The rapid growth of digital payments, online wallets, and embedded finance has increased demand for regulated financial structures. Many FinTech companies explore EMI licensing as a way to operate lawfully while offering electronic money and payment services.
Understanding how to get an EMI license is not straightforward. EMI authorization depends on jurisdiction, business model, and regulatory structure. This guide explains the EMI licensing process clearly and accurately, without misleading claims or assumptions.
What Is an EMI License?
An Electronic Money Institution (EMI) license is a regulatory authorization that allows a company to issue electronic money and provide certain payment services.
Licensed EMI businesses typically handle customer funds electronically and must comply with strict regulatory, safeguarding, and compliance obligations..
Is an EMI License Available in Every Country?
No.
Not all jurisdictions issue a formal EMI license.
In some regions, electronic money activities are regulated under alternative frameworks, such as payment service registrations or money services business structures. These frameworks perform a similar regulatory function, even if they are not called an “EMI license.” For example, the UK FCA and Lithuanian Bank provide EMI licenses to qualifying entities. ”https://www.fca.org.uk/firms/authorised-electronic-money-institutions
This distinction is critical for compliance and regulatory accuracy.
How to Get an EMI License: Key Steps Explained
Regulatory Feasibility Assessment
The first step in EMI licensing is determining whether your business model qualifies for EMI authorization or an EMI-equivalent structure.
Regulators examine how customer funds are handled, how payments are processed, and whether electronic money is being issued. Without this assessment, applications often fail.
Selecting the Right Regulatory Structure
Depending on the jurisdiction, businesses may need to apply for a formal EMI license or operate under an equivalent regulated framework.
Choosing the correct structure early prevents delays, rejections, and compliance risks.
Capital and Safeguarding Requirements
Regulators require licensed entities to demonstrate financial stability.
This usually includes maintaining minimum capital levels and safeguarding customer funds through segregated accounts or approved safeguarding mechanisms. https://www.fca.org.uk/publication/finalised-guidance/fg18-01.pdf
These measures protect customers and ensure operational resilience.
Governance and Management Requirements
A compliant EMI structure must include experienced management and transparent ownership.
Regulators assess directors, senior officers, and shareholders to ensure they are fit, proper, and capable of managing regulated financial activities.
Weak governance is a common reason for regulatory rejection.
Compliance and AML Framework Development
Compliance documentation is a core requirement for EMI licensing.
Businesses must implement robust policies covering AML controls, risk assessment, customer due diligence, transaction monitoring, and internal reporting.
Generic or copied compliance documents often result in regulatory objections.
Application Submission and Regulatory Review
Once documentation is prepared, the application is submitted to the relevant authority.
Regulators typically review business models in detail and may request clarifications or amendments before approval. Timely and accurate responses are essential.
Ongoing Compliance After Authorization
EMI authorization comes with continuous obligations.
Licensed or registered entities must maintain compliance programs, submit regulatory reports, conduct audits, and update policies as regulations evolve.
Compliance is an ongoing responsibility, not a one-time requirement.
| Stage | Step | Key Requirements & Action Items |
| 1. Preparation | Legal Entity & Base | Register a company in your chosen jurisdiction (e.g., UK, Lithuania). You must have a physical office and local “mind and management.” |
| Capital Deposit | Deposit the minimum initial capital. For a full license, this is typically €350,000. | |
| Fit & Proper Test | Vet your board of directors and key roles (CEO, MLRO). They must prove they have the experience and integrity to run a financial firm. | |
| 2. Compliance | Business Plan | Provide a detailed 3-year forecast, including target markets, expected volumes, and product descriptions. |
| Policy Framework | Create comprehensive manuals for AML/KYC, Risk Management, IT Security, and Data Protection. | |
| Safeguarding | Set up “Segregated Accounts” with a bank to ensure customer funds are never mixed with company operating cash. | |
| 3. Submission | Application | Submit all documents to the regulator (like the FCA or Central Bank) and pay the application fee. |
| Review Period | Respond to “Requests for Information” (RFIs). The regulator will likely ask for deeper details on your tech stack or risk models. | |
| 4. Approval | In-Principle Grant | Receive a “conditional” approval. This is your green light to finalize systems and hire remaining staff. |
| Final Activation | Once all conditions are met, the license is activated, and you are added to the official public register. | |
| 5. Operations | Ongoing Audit | Maintain “Own Funds” (capital) requirements and submit regular reports on transaction volumes and fraud. |
Common Challenges in EMI Licensing
Many businesses struggle with EMI licensing due to unclear regulatory understanding.
Applying in unsuitable jurisdictions, underestimating compliance requirements, or lacking regulatory expertise often leads to delays or rejection.
Professional regulatory guidance significantly improves success outcomes.
How 7BaaS Supports EMI Licensing
7BaaS provides regulatory advisory and compliance support for businesses seeking EMI authorization or EMI-equivalent regulatory structures.
Our services include regulatory assessments, compliance framework development, AML documentation, and structured regulatory readiness support.
Explore our regulatory and compliance services here:
https://7baas.com/services/emi-licensing/
Alternative Market Entry Options
For businesses seeking faster access to regulated operations, 7BaaS also facilitates the buying and selling of registered MSBs and PSPs, allowing companies to operate through established compliant entities.
Learn more about this service here:
https://7baas.com/buying-and-selling-registered-canadian-msbs-and-psps/
Access Regulatory Insights
Regulatory requirements evolve frequently. Staying informed is essential for long-term compliance.
Access practical regulatory updates and insights here:
https://7baas.com/insights/
Conclusion
Understanding how to get an EMI license requires regulatory clarity, compliance readiness, and realistic structuring.
An accurate approach avoids regulatory risk and supports sustainable growth. With the right advisory support, EMI licensing or equivalent authorization becomes a structured and achievable process.
7BaaS supports businesses through this complexity with precision, transparency, and regulatory integrity.
