EUR 250,000 initial capital.

Worked examples

A money remittance business. Today it holds EUR 20,000 initial capital. Under PSD3 the floor doubles to EUR 40,000, and method B applied to its payment volume will often be higher. Small changes in the floor matter most to businesses that have operated close to the minimum.

A card-issuing EMI. It issues e-money and provides card payments and transfers, with average outstanding e-money of EUR 20 million. Initial capital rises from EUR 350,000 to EUR 400,000. Own funds for e-money are at least EUR 400,000 under method D, plus own funds under method B for payment services not linked to the e-money.

A payments group adding pay by bank. A payment institution providing acquiring adds payment initiation. Initial capital becomes EUR 200,000, against EUR 125,000 today.

A prepaid programme issuer. An EMI issues e-money for gift and expense cards through a network of distributors and provides no other payment services. Its initial capital falls from EUR 350,000 to EUR 250,000. With average outstanding e-money of EUR 30 million, method D requires own funds of at least EUR 600,000, so the ongoing requirement, not the floor, decides how much capital the business holds. The lower floor matters mainly at launch or for programmes with small balances.

In each example the figures are minimums. Regulators expect a buffer above them, and banking partners often ask for more.

What counts as own funds

As under PSD2, own funds for payment institutions and EMIs follow the definitions used for banks in the EU Capital Requirements Regulation. In practice, the core is ordinary share capital, share premium and audited retained earnings. Losses, intangible assets and certain deferred tax assets are deducted. Subordinated loans can count in limited circumstances and within limits, and interim profits generally count only once verified.

Two points come up repeatedly in reviews. Capital used to meet the requirement must not be counted twice within a group, so a parent cannot rely on the same funds for two regulated subsidiaries. And funds held as own funds are not safeguarded customer money: the two must be kept and reported separately.

Account information providers and insurance

Account information service providers continue to need no initial capital under PSD3. Instead they hold professional indemnity insurance, or a comparable guarantee, covering their liability to account providers and users. Payment initiation service providers hold EUR 50,000 of initial capital, and the agreed texts also require cover for their liabilities. An institution that adds account information to an existing payment or e-money authorisation should confirm with its insurer that the policy extends to the new service.

Capital and the re-authorisation timeline

Capital is one of the easier sections of the re-authorisation file to prepare, but it depends on two things that take longer: an accurate list of services, and up-to-date audited figures. Institutions with a financial year ending in 2027 should plan to file using those audited accounts, so the board should agree the capital plan before the year-end close. Where a capital injection is needed, allow time for shareholder approvals and, if the injection changes ownership above the regulatory thresholds, for the regulator's change of control approval, which can take several months.

What goes in the re-authorisation file

Article 3(3)(c) requires evidence that the institution holds the initial capital under Article 5. For existing institutions, the regulator will also expect the own funds calculation and how it is monitored. A clear capital section includes the services mapped to Annex I, the initial capital calculation, the own funds calculation under the method used with the underlying figures, the composition of own funds, and how capital is monitored and reported to the board. Many institutions add a forward projection to show headroom over the next two to three years.

Groups that hold licences in several member states should prepare a consistent methodology across entities, because supervisors increasingly compare files within groups.

Planning for the change

  1. Map services to Annex I. Capital follows the services in the authorisation, so the list must be right first.
  2. Recalculate. Work out initial capital and own funds under PSD3 using the latest audited figures.
  3. Check headroom. If headroom is thin, plan a capital injection or reconsider services before filing.
  4. Document. Write the capital section for the file and a short paper for the board.

Our guide to the EMI licence under PSD3 explains the wider change for e-money institutions, and our Lithuania payment institution licence guide shows how capital is assessed in one of the main EU licensing hubs.

Choosing services with capital in mind

Because PSD3 adds capital amounts together, the list of services in the authorisation now has a direct cost. Before filing, review each service against the business plan for the next two to three years. A service that is unlikely to be used, for example payment initiation added in case of future demand, adds EUR 50,000 to the floor and expands what the regulator reviews. It may be better to apply for it later through a variation once the product is ready.

The opposite also applies: a service the business actually provides must be in the authorisation, whatever its capital cost, because services left out cannot be provided after the transition. White-label card programmes, cash withdrawal services and remittance corridors added since the original licence are the usual items to check. The goal is an authorisation that matches the business exactly, with capital sized to fit.

How Buckingham Capital Consulting helps

We recalculate initial capital and own funds under PSD3, prepare the capital section of re-authorisation files, and advise on structuring services to avoid unnecessary capital. For new applicants we prepare the full authorisation file, including the capital plan, in the member state that suits the business.

Questions

What is the initial capital for a payment institution under PSD3?

EUR 150,000 for the core payment services, EUR 40,000 for money remittance only and EUR 50,000 for payment initiation. Amounts add up where services fall in more than one band.

What is the initial capital for issuing e-money under PSD3?

EUR 250,000, plus the amount for any other payment services the institution provides.

Are PSD3 capital amounts cumulative?

Yes. Unlike PSD2, where the highest amount applied, PSD3 adds the amounts for each band of services the institution provides.

Which own funds method applies by default under PSD3?

Method B, based on payment volume. Methods A and C remain available, and e-money uses method D at 2% of average outstanding e-money.

Do account information providers need capital?

No initial capital, but they must hold professional indemnity insurance or a comparable guarantee.

Will my EMI need more capital under PSD3?

An EMI that also provides core payment services moves from EUR 350,000 to EUR 400,000. An EMI that only issues e-money needs EUR 250,000.

Sources

Get in touch: WhatsApp +44 7563 115980, Telegram @buckinghamcapital or [email protected].

This article is general information, not legal advice. Requirements change, and the regulator’s own publications take precedence.

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