How to Get an EMI Licence

Key requirements (EU / UK)

• Initial capital: EUR 350,000 under EMD2; the UK EMRs 2011 apply an equivalent requirement.
• Ongoing own funds: calculated on outstanding e-money and payment volumes.
• Safeguarding: customer funds segregated in safeguarding accounts or covered by insurance/guarantee.
• Governance: fit-and-proper directors, local management, compliance and MLRO functions.
• Programme of operations and business plan with three-year financial projections.
• AML/CTF framework, IT security and outsourcing policies.

Choosing a jurisdiction

EU EMIs can passport across the EEA. National authorities differ in substance expectations and supervisory approach. Since Brexit, UK EMIs cannot passport into the EU.

Technology implications

EMIs need a reliable e-money ledger reconciled daily to safeguarding accounts, plus onboarding, monitoring and reporting.