How to Get an EMI License in the UK or EU: Cost and Process Guide

An EMI license (Electronic Money Institution license) is the permission fintech and crypto firms need to issue digital cash and operate payment services in regulated markets. It allows a company to issue pre-paid monetary value (“e-money”) and offer e-wallets, prepaid cards, remittances and other payment services. In practical terms, EMIs turn customer deposits into digital currency that can be used for payments under strict safeguards. Without this license, startups cannot legally onboard customer funds for payments or issue e-money products. This guide explains how to get an EMI license in the UK or EU, covering the application steps, regulatory requirements, typical costs and timelines in each jurisdiction. We compare UK EMI licensing with EU licensing (e.g. Lithuania, Ireland, France) and highlight why fintechs and crypto platforms often choose EMI licenses to expand globally.

What Is an EMI License?

An EMI license is essentially a fintech regulatory license that lets a business handle e-money. The Bank of Lithuania defines an EMI as a firm “licensed by [the] Bank of Lithuania, which has the right to issue electronic money” – a form of “pre-paid monetary value” that is stored electronically and used for payments. In other words, an EMI can legally hold customer funds in a safeguarded account and convert them into electronic money balances. Under EU law (the E-Money Directive) and the UK’s Electronic Money Regulations, only licensed EMIs (or banks) may offer e-wallets, prepaid cards, IBAN accounts, and certain payment services.

EMI licenses come in authorized (full) or restricted/small forms. In the UK, for example, a full Authorized EMI (AEMI) must meet higher requirements, while a Small EMI (SEMI) registration is available for low-volume issuers (with average outstanding e-money under €5 million). Regardless of size, all EMI applicants must comply with anti-money laundering rules and consumer protections. Obtaining an EMI license demonstrates to partners and customers that a fintech meets rigorous FCA or EU regulatory standards. For crypto platforms, an EMI license is often paired with crypto-exchange or wallet licenses, enabling smooth fiat integration.

• “Electronic money is pre-paid monetary value issued into circulation by an electronic money institution… which can be used for payment purposes”.
  
• A UK or EU EMI license mandates safeguards on customer funds and imposes capital, governance and AML requirements.
  
• Having an EMI license builds trust: regulators supervise your platform, making it easier to partner with banks or expand across borders.
  

Why Fintechs and Crypto Platforms Need an EMI License

Fintech startups, neo-banks and crypto firms need an EMI license to operate legally. It’s the gateway to offering regulated payment services. For example, if you want to issue a digital wallet, offer currency exchange, or take customer deposits online, an EMI license (or a banking license) is required. Major digital banks like Wise and Monzo in the UK, or modern payment services like Revolut (UK/EU), all operate under EMI or electronic money licenses. These licenses allow a company to take in customer money and re-issue it as e-money.

Key reasons you need an EMI license include:

• Legal compliance: EMI licensing is mandatory for e-money activities under both UK and EU law. Operating without one can lead to enforcement action.
  
• Customer trust: An authorized EMI must safeguard client funds and meet strict AML/KYC rules. This regulatory oversight protects customers and enhances your credibility.
  
• Global market access: An EMI license enables cross-border services. A UK EMI can serve UK customers and passport into the EEA only if a separate arrangement exists. An EU EMI (unrestricted) can operate across the EU (the “EU financial passport”).
  
• Broader service offering: Licensed EMIs can partner with payment schemes (Visa/Mastercard), issue IBAN accounts, and integrate crypto conversions legally. Without a license, you’d be limited to unregulated activities.
  

In short, for fintechs and crypto exchanges looking to handle fiat and scale internationally, an EMI license is often the most practical option. It signals to banks and regulators that your startup is safe and serious about compliance. (7BaaS’s EMI Licensing service guides companies through exactly this process.)

Jurisdiction Comparison: UK vs EU (Lithuania, Ireland, France)

Deciding where to apply is critical. Post-Brexit, the UK and EU are separate regimes:

• UK (FCA): The Financial Conduct Authority (FCA) regulates UK EMIs. The process requires a UK company with at least one UK director and a UK-based “mind and management” team. Authorized UK EMIs must meet the standard capital threshold (see below) and follow the UK’s Electronic Money Regulations. UK EMI licenses only cover the UK market; there is no automatic passport to the EU. Application fees are on the higher end (e.g. £5,580 for a full EMI authorization). The FCA is thorough: while it aims to decide within 6 months of a complete application, many issuers find the process can take 12 months or more due to queries and detailed reviews. Managers and investors must be “fit and proper,” and UK EMIs must have robust governance and safeguards.
  
• Lithuania (Bank of Lithuania): Lithuania has emerged as a popular EU hub for EMI licenses. The Bank of Lithuania offers two tracks: a Restricted EMI license (no minimum capital, Lithuania-only) and a standard EMI license (EU passport, €350,000 capital minimum). A Restricted EMI is ideal for new startups wanting to enter Lithuania’s market and later upgrade. The Bank of Lithuania is noted for fast turnaround. After submission, it has 5 business days to check paperwork, then typically issues a license within 3 months if documents are complete. The state fee is modest (€1,463). Lithuania’s regulator is English-friendly and sees many fintech applications, making it one of the quickest EU routes.
  
• Ireland (Central Bank of Ireland): Irish EMI licenses (CBOI) also meet the EU-wide rules (capital €350k). Ireland is known for a strong legal framework and English-speaking environment. Timelines are roughly similar to Lithuania, though often around 6–9 months. Ireland emphasizes detailed business plans and compliance checks. An Irish EMI enjoys full EU passporting, but note that post-2020 a UK branch requires separate UK authorization.
  
• France (ACPR, Banque de France): The French Prudential Authority (ACPR) licenses EMIs under the French Monetary and Financial Code. Initial capital is €350k. The ACPR process is rigorous but swift: if all documentation is in order, licensing can occur within about 3 months of a complete application. France is attractive for its large market, but regulatory scrutiny is high and costs (consultants, staff) can be greater. An EMI license from France also grants EU passporting.
  

Key differences: A UK EMI license is sufficient for UK operations but needs a separate EU license for Europe. An EU EMI (from any Member State) allows pan-EU passporting. Lithuania and France stand out for relatively quick timelines (~3 months), whereas the UK often takes longer (many applicants see 6–12+ months). However, the FCA is well-known and globally respected, which may suit some businesses. Choice of jurisdiction depends on your target market, risk tolerance, and timeline.

Step-by-Step EMI Licensing Process in UK and EU

The EMI licensing process has similar phases across jurisdictions, with local variations. Below is a high-level step-by-step approach, with UK and EU-specific notes:

1. Planning & Documentation: Prepare a detailed business plan, financial forecasts, and internal policies (AML/KYC, risk, governance). Key staff must be identified (Directors, Compliance Officer, etc.), with evidence of their fit and proper status. In your documents, clearly describe the electronic money services you will offer, your target markets, IT systems, and safeguarding arrangements. For example, the FCA requires you to include your proposed e-money activities, governance, capital plan and wind-down plan.
   
2. Meeting Regulators (Recommended): In some countries (e.g., Lithuania), schedule a pre-application meeting. Bank of Lithuania encourages early discussions to clarify requirements. This can help align expectations and avoid common pitfalls.
   
3. Company Setup: Establish a local entity if needed. For UK authorization, incorporate a UK company with at least one UK-resident director. For EU, form an entity in your chosen state (e.g. a Lithuanian LLC).
   
4. Initial Capital: Arrange the minimum capital. For a full EMI, this is €350,000 (or equivalent) for both UK and EU regimes. (Lithuania’s restricted license is exempt from initial capital). Deposit these funds as required – often into a bank account or other safeguarded form as per regulator instructions.
   
5. Application Submission: File the application with the regulator:
   
   • UK: Use the FCA’s Connect portal to apply for AEMI or SEMI status. Include all required forms and supporting material. Pay the application fee (Category 5: £5,580 for AEMI; Category 3: £1,120 for SEMI).
     
   • EU: Submit to the national competent authority (e.g. Bank of Lithuania’s online portal or office). For Lithuania, you’ll pay the €1,463 license levy beforehand. Provide translated documents as needed (English is usually accepted in Lithuania).
     
6. Regulator Review: The authority will first check completeness. FCA aims to allocate a case officer within 3 weeks, and Bank of Lithuania takes 5 business days to vet documentation. Then begins substantive review. The regulator may ask follow-up questions or request clarifications – respond promptly. Commonly requested supporting materials include organizational charts, detailed compliance manuals, and job descriptions.
   
7. Decision: Assuming requirements are met, a decision follows. In the EU, statutes mandate a decision within 3 months of a complete application. In practice, it can take up to 3–6 months if questions arise. In the UK, the FCA formally aims for a 6-month turnaround, but many EMI authorizations take 12 months or longer due to iterative queries. Once approved, you receive your EMI license and can commence regulated operations.
   

Each step involves rigorous checks. Make sure to emphasize robust governance, safeguarding of customer funds, and AML controls, as regulators focus on these areas. Most applications falter on incomplete or inconsistent documentation, so thorough preparation (or expert help) is essential.

Timeline Breakdown: Average Approval Times

The time to obtain an EMI license varies by jurisdiction and application quality:

• United Kingdom: According to recent FCA statistics, new firm authorizations averaged about 110 days (3.7 months) in Q4 2024. However, that is an average across all sectors. The FCA officially aims to decide within 6 months after a complete application, but in practice many EMI applicants experience 9–12+ months before final approval. Delays often stem from additional questions on business model, compliance or management credentials.
  
• Lithuania: The Bank of Lithuania publishes a strict timetable. After submission, it checks formal completeness in 5 business days, then strives to issue an EMI license in the statutory 3-month review window (2 months for restricted EMIs). In experience, if documents are well-prepared, decisions often come in about 3 months. If additional information is needed, the timeline extends from that point.
  
• France: The ACPR (Banque de France) likewise processes complete EMI or payment institution applications in about 3 months. If you provide all materials at once, the license is typically granted within this period.
  
• Ireland: The Central Bank of Ireland generally reviews EMI applications over a 6–9 month period. While no statutory deadline is published, applicants should plan on roughly half a year or more from submission to authorization.
  
• General (EU average): Under PSD2/E-Money rules, competent authorities must decide on full EMI authorizations within 3 months of a complete file. In practice, aiming for 3–6 months in efficient regulators (Lithuania/France) and up to 9–12 months in more conservative ones (large economies) is prudent.
  

In summary, expect at least 3 months in the best-case (EU) and 6–12+ months in the UK for EMI licensure. The clock essentially pauses whenever regulators seek more information, so responsiveness on your side is key to keeping on schedule.

Cost Breakdown: Government Fees and Advisory Expenses

Government Fees: Application fees differ by jurisdiction. In the UK, FCA charges an AEMI application fee of £5,580 (Category 5). A small EMI application is cheaper at £1,120 (Category 3). In Lithuania, the state levy for a full EMI license is €1,463 (restricted license: €1,235). Other EU regulators have similar nominal fees (often €1,000–€3,000 range). Note this is just the state fee; you also need to meet the initial capital threshold (~€350,000) by funding your entity.

Initial Capital and Ongoing Costs: Both UK and EU full EMIs require €350,000 (or equivalent) in own funds. This capital must be unencumbered. Additionally, you must prove ongoing solvency (regulators expect forecasted capital adequacy). Once licensed, annual supervisory fees apply. For example, FCA levies an annual transacted-activities fee (a small % of e-money issued) plus a fixed periodic fee.

Advisory and Setup Costs: Legal, accounting and consulting support form a significant part of the budget. Industry analysts estimate that fully preparing and launching an EMI can cost €500,000–€1,000,000 in total. This covers document preparation, hiring experienced staff (compliance officers, etc.), IT system setup, audit fees, and the time of regulatory consultants. 7BaaS and similar firms typically charge tens of thousands to hundreds of thousands of euros for end-to-end license support, depending on complexity.

Other Expenses: Don’t forget ancillary costs: corporate formation fees, bank account setup, and compliance software. Safeguarding accounts (required by EM law) may carry their own bank fees. Many jurisdictions also require a professional indemnity insurance or comparable guarantee.

Summary of Key Costs:

• Application fee: ~£5,580 (UK AEMI); €1,463 (Lithuania EMI); varies by country.
  
• Initial capital: ≥€350,000 (mandatory).
  
• Consulting/legal: €50K–€200K+ depending on scope.
  
• Time/human capital: staffing compliance, IT and operations.
  

Overall, EMI licensing is a significant investment. As one industry report notes, it’s neither simple nor cheap – budget for half a million euros or more to cover fees, capital, and professional assistance.

Common Challenges and How to Overcome Them

Lengthy Due Diligence: Regulators will scrutinize every detail of your application. Incomplete or unclear documentation is the top cause of delays. Ensure all forms are correctly filled and everything promised (in business plan) is evidenced. Hiring an experienced fintech lawyer or compliance expert can pre-empt many questions.

Governance and “Mind and Management”: Both the FCA and EU supervisors require that senior management and key persons are of good repute and experienced. In the UK, the FCA enforces a “mind and management in the UK” rule – if all major decision-makers are abroad, the FCA may refuse authorization. To overcome this, applicants should appoint at least one director and compliance officer who are UK-resident and meet FCA fit-and-proper tests. Similarly, EU authorities expect key individuals to be locally accountable.

Capital Mistakes: Underestimating how much capital is truly needed can be fatal. Apart from the regulatory minimum (€350k), you must have enough working capital to sustain operations (and unexpected costs) for the first 2–3 years. Document realistic financial projections and show reserve funds.

Crypto-specific issues: Crypto firms often seek both EMI and crypto licenses. This can raise extra scrutiny on AML and cybersecurity. Be prepared to explain how your crypto business model manages money-laundering risk and IT security. Some regulators may require additional crypto licenses (e.g. Virtual Asset Service Provider regs) in parallel.

Navigating Multiple Jurisdictions: If you plan to use your license in more than one country (via branches or passporting), each country’s regulator may review your operations. Brexit complicates UK-to-EU and EU-to-UK services. Solution: decide early where your main market is and consult 7BaaS to handle multi-jurisdiction compliance. For example, a UK EMI cannot automatically operate in France without French registration, and vice versa for a Lithuanian EMI in the UK.

Overcoming Challenges: The best strategies are thorough preparation and expert guidance. 7BaaS advises clients to engage regulators early (e.g., schedule meetings with Bank of Lithuania before filing). Use internal checklists like the FCA’s “Supporting material” list to ensure nothing is missing. Work with auditors or consultants experienced in EMI applications. Finally, having a wind-down plan and solid policies ready from day one shows regulators you are serious about governance.

Why Work with a Licensing Partner Like 7BaaS

Navigating EMI licensing is complex, but you don’t have to do it alone. 7BaaS specializes in guiding fintechs and crypto startups through this process worldwide. Our team has deep experience with both FCA and EU regulators. We can help you:

• Strategize the best jurisdiction and license type for your business model (UK AEMI vs EU EMI).
  
• Prepare comprehensive documentation, from your business plan to compliance manuals, matching exactly what regulators expect.
  
• Meet regulatory requirements efficiently by liaising with authorities on your behalf, addressing queries quickly. This speeds up approval.
  
• Handle company setup in multiple countries (we also offer Company Formation services to establish the required legal entities).
  
• Coordinate related licenses, such as crypto exchange authorization via our Crypto & Virtual Asset Licensing experts, ensuring a unified compliance approach.
  

In short, a partner like 7BaaS reduces risks and surprises. We know common pitfalls – for instance, that regulators prize clear AML policies and a committed leadership team. By leveraging our expertise, many clients have secured EMI licenses faster and at lower total cost. As the 7BaaS EMI Licensing service explains, we provide end-to-end support from consult to compliance, so you can focus on your product, not paperwork.

Internal Resources: If you need step-by-step help, see 7BaaS’s detailed EMI Licensing page for more about the process and benefits. We also support entrepreneurs with crypto licensing and company formation services, so your fintech venture can launch smoothly in any market.

Conclusion and Next Steps

Getting an EMI license in the UK or EU is a major undertaking but crucial for fintech growth. Key takeaways:

• EMI licensing is mandatory if you want to issue e-money or operate payment services legally in the UK/EU. It involves meeting capital, governance and compliance conditions.
  
• UK vs EU: A UK EMI license is valid in the UK only, while an EU EMI license (e.g. Lithuania, Ireland, France) includes an EU passport. Lithuania and France offer relatively quick 3-month approvals, whereas the FCA process often takes 6–12+ months.
  
• Costs: Expect regulatory fees (£5,580 UK; ~€1,463 Lithuania) plus at least €350k capital. Total project costs (including consulting) can range from hundreds of thousands to a million euros.
  
• Regulatory requirements: Prepare a rock-solid business plan, compliance framework, and fit-and-proper management team. Regulators will carefully review these elements.
  
• Challenges: Common hurdles include lengthy reviews, documentation gaps, and jurisdictional complexities. Overcome them by detailed preparation and expert help.
  

In conclusion, an EMI license unlocks broad opportunities in digital finance. It lets your company hold customer funds, expand payments, and even offer crypto-related financial services under regulatory oversight. For a smooth journey, partner with specialists. 7BaaS’s EMI Licensing service can guide you through the UK/EU application process, ensuring compliance at every step. Contact 7BaaS today for a consultation and start your EMI application with confidence – our experts will tailor a roadmap for your fintech or crypto business.

Get started: Visit 7BaaS EMI Licensing or Contact Us to learn how we can accelerate your licensing.

External References: Detailed guidance can be found on regulators’ websites (FCA, Bank of Lithuania). For example, the FCA outlines EMI authorization conditions, and the Bank of Lithuania publishes EMI application steps and timelines.

FAQ

Q1: What is the difference between an EMI license and a payment institution license?
An EMI (Electronic Money Institution) license lets you issue e-money (electronic cash), whereas a Payment Institution (PI) license lets you provide payment services without issuing e-money. EMIs can do everything a PI can do, plus issue stored-value products. If you plan to hold customer balances and re-issue them as e-money (e.g. e-wallets, prepaid cards), you need an EMI license.

Q2: How long does it typically take to get an EMI license in the UK or EU?
Timelines vary. In the UK, the FCA aims for a 6-month decision but many cases take 9–12+ months if additional information is needed. In the EU, top regulators like Lithuania or France typically approve a complete application in about 3 months. More complex applications (or slower regulators) can take up to 6–9 months.

Q3: How much does an EMI license cost to obtain?
Government fees are modest (e.g. FCA charges £5,580 for a full EMI, Bank of Lithuania charges €1,463). The big cost is meeting capital and professional fees. You must have at least €350,000 in capital. Including consultants, legal, audit and staff, total project costs often range from a few hundred thousand to €1M.

Q4: Can I use an EU EMI license to operate in the UK after Brexit?
No. Since Brexit, EU EMI licenses do not automatically cover the UK. You would need a separate UK EMI license (with the FCA) to serve UK customers. Conversely, a UK EMI cannot passport into the EU. If you want cross-border coverage, many companies apply in both the UK and an EU state (like Lithuania) to benefit from each market.

Q5: What are the main FCA requirements to get an EMI license in the UK?
The FCA requires an applicant to have adequate initial capital, robust governance, and qualified management. You must safeguard customer funds and comply with money laundering regulations. Key people (directors, compliance officer) must be fit and proper. If these conditions are met, and you demonstrate sound compliance systems, the FCA can authorize you as an Authorized EMI (AEMI).