EMI regulations in Europe

During the last years, the e-money market is developing vividly in Europe, which attracted the interest of regulators and legislations. The activities of e-money institutions are regulated at the level of the European Union according to the Electronic Money Directive 2009/110/EC. At the same time it was supplemented by the second payment directive PSD2 Directive (EU) 2015/2366 aimed at the security of payments and protection of consumers. In this article, lawyers from Regulated United Europe want to bring forward some of the most relevant regulatory aspects for electronic money institutions in Europe, respectively the licensing regime, share capital and the application procedure.

Licensing regime

In order to start activity in the electronic money field, firms must obtain an EMI – Electronic Money Institution license. One such license can be given only if the company satisfies a number of criteria, among these being:

• Business plan submission: An adequate business plan containing a description of the activities proposed, risk management systems, administrative structure and expected financial flows of the operations to be undertaken.
• Management team: Evidence of qualifications and adequate experience of the management team.
• Anti-money laundering (AML) measures: Apply adequate procedures and systems to prevent money laundering and financing of terrorism.

The minimum authorized capital for e-money institutions in Europe is 350,000 euros paid in fully at the time of application for a license.

Application review process

Once an application is received and all documents are included, the start of the review process begins by the regulator. This can take anything between 3 to 12 months, depending on the country, completeness, and quality of the submitted documentation, and depending on the specifics of the declared activity. Throughout this period, a regulator may also ask for more information or clarifications. Regulation of e-money institutions is turning Europe into a safe and transparent environment where electronic payments are executed along with protection of consumer interests. At the same time, regulators try to boost innovation and competition in the market. Careful preparation of the licensing process, meeting all requirements, and regulations are required for companies willing to enter this fast-growing sector. After obtaining an EMI license, several opportunities for companies open on how to develop and expand in the European e-money market.

EMI regulations in Lithuania

Over recent years, Lithuania has been actively positioning itself as one of the leading European fintech hubs, including for e-money institutions. The country has a very friendly regulatory environment that aims to stimulate innovation and attract business from abroad.

Regulatory Environment

The main regulator responsible for issuing licenses to e-money institutions is the Lithuanian Bank. Regulation is based on the EU E-money Directive (2009/110/EC) and lays down strict requirements regarding operations and risk management.

License Requirements

To obtain a license for an electronic money establishment in Lithuania, there is a need to meet the following basic requirements of a company:

• Authorised capital: The minimum capital that an electronic money establishment may be authorized with shall not be less than EUR 350,000.
• Business Plan: A comprehensive business plan should be provided which describes the proposed activity, including a risk assessment and risk management strategy.
• Management structure: The organization should prove proper organizational structures with lines of responsibility clearly defined and an adequate policy for risk management.
• AML Procedures: Implementation of AML and terrorist financing procedures.

Application Submission and Review Process

The application process involves the preparation and submittal of the necessary package of documents to the Lithuanian Bank. Once the application is submitted, the regulator will perform a detailed review of the information and documents provided.

• Application processing time: The application review usually takes 3 to 6 months, which depends on whether the documentation submitted is complete and how complicated it is.
• Audits and inspections: the State Bank of Lithuania might request some additional documents in addition during the review process or arrange meetings with the representatives for the sake of clarification.

The strategic geographical location, developed fintech infrastructure, and supportive regulatory environment create attractive conditions for e-money institutions in Lithuania. Compliance with all the above-mentioned requirements and careful attention to the application process will considerably enhance the chances of the company in successfully obtaining a license and further developing its e-money activity in the European market.

EMI regulations in the UK

The UK has long established itself as one of the world’s leading centres of financial innovation-particularly in the area of Fintech and e-money institutions. E-money institutions in the UK are controlled by the Financial Conduct Authority, which has imposed strict standards to make sure financial services are clear and transparent, safe and sound. In this article we’ll take a look at the main regulatory aspects for the e-money institution in the UK, using business language and a business style of communication.

Licensing Requirements

To start practicing electronic money activity in the UK, you need to gain a relevant licence from the FCA. To be able to do so, the company has to satisfy the following criteria:

• Share capital: The minimum size, in respect of share capital, will depend on the type of license applied for. £350,000+ for a full EMI license.
• Business Plan and Financial Projections: An elaborated business plan, which should include the description of a business model, financial projections, risk analysis, and mitigation strategies.
• Policies and Procedures: Develop and provide policies and procedures, including AML measures and customer data protection compliance.
• Management team: Evidence of the competence and reliability of the management team and key individuals responsible for the institution’s operations.

Application Submission and Review Process

• Application: It is presented to the FCA via its web portal, joining all the documents and information requested.
• Processing time: The processing of an application for the EMI license takes different periods but usually takes between 3-6 months from the date such an application was submitted, depending on the completeness and complexity of the submitted documentation.
• Assessment and verification: The FCA will review this information thoroughly, but in some instances may request further data or clarification.

Getting a license of an e-money institution is a very complicated and resource-intensive process, which needs serious preliminary preparation and attention to all nuances. Complying with FCA regulatory requirements and standards ensures a high level of safety and security in the services that can be provided by an e-money institution, which also contributes to consumer confidence and helps maintain stability in the UK financial system.

EMI regulations in Netherlands

The policy on e-money pursued by the Dutch government is similar to that of the majority of other EU members, keeping a balance between the safe and secure use of electronic money and providing an enabling environment for innovation and development of the industry. E-money institutions of the Netherlands are regulated by the Netherlands Bank, De Nederlandsche Bank, DNB and the Netherlands Authority for Financial Markets, Autoriteit Financiële Markten, AFM, which together guarantee the follow-up on the national and European regulations.

Licensing requirements

For starting an operation of being an e-money institution in the Netherlands, one should obtain a license from DNB. The basic licence requirements include the following:

• Authorised capital: It is EUR 350,000 for the establishment of electronic money in the Netherlands.
• Business Plan: A highly detailed business plan is to be provided, covering services offered, market analysis, marketing strategy, financial projections, and a risk assessment.
• Management structure and personnel: Experienced and qualified management and employees who enjoy good reputation and have relevant experience along with personnel policy.
• Anti-Money Laundering (AML) and Terrorist Financing Measures: Effective AML procedures and controls are to be in place and implemented.

Application and review process

• Application: The license application should be submitted via the DNB e-application facility, accompanied by all relevant documents and information, where applicable.
• Processing time: The average processing period for an e-money institution licensing application is 3 up to 6 months, depending on, amongst others, the complexity of the application and whether the application dossier is complete, accurate and adequate.
• Verification and Validation: In the course of review and verification, DNB and AFM undertake detailed scrutiny of data provided on financial stability, business model, risk management systems, and AML procedures of the company concerned. In case regulators require additional information, applicants may be invited for meetings or discussions with a view to seeking clarification on any aspect.

The Netherlands are very friendly to fintech companies, underlining innovation in the financial sector and maintaining a high level of consumer protection and stability of the financial system. For those companies who want to provide their services in the sphere of electronic money in the Netherlands, a very significant place should be taken by preparation for licensing in order to enter this promising market.

EMI regulations in Cyprus

Cyprus, as a full member of the European Union, fully respects European directives and regulations also in the field of electronic money. E-money institutions in Cyprus are regulated by the Central Bank of Cyprus (CBC) in line with the EU E-money Directive (2009/110/EC).

Licensing requirements

A license from the Central Bank of Cyprus is necessary for one to start operating as an e-money institution in Cyprus. The key requirements, among others, include:

• Authorized capital: The minimum amount of authorized capital for the establishment of electronic money is EUR 350,000.
• Business Plan: To be submitted in as much detail as possible, the business plan shall contain a description of services, market analyses, risk management, and financial projections of flows.
• Organization Structure: Proof of adequate organization structure and management experience that would be able to ensure the proper and efficient functioning of the institution.
• AML/CFT Politics: Politics and procedures against laundering and financing of terrorism are drafted and implemented.

Application and review process

• Application: The license application, together with all the supporting documentation and information, shall be submitted to the Central Bank of Cyprus.
• Duration for Processing an Application: The standard duration for processing generally ranges from 3 to 6 months. This period may, however, be influenced by the comprehensiveness and complexity of the application submitted.
• Additional Requirements: During the application processing period, the application shall be subjected to further requests by the Central Bank on the provision of more documents or complementing information/clarification.

Obtaining an e-money institution license in Cyprus is definitely a case of careful preparation and compliance with relevant regulatory requirements. Offering one of the most friendly legal and tax environments for Fintech, together with access to the European Union market, Cyprus is a choice which is hard to pass for many international e-money players. Companies looking to capitalize on such opportunities should pay due attention to preparation for the licensing process with a view to successfully entering the financial sector in Cyprus.

EMI – Poland

In recent years, Poland has been actively developing its fintech sector, aiming to become one of the leaders in Central and Eastern Europe in the field of innovative financial technologies. E-money institutions in Poland are regulated in accordance with the European E-money Directive (2009/110/EC) and local legislation governing financial services. The key role in licensing and supervision of e-money institutions is played by the Commission for Financial Supervision (KNF – Komisja Nadzoru Finansowego).

Licensing requirements

In order to pursue an e-money institution activity on the territory of Poland, it is necessary to obtain a licence in return for fulfilling the following requirements:

1. Business Plan: Provide a detailed business plan with the description of the company, risk assessment, marketing strategy, and financial projections among other things.
2. Management structure: Evidence of effective management structure with qualified management that enjoys a good business reputation.
3. AML Procedures: Develop and implement Anti-Money Laundering AML and Combating Terrorist Financing policies and procedures.

Application and review process

• Application: An application for a license, with all the supporting documents, is filed to the Financial Supervisory Commission.
• Processing time: Normally, processing takes from 3 to 6 months. However, it might take longer, depending on the complexity of and completeness of the documentation filed.
• Additional Requests: In the course of proceedings, the KNF may request additional information or arrange meetings with an applicant to discuss in detail the circumstances of the application for authorization.

Clear regulatory requirements and active support of innovation within the Fintech sector create favorable conditions for the development of e-money institutions in Poland. Needless to say, getting an e-license requires serious preparation and tight correspondence to all regulatory standards. Overcoming this barrier opens up dynamically developing financial services markets in Poland for companies and allows them to contribute to the progress of the country’s digital economy.

Regulation of EMI in Sweden

In Sweden, which is among the world leaders in the development of financial technologies, control over the functioning of e-money institutions is carried out by the Swedish Financial Supervision Authority (Finansinspektionen). The introduced norms should provide stability for the financial system, protection of consumer rights and prevent financial crimes.

Licensing requirements

To license an e-money in Sweden, the company shall meet the following minimum requirements:

• Business Plan: The undertaking shall provide a business plan, in which it describes the activity proposed, such as forecasted e-money transactions, risk evaluation, and arrangements for risk management.
• Management structure: The firm shall have an organizational chart showing lines of responsibility, proper internal controls, and risk management procedures.
• AML/CFT policies: Development and implementation of policies and procedures to avoid utilizing the company for money laundering and terrorist financing purposes.

Application and review process

• Application: An application for a license, along with all the necessary documents and information, shall be filed with the Swedish Financial Supervisory Authority.
• Processing time: The average time needed for processing an application is from 3 up to 6 months; this may vary, however, in accordance with the complexity of the documentation filed and their completeness.
• Additional Requests: In the course of processing the application, the Financial Supervisory Authority may request additional documents or clarifications with the view of understanding the way a specific business model or activities are performed by the company concerned.

The innovative economy and far-sighted regulation make Sweden a very good place for the development of an e-money institution. Licensing compliance, which allows a company to successfully pass the application process, opens up opportunities for operation in the Swedish market of e-money. Careful preparation of the whole process will be however required, focusing on the elaboration of a business plan, of management structure and policies on anti-money laundering and anti-terrorist financing answering the very high standards required by Swedish Financial Supervisory Authority.

EMI regulations in Germany

In Germany, one of the leading economies in Europe, the regulation of e-money institutions strictly complies with European standards and directives, ensuring a high level of consumer protection and stability of the financial system. E-money institutions are regulated by the Federal Financial Services Supervisory Authority (BaFin – Bundesanstalt für Finanzdienstleistungsaufsicht), which requires strict regulatory compliance and has high licensing requirements.

Licensing requirements

To operate an e-money institution, a license shall be obtained from BaFin. Amongst others, the following are the key elements which are required by any applicant looking to obtain a license:

• Authorized capital: The minimum authorized capital to establish electronic money should be at least EUR 350,000.
• Business Plan: It shall be presented in as much detail as possible, describing the proposed activity, market analysis, financial projections, and risk assessment that may arise from such activity.
• Management structure: The company shall have a sound management structure with well-defined responsibilities and appropriate risk management policies.
• AML Procedures: Establishment and implementation of effective procedures for AML and terrorist financing counteraction.

Application and review process

• Application: The license application shall be submitted to BaFin along with an application form and all supporting documents with proof of the above requirements.
• Processing time: The processing of an application usually takes 6 to 12 months, depending on the completeness and complexity of submitted documentation.
• Additional inquiries: In some instances, BaFin may ask for more information during the review process and request meetings with company representatives to discuss details of the application.

The regulation for the establishment of e-money in Germany is a multi-step procedural undertaking that requires careful planning and strict adherence to regulatory requirements. The license from BaFin is a very important milestone when conducting e-money business, opening ways for the market of one of the largest and most developed financial markets in Europe. A successful applicant needs to prove that his business model is not only economically sound and transparent but also highly responsible when it comes to risk management and regulatory compliance.

EMI regulations in Spain

In Spain, the regulation of e-money institutions comes under the scope of both national and European legislation. Regulation is targeted at providing stability to the financial system, protection of consumer rights, and preventing financial crimes like money laundering and terrorist financing.

License obtaining process

To initiate operation as an e-money institution in Spain, an entity has to obtain the respective license from the National Securities Market Commission, or through the Bank of Spain, depending on the kind of activity involved in a certain operation. The application must be supported by a detailed business plan, a description of the systems of risk management and control procedures, confirmation of observance of the requirement for minimum regulatory capital, liquidity, and others.

Requirements connected to the applicant

The applicant institution shall prove its financial strength, sufficient organizational structure, professional and reliable management, that it is able to comply with the regulatory requirements related to e-money activity. Particular attention is given to the data protection systems and measures against money laundering and financing of terrorism.

Amount of the necessary authorized capital

Where the extent of the planned activity so warrants, the minimum authorized capital of an e-money institution differs, but it needs to be at least 350,000 euros in conformity with European regulations. This sum is supposed to guarantee the institution’s financial stability and also cover start-up expenses and losses that are expected.

Application Processing Time

The time taken to process a license application will vary according to the complexity of the particular application and also with the workload of the regulatory authorities. On average, from the date that all documents have been submitted, it usually takes between 3 to 6 months. Timing and completeness of all information and documentation at the appropriate time greatly accelerate the review process.

Entering Spain’s e-money market needs serious planning and preparation, such as a well-thought-out business plan and conformation to demanding regulatory requirements. In fact, a license obtained successfully opens the dynamically developing financial sector of the country to an e-money institution and allows it to grow and develop. The key success factor is not obtaining a license but maintaining high standards of operations: the quality of customer service and safety and soundness of financial transactions.

EMI regulations in Italy

Italian E-money institutions are regulated according to the European e-money Directive (2009/110/EC), as well as national legislation, especially the regulations issued by the Bank of Italy. The mentioned regulations seek to guarantee market stability and transparency, consumer protection, and prevention of financial crime. In Italy, institutions have to apply for a license to be allowed to operate in the e-money sector, but also to comply with a series of requirements and ensuring a certain share capital level.

Licence obtention procedure

Applications for a licence shall be submitted to the Bank of Italy with a detailed business plan, explanation of the risk management system, information on managers and owners, and with documentation of compliance with the regulatory requirements concerning share capital. The application form is, therefore, analyzed from several standpoints by the Bank of Italy, which considers the financial strength of the applicant, the reputation and experience of the management team, and the sufficiency of systems and controls in place so as to prevent financial crime.

Applicant Requirements

• The business plan is well-structured to show its viability.
• To comply with the regulations concerning risk management and internal control would therefore be very desirable.
• Confirmation of the professional and responsible attitude of the management and key personnel.
• Sufficient anti-money laundering and Combating terrorist financing measures.

Amount of the required authorised capital

The minimum authorized capital for Italian e-money institutions is 350,000 euros. In general, such capital corresponds to the initial cost of operations and serves as a sort of financial cushion in case there would be losses. The amount of capital may be adjusted upwards depending on the scope of activities and risk assessment.

Application processing time

Accordingly, the time it takes to process the application for an e-money institution license in Italy varies but usually takes 3 to 6 months from the moment of submission of a full set of documents. The time taken to process an application can vary depending on factors such as the quality of the submitted documentation and the workload of the Bank of Italy at any given time. Full and accurate submission of all information and documents contributes to a faster review process.

Setting up an e-money facility in Italy requires a great deal of preparation and strict adherence to regulatory requirements, such as a detailed business plan, sufficient authorized capital, and an effective risk management system. Once successfully completed, this licence opens the floodgates for the firm into the well-woken and dynamic market for e-money in Italy, with bright prospects for enlargement and development within the financial markets.

EMI regulations in France

The authorization of e-money institutions, the exercise of the freedom of establishment, and the freedom to provide services concerning their activities in France are highly regulated and closely monitored by French financial regulators, particularly the Autorité de Contrôle Prudentiel et de Résolution (ACPR), operating under the auspices of the Bank of France. These requirements also encompass licensing, share capital, and procedural processes in the interest of consumer protection and stability of the financial system.

Licencing Process

It shall commence its activities in the form of an e-money establishment in France only after receiving a license from the ACPR. The application procedure involves the preparation of a number of documents, which need to be submitted to the competent authority: a business plan, description of the risk management system, including information concerning the executive and management team, proof of sufficient authorized capital. Applicants must also demonstrate an ability to comply with requirements set out under domestic law and regulations, in particular concerning AML and ATTF.

Applicant’s Requirements

• Having a well-drafted and realistic business plan covering financial projections and development strategy.
• Evidence of reliability and professionalism of management.
• Establishment of appropriate risk management systems and internal controls.
• Sufficiency of measures against money laundering and terrorist financing.

Amount of Required Authorized Capital

The minimum amount of authorized capital depends on the extent of the operations, but it usually needs to be at least €350,000. This capital gives the institution the financial stability necessary during the first period and acts as protection against possible financial risks.

Application Processing Time

The processing time for an e-money institution license in France may take three to six months on average. Again, this is greatly dependent on how complete the documentation is, the quality, and at what time the application was presented vis-à-vis the workload of ACPR. Thorough preparation for and submission of all required documents in full facilitates a swifter process.

Setting up an e-money institution license in France is very labor-intensive, from complying with stringent regulatory requirements to the preparation of a very detailed business plan, having an adequate share capital base, and showing that risk is well-managed and that regulatory standards are complied with. Once obtained, access is given to the promising but highly regulated French e-money market, which opens great opportunities for institution growth and further development.

EMI regulations in Ireland

Ireland, due to its strategic location and favorable tax regime, attracts many e-money institutions that are looking for an operating license within the European Union. Regulations regarding e-money institutions in Ireland are subject to European directives and local legislation; the main role in regulation and supervision plays Central Bank of Ireland, CBI.

Licensing Process

An Irish e-money institution operates on the basis of a license issued by the Central Bank of Ireland. Applying for it involves preparing a rather comprehensive package with respect to a document for submission, a detailed business plan, proof of financial strength, description of risk management systems, information about principals and beneficial owners, and compliance plans, including AML/CFT measures.

Applicant Requirements

The applicant institutions, for a licence, should be in a position to meet a number of requirements as laid down by the Central Bank of Ireland. The key ones are:

• Evidence of clearly defined organizational structure and adequate internal controls.
• Adequate and sufficient authorized capital.
• Professional competence and integrity of management staff should be checked.
• Efficiency in controlling different types of risks, like credit risk, market risks, operational risks, liquidity risk, capital risks, etc.

Amount of the required authorized capital

The minimum authorized capital for electronic money institutions in Ireland is €350,000. It gives assurance of the fact that the institution is financially sound to absorb current and future liabilities.

Application Processing Time

The time required for processing a license application may vary, but on average takes between 3 and 6 months from the date of filing of a full and complete set of documents. However, this period may be extended in accordance with the circumstances of the application and workload of the Central Bank at that particular moment.

The license of an Ireland e-money institution comes in a very well-prepared and regulated environment. Definitely, all those who manage to achieve it have to show financial strength and appropriate risk management, taking into consideration the commitment for high standards of operation. A license gives access to the EU market, which means great opportunities for growth and development in the e-money industry.

EMI regulations in Malta

Malta is actively developing its financial sector to become a leading centre in Europe for financial technology and innovation. E-money institutions in Malta fall under European Directives and local legislations, and the licensing and supervision role is directed by the Malta Financial Services Authority, MFSA. So far, Malta’s regulatory environment has been directed towards ensuring that stability and soundness of the financial system go hand in hand with protection of the consumer’s interests.

Application Process for License

In order to be able to commence activities as an e-money institution in Malta, one should obtain a license from MFSA. It involves extensive preparation of the application package, to be supported with a detailed business plan, description of internal processes and policies, management details, and evidence regarding the compliance of authorized capital and financial stability. The applicant shall also point out the risk management systems besides adherence to money laundering and terrorist financing prevention requirements.

Requirements for Applicant

The major requirements of the applicant shall include:

• Having a clear and realistic business plan describing the proposed operations, market strategies and financial projections.
• A transparent organisational structure with a clear division of responsibilities and authority.
• Sufficient and adequate authorised capital to support start-up activities and risk management.
• Systems and procedures for effective risk management, including credit, operational, market, liquidity and capital risks.
• Measures to combat money laundering and terrorist financing.

Amount of the required authorised capital

The minimum share capital varies based on the license type and the scope of the proposed activity, but normally it is in the range of €350,000 for entry-level activities. This should be viewed as adequate to cover all risks and liabilities pertaining to the activities of the institution.

Application Processing Time

The time to process a licence application can take between three and six months, depending on the intricacy of the application and the workload of the MFSA at the time of submission. Suffice it to say that the whole review process is considerably shortened if all required documents and information are filed in a timely and complete manner.

E-money institutions seeking to operate in Malta should be suitably planned for licensing, keeping in mind strict compliance with all requirements, with a view to actually demonstrating that they are capable of managing risks effectively and maintaining financial stability. Upon acquisition of a license, this will lead to access in a vibrant e-money market situated in a jurisdiction offering an attractive regulatory and tax regime that therefore holds immense possibilities of growth and expansion.

Regulacje EMI w Luksemburgu

The Grand Duchy of Luxembourg is one of the leading financial centres in Europe, so its conditions are pretty well-suited for developing e-money institutions. Regulation of the mentioned financial institutions in Luxembourg is provided by the Commission de Surveillance du Secteur Financier, CSSF, in full accordance with European directives, as well as with local legislation. This helps ensure financial stability in the markets, consumer protection, and control of financial crimes.

License Application Procedure

Any e-money institution should be granted a license by CSSF before commencing its professional activities within the territory of Luxembourg. The process of application is profound preparation and is submitted with the comprehensive set of documents, comprising a detailed business plan, description of the risk management system, information on the principals and beneficial owners, proving compliance with regulatory capital and financial strength requirements. An applicant needs to provide evidence of the ability to comply with legal and regulatory requirements, including AML/CFT measures.

Requirements for the Applicant

• A well-defined and solid business plan including financial projections and expansion plans.
• Organizational structure clearly defined and internal controls appropriate.
• Authorized capital to be adequate to support start-up and cover risks.
• Policies and procedures to be implemented to ensure compliance with anti-money laundering and counter-terrorist financing legislation.

Amount of the Required Authorized Capital

The minimum capital for e-money institutions in Luxembourg is €350,000. This kind of capital is needed to ensure the institution’s financial soundness to meet both liquidity and operational requirements.

Application Processing Time

The processing time for the license application by an e-money institution varies in Luxembourg, but on average, it generally takes between 3 to 12 months, depending on the complexity of the file and the workload of the CSSF at the given moment. It is worth underlining that completeness and quality of documentation will have a great impact on the speed of the application.

E-money institutions licensed to operate in Luxembourg are required, before starting their activities, to be suitably prepared and meet regulatory requirements before commencing said activities. Because of its membership in the European market and the generally favorable regulatory environment, Luxembourg remains one of the most desirable countries for many fintech companies. It is important that the whole licensing procedure be handled with due care and professionalism in order to develop a successful business in this jurisdiction.

PI regulations in Europe

PSP/ PISP regulations in Europe

The regulation of Payment Service Providers in Europe is a factor that should ensure safety, security, and efficiency in the payment systems in the region. This is done at the European Union level through several directives and regulations aimed at providing a single market for payment services. Basic regulatory framework EMD and PSD2 provides the legislative foundation for licensing, risk management, consumer protection and anti-money laundering.

Licensing process

To begin its operation, a payment service provider has to apply to the national regulator of the EU Member State where it would like to carry out its activities for a license. This involves quite an extensive set of documents to be prepared and submitted along with the application that will prove the firm’s compliance with the requirements of the regulator. The list includes a business plan, risk management policies, internal control systems, information on managers and founders, proof of financial stability.

Requirements from the Applicant

Payment service providers should be able to prove the following:

• There is an explicit organisational structure and appropriate risk management procedures in place.
• It has qualified management and fulfils requirements regarding clean reputation.
• It is capable of safeguarding customer funds and offering a high degree of security regarding payment transactions.
• It meets anti-money laundering and counter-terrorist financing requirements.

Amount of the Required Authorised Capital

The minimum level of capital that is required from payment service providers depends on the level of the provided services and starts from 20,000 up to 125,000 EUR for start-up positions. In cases of large operators offering extensive portfolios of payment services, the requirement for capital can be much higher.

Application processing time

The time that is spent processing the license applications also varies from one country to another and from one regulator to another, with an average period ranging from 3 to 12 months. It is good preparation and completeness of the documents presented that will reduce the time needed for the processing of an application.

First of all, the licencing of a Payment Service Provider in Europe needs a lot of preparation and strict adherence to regulatory requirements. That means, among other things, preparing all the documents for filing that simultaneously develop effective risk management and internal control systems in support. Once this process is completed with flying colors, it opens up the single European market to payment services, along with great opportunities for growth and development in Fintech.

AISP regulations in Europe

Account Information Service Providers, or AISPs, act as a bridge to European financial ecosystem users by giving them an overview of their financial information through various bank and financial accounts on a single interface. The operation of AISPs in Europe is regulated under the Second Payment Services Directive-PSD2, targeted at ramping up competition and innovation in the field of payments, along with fostering better consumer protection.

Procedure to be followed for obtaining a licence

The licence for account information services providers should be obtained from the national regulator where the firm is incorporated. The application procedure requires addressing the business model, management information, anti-money laundering and counter-terrorist financing measures, and security and data protection systems. Internal control and risk management policies should also be demonstrated.

Applicant requirements

Size of the required authorized capital

The European Commission did not impose any strict minimum share capital requirements for AISPs, unlike in the case of the institutions of payment or e-money. However, national regulators are entitled to establish their own requirements with respect to financial stability of companies, depending on the scope and specificity of their activity.

Application Processing Time

The time it takes to process an application for the license of AISPs varies from country to country. However, generally speaking, the duration does not usually take more than 3 to 6 months. It can take more than that, depending on how complete and qualitative the submitted documents are, and the requirements of the national regulator.

Obtaining a license for account information service provision in Europe calls for imminent preparation, ensuring full observance of the set regulatory requirements on data protection and risk management. Once approved for a license, open access to the wider European Union market will be granted to all AISPs to develop and expand their financial technology businesses.

PI regulations in Lithuania

Lithuania has become famous during recent years as one of the leading centres of the fintech industry in Europe with a very favorable regulatory and business environment for payment service providers, including payment institutions. Regulation in this area is carried out by the Bank of Lithuania, which performs the function of the main regulator and supervisor.

Process for obtaining a licence

To start their operations, a payment service provider should obtain an appropriate licence from the Bank of Lithuania. The respective application with a package of documents must be filed. Usually, the business plan, description of the risk management system, information about managers, founders and owners of the undertakings, evidence of financial stability must be included in the package. The applicant will have to prove its capability of observing the legal and regulatory requirements, including anti-money laundering and anti-terrorist financing measures.

Applicant’s Requirements

• Capital Adequacy: A payment service provider shall prove to have adequate share capital and financial strength to carry out the activities it proposes to undertake.
• Directors and Management: There shall be evidence that the management and key personnel of the organization are reliable and professionally competent.
• Compliance with legislation: The Company will ensure compliance with the legal requirements of Lithuanian and EU legislation, including data protection, anti-money laundering, and countering the financing of terrorism, among others.

Amount of the required authorised capital

The minimum share capital required for the payment service providers in Lithuania depends on the type of license a firm is applying for. In terms of the payment institutions, the minimum can range from EUR 20,000 to EUR 125,000, depending on the scope and specifics of the services provided.

Application processing time

The term of processing of the application for a payment service provider licence in Lithuania is from 3 up to 6 months from the date of submission of a full set of documents. The processing time depends on the complexity of an application and the workload of the Bank of Lithuania at the given moment.

Very favorable conditions for the development of payment service providers and their integration into the European financial market are created in Lithuania. Strict but just regulation from the part of the Bank of Lithuania is a warranty of very high confidence in the activity of organizations that provide payment services and an important ground for sustainable growth and continuous development. Obtaining a licence demands long-term and serious preparation, strict adherence to regulatory requirements; however, it opens vast opportunities in the EU market.

PI regulations in the UK

The UK has created an excellent environment for developing payment services and payment organisations and has been considered as one of the world’s leading centres of financial innovation. In addition, the Financial Conduct Authority (FCA) is in charge of regulation here and tries to maintain the integrity and stability of the financial markets of the United Kingdom.

Procedure to get a Licence

To conduct the activity of a payment service provider in the UK, it is necessary to obtain an appropriate license from the FCA. The licensing application involves preparing and submitting an elaborate package of documents. There should be included a business plan, information about directors and beneficial owners, a description of a risk management system, and policy and procedures to observe legislation on anti-money laundering and counter-terrorist financing.

Applicant’s Requirements

• Financial strength: One should prove that the company has sufficient authorized capital and financial strength.
• Management: The management should be qualified, reputed, and with experience in finance.
• Compliance with Laws and Regulations: The Company must ensure that it complies with all legal and regulatory requirements including those on GDPR and FCA rules.

Quantum of the required authorized capital

All this depends on the type of payment services offered, and the amount of such authorized capital. For example, the FCA has different minimum share capital requirements for payment institutions and e-money issuers. Starting from £20,000 for some categories up to much higher amounts for organizations that are engaged in a wider range of payment services.

Application processing time

The time it takes to process an application for a licence can vary and is dependent upon many factors including, but not limited to, the completeness and quality of the documentation submitted and the current workload of the FCA. The average time it takes to complete an application varies between 3 and 6 months but for some applications, this could be longer.

The UK offers secure and transparent conditions for the regulation of payment service providers, favoring innovation and consumer protection. Obtaining a license with the FCA requires much effort of preparation and complete adherence to strict rules. When accepted, candidates will have opened the door to one of the world’s most developed financial markets, enjoying full trust and support from the regulator.

PI regulations in the Netherlands

The country has placed itself as one of the drivers of fintech and innovation in Europe, providing a relatively favorable climate for the development of both payment service providers and also payment organisations. These services in the Netherlands are controlled by the DNB, the Dutch Central Bank, and the Authority for the Financial Markets of the Netherlands (AFM), which ensure that security, transparency, and reliability are observed at high standards.

Licensing Procedure

The whole licensing process for a payment service provider in the Netherlands, through either DNB or AFM, starts with the submission of the application. In this respect, it should be focused on preparing and submitting an application package in respect of all the requirements, which in general would comprise a business plan, a description of the internal organizational structure, information on management, risk management policies, and anti-money laundering and anti-terrorist financing strategies.

Requirements for the applicant

• Financial strength: There is a requirement that the company have enough authorized capital and be able to continue financial stability.
• Management and organization structure: The management should be qualified and of undoubted good repute and have an adequate organizational structure of the applicant’s management.
• Regulatory Compliance: The Company shall at all times observe all relevant Dutch and European Union legislative and regulatory requirements including, but not limited to anti-money laundering and counter-terrorist financing regulations.

Amount of required authorized capital

The minimum authorized capital for payment service providers in the Netherlands, depending on the type of activity and accordingly, may be as follows: for example, for payment institutions, from EUR 125,000. In general, the capital requirements depend on the scope and nature of the provided payment services.

Application processing time

The processing of the license usually takes 3 to 6 months, though it may take longer depending on the complexity of the application and the workload of the regulator. Complete and accurate documentation is preferable in order to expedite the process as much as possible.

The Netherlands offers a stable, well-regulated environment to payment service providers, which nurtures innovation while protecting consumers. It is only the carefully prepared and strictly compliant applications that will get their license. On the other hand, successfully licensed candidates shall have the opportunity to work in one of Europe’s most innovative and developed financial markets.

Cyprus PI REGULATIONS

The Republic of Cyprus is a member state of the European Union and therefore offers an extremely favourable environment for the development of financial technology and payment services, which makes this country so attractive for companies from all over the world. The activities of the payment service providers and payment organisations in Cyprus are regulated either by the Central Bank of Cyprus or by the Cyprus Securities and Exchange Commission, CySEC, depending on the provided services. These regulators assure compliance of companies with local legislation as well as European legislation, such as the Payment Services Directive (PSD2), devised to enhance transparency and security of payments in the EU.

Licensing Procedure

At the same time, to get licensed, a payment service provider needs to file an application with the Central Bank of Cyprus or CySEC. It will include some hectic preparation and submission of a voluminous set of documentation that needs to cover such aspects as a business plan, information about principals and beneficial owners, description of the risk management system, and evidence of financial stability and anti-money laundering measures.

Requirements for the Applicant

• Financial strength: It shall be adequately capitalized with authorized capital and have the financial strength to carry out proposed activities.
• Management: The management shall be qualified, experienced, and have a good track record in the financial sector.
• Legal Compliance: It shall ensure full compliance with all regulatory requirements, such as Cyprus laws, and EU directives, notably on data protection and anti-money laundering.

Amount of the required authorised capital

The minimum amount of share capital for payment service providers in Cyprus depends on the type of license and may start from €20,000 for small payment institutions up to €125,000 for full payment institutions. Requirements are given in more detail depending on the volume and nature of the payment transactions to be performed.

Application processing time

The time generally taken to process a licence application falls between 3 and 6 months. However, this can change depending on the complexity of the application in question and the workload placed upon the regulator. It is prudent that the documentation presented is accurate and complete to ensure that the review process is done in a timely manner.

Cyprus develops into a very attractive place for payment service providers, offering stringent yet reasonable regulatory requirements with direct access to the Single European Market. In turn, thorough preparation and compliance are in order when obtaining a licence. Whoever manages to succeed in this respect is allowed to work in a stable, innovative financial environment that leads to further growth and development in the industry of payment services.

PI Regulations in Poland

The State of Poland is actively developing its financial sector and fintech industry, creating favorable conditions for both payment service providers and payment organisations. Regulation of this sphere in Poland is provided by the Financial Supervision Commission (Komisja Nadzoru Finansowego, KNF) responsible for supervision and control of financial markets, including payment services. It provides rules for market stability and transparency, safeguarding consumers’ interests.

Licensing Process

Regarding the above, it should be noted that any payment institution that wishes to start its activity within Poland must obtain a license from the KNF. The following procedure for this license also encompasses the preparation and submission of a full package of documents, such as a business plan, information on managers and owners, the description of the risk management system, and evidence of compliance with requirements of authorized capital and financial stability. Applications need to prove their capability of observing regulatory requirements among which anti-money laundering and counter-terrorist financing measures are present.

Applicant Requirements

• Financial strength: It should be sufficiently capitalized with authorized capital to carry on a business.
• Governance and management: Management should be qualified, have a good business reputation, and the organizational structure should be sufficient.
• Compliance: The Company must comply with all the relevant legal and regulatory requirements including the ones on data protection and anti-money laundering.

Amount of the required authorized capital

The minimum authorized capital of a payment service provider in Poland depends on the type of the activity carried out. For the payment institutions, the minimum required share capital ranges from EUR 20,000 to EUR 125,000 depending on the scope and specifics of the services provided. For more detailed information, please refer to the official website of KNF.

Processing of Application

The average time required for processing an application for a license for a payment service provider in Poland is between 3 to 6 months; however, actual processing may take longer or shorter, depending on the specific complexity of the particular application under review and/or the workload of the KNF at the given time. Completeness and accuracy of the submitted documents can expedite the process of review.

The regulatory and business environment in Poland is, therefore, congenial in allowing innovation and competition to come to the fore in the financial market. The preparation and qualification for the licence are well-regulated, with strict adherence to the established requirements. After eventual selection, they will get an opportunity to work in one of the fastest-expanding financial markets in Europe by furthering the growth and innovations in payment services.

PI regulations in Sweden

Sweden is considered one of the leading centres of innovation in financial technology in the world. Due to such a position, the surrounding conditions in Sweden are perfect for setting up payment service providers and payment organisations. According to the Act on Payment Services, the regulatory environment of this country is centred around the Swedish Financial Supervisory Authority, Finansinspektionen, or simply FI, in charge of licensing and supervision in the field.

Licensing procedure

For operation, the Payment Service Provider shall apply for a license from the FI supported by an application form containing a comprehensive application package. The content thereof shall include a business plan, information about principals and beneficial owners, description of the risk management system, and proof concerning compliance with authorized capital requirements. In addition, it is necessary for applicants to assure the FSA of their capability to satisfy regulatory requirements, including anti-money laundering and counter-terrorist financing measures.

Applicant’s Requirements

• Capital Adequacy: The firm has to ensure that it is adequately capitalized with authorized capital for the conduct of proposed activities.
• Directors and Management: It should be managed by qualified management, its directors must enjoy a good business reputation, and there should be a proper organizational structure.
• Compliance: The Company shall comply with all applicable legal and regulatory requirements, including obligations relating to data protection and anti-money laundering.

Scope of Required Authorized Capital

The minimum authorized capital for the payment service providers in Sweden depends on the type of activity and can begin with SEK 50,000 (approximately EUR 5,000) for the status of a payment agent registration up to as much as SEK 2 million (about EUR 200,000) for a full-fledged payment institution license.

Application Processing Time

The time frame for processing an application for a licence as a payment service provider in Sweden normally takes an average of 3 to 12 months depending on the complexity of the case and on the workload of the FI. Quite understandably, it will help if the documentation is available and complete and accurate in order to expedite the review process.

The Swedish licensing environment is one of the most innovative and friendly to payment service providers in Europe, therefore allowing the development and growth of the fintech industry. Acquiring a license requires preparation and strict adherence. As a candidate who later emerges with the license, you can work in a progressive and dynamic financial market that offers innovative solutions in payment services.

PI regulations in Germany

With this country taking one of the leading positions in the European economy, there is big potential for payment service providers and payment organisations. The Financial Federal Services Supervisory Authority or short BaFin is responsible for ensuring that the financial sector behaves with a high level of safety, transparency and reliability.

Licensing procedure

The payment service providers in Germany have to start their operations after receiving a licence from BaFin. The application procedure requires the elaboration and submission of the documents, including a business plan, information about directors and beneficial owners, a detailed description of the risk management system and internal control procedures, together with proof of financial strength and compliance with the requirements on authorized capital.

Requirements Applicant

• Financial strength: The supplier must be able to prove that it has adequate authorized capital to support its operations.
• Leadership and management: Evidence of management qualifications and reliability; an effective organizational structure.
• Regulatory compliance: The Company must comply with German and EU legislation, including anti-money laundering and counter-terrorist financing regulations and data protection requirements.

Amount of the required authorized capital

The minimum German required authorized capital for a Payment service provider depends on the type of provided services. It can range from €50,000 to €125,000, for example in case of a payment and e-money institution. Detailed information is best directly obtained from BaFin or other specialized legal advisors.

Application processing time

The processing time for a license application differs, but it takes on average from 3 to 6 months depending on the application’s complexity and workload at BaFin. In order to speed up the review process, one has to file a complete and accurate set of documents.

Payment service providers face a very strict but just regulatory environment in Germany. Innovation and consumer protection are right next to each other. In turn, license acquisition presupposes serious preparation and strict conformation. Successful candidates get immediate entry to one of the largest and most advanced financial markets in Europe, providing huge avenues for growth and expansion.

PI regulations in Spain

Spain is among the active participants in developing financial technology and the payment services market in Europe. In-country payment service providers and payment organizations are regulated by the National Bank of Spain-Banco de España, and are under European legislation, namely the Payment Services Directive-PSD2, which seeks to enhance payment security and consumer protection.

Process for obtaining a licence

A Payment Service Provider who wants to start a business in Spain needs to obtain a license from Banco de Espana and this is done by applying and submitting the following: a business plan; information about principals and owners; proper description of risk management system; documents regarding compliance with requirements on authorized capital, financial strength; and possible compliance with regulatory regime, anti-money laundering, and counter-terrorist financing requirements.

Applicant’s requirements

• Economic solvency: providers shall possess the appropriate amount of authorized capital to support business operations effectively.
• Direction and management: Management qualified with good business reputation.
• Compliance: The Company shall be subject to and in compliance with all applicable Spanish and European Union legislation in respect of anti-money laundering and counter-terrorist financing.

Authorised capital amount required

The minimum authorized capital for payment service providers of Spain depends on the type of services provided, thus it differs. For the purposes of registering as a Payment Institution, the minimum authorized capital is usually €20,000-€125,000, depending on the volume of operations and services provided.

Application processing time

The time required to process an application normally ranges from three to six months, depending on the completeness and complexity of the documentation filed and Banco de España’s workload at any given time.

At the same time, Spain is a very good place for developing payment service providers with the highest level of innovation and competition on the market, with the most strict adherence to regulatory requirements, enabling any financial transaction to be safe and transparent. On the corresponding note, preparation and adherence to acquiring a license are strict. The successful candidates get access to one of the biggest European markets, opening important opportunities for growth and extension of their presence in the payment services market.

PI regulations in Italy

Italy, with a dynamic financial sector and an innovative Fintech industry, is considered a very attractive place for payment service providers and for payment organizations. Regulated by the Banca d’Italia and Italian Markets and Competition Authority—also known as the Autorità Garante della Concorrenza e del Mercato or AGCM—these ensure the application and enforcement of European and national legislation, including PSD2, with a view to enhancing security in payments and consumer protection.

Application process

According to the Italian Normative, in order to provide payment services in Italy, a license from the Bank of Italy must be applied for. For the application procedure, quite an extended set of documents is to be prepared and filed: a business plan, information on directors and beneficial owners, a detailed description of the risk management system and internal control procedures, proof of financial strength, and conformity with the share capital requirements.

Applicant Requirements

• Financial capability: It must be proved that the company has sufficient authorized capital for its activities.
• Leadership and management: This can be proved by showing managers’ qualifications and reliability, efficient organizational structure.
• Compliance: The Company will have to comply with Italian and EU legislation.

The minimum authorized capital for payment service providers in Italy depends on the type of activity. Normally, for payment institutions, the minimum is from EUR 125,000. For e-money institutions, it may be more and shall be calculated depending on the volume of transactions and services provided.

Application processing time

The entire process of a license application usually takes 3-6 months but can be longer or shorter due to the completeness and complexity of the documentation provided and also based on the workload of the Bank of Italy at that particular moment in time. An expedited review could be facilitated if all documents are complete and accurate in the first instance.

Italy creates an extremely favorable environment in which payment institutions can develop and expand their activities within the European market. The strict but fair regulatory requirements helped instill a high level of trust and security in the financial sector. Acquiring a license involves thorough preparation with strict adherence to the requirements. Once granted, lucrative opportunities open one’s gates toward a dynamic market that fosters innovation and competition in payment services.

PI Regulations in France

In France, the payment service providers along with the payment organisations fall under the strict supervision of the French Prudential Supervision and Resolution Authority, in French Autorité de Contrôle Prudentiel et de Résolution (ACPR), part of the Banque de France. This regulatory environment is set to ensure financial stability of the system, consumers’ protection and fight against financial criminality, including money laundering and terrorist financing.

Licensing Procedure

Before commencing the activity, a payment service provider should submit an application to the ACPR for authorization. The licensing procedure includes extensive preparations and submissions of all kinds of documents, including a business plan, information about directors and beneficial owners, a description of the risk management system and internal control procedures, proof of financial stability, and compliance with the requirements concerning authorized capital.

Applicant Requirements

• Financial strength: The Company must demonstrate that it is adequately capitalized with authorized capital.
• Leadership and management: Management competent to operate the business with good business repute.
• Compliance: The Company must be in compliance with French and EU legislation, including anti-money laundering and counter-terrorist financing legislation.

The minimum authorized capital for France’s payment service providers differs according to the type of services involved. Generally speaking, this minimum varies from 20,000€ to 125,000€, depending on the scope and specificity of the services provided.

Processing Time of Application

The processing time for an application in France of a license as a payment service provider takes approximately 3 to 6 months. It would also depend on the completeness and complexity of the documentation submitted and on the current workload of ACPR.

France is among the European leaders in creating conditions for the successful development of financial institutions that provide payment services, emphasizing innovative approaches and security of clients’ needs. Strict but fair regulatory requirements create a very high level of confidence in the financial sector. A license can be obtained only after serious preparation and strict compliance with the requirements. Having received a positive decision, an applicant gets access to one of the largest and most developed financial markets in Europe, which opens huge prospects for the growth and expansion of business in the field of payment services.

PI regulations in Ireland

Ireland is an attractive jurisdiction with a favorable tax regime and open economy for many international and local fintech companies and payment service providers. Payment services, and payment organisations providing such services in Ireland, are regulated by the Central Bank of Ireland in line with applicable European directives, among others the PSD2 that was enacted in each EU state with the purpose of enhancing the security and innovation of the payment market.

Application process

Financial institutions needing to provide payment services in Ireland have to apply for a licence with the Central Bank of Ireland before they can commence operation. The application in such a case would be filed with the detailed package of documents, which should include but not be limited to the following: a business plan, information on principals and beneficial owners, a description of the risk management system and internal controls, verification of the fulfillment of statutory capital and financial stability requirements. Information related to anti-money laundering and anti-terrorist financing measures would also be required.

Requirements for the Applicant

• Financial strength: Suppliers should be in a position to demonstrate that they possess at least an amount of authorized capital necessary for the effective start of the business operation and its continuation thereafter.
• Leadership and management: Qualified management who enjoy a good reputation in the business arena with an appropriate organizational structure.
• Compliance: The Company must be in compliance with relevant Irish and EU legislation and regulatory requirements.

The minimum authorized capital varies on the type of services a payment service provider may provide. It typically starts at €20,000 for payment institutions. However, this amount may vary based on the particular services provided and on the scope of business conducted.

Application Processing Time

The in-processing duration for an application for a Payment Service Provider License in Ireland is indeterminate, averaging 3 to 6 months. The actual time it takes to process an application depends on how complete and correct the documentation is at the time of presentation and on the workload of the Central Bank at any given moment.

Ireland offers a secure and supportive regulatory environment for the fostering of innovation in payment services while at the same time giving high priority to consumer protection. Obtaining a license is quite burdensome, since preparation for this procedure can be really time-consuming and requires ultimate adherence to the regulatory requirements. In return, successful candidates are presented with a great opportunity to extend their business in one of the most vivid and open markets in Europe, to enjoy the substantial advantages provided by the favorable tax regime, and to benefit from access to a wide range of financial and technological innovations.

PI regulations in Malta

With its friendly business climate and advanced financial technology regulation, Malta offers specific opportunities not only for payment service providers and payment organisations but also for any other people involved in this sphere. Malta strives to be among the first in innovative and technological development by giving businesses a transparent, fast, and effective regulatory environment.

Regulatory structure

Payment services in Malta are regulated by the Malta Financial Services Authority. The MFSA is the central authority responsible for the licensing and supervision of payment service providers and payment organisations in terms of European and local legislation.

Licensing requirements

1. Applicant: Should be legally constituted in Malta. For an applicant to be granted a licence, it must also provide a detailed business plan outlining the nature of the proposed activity, management structure, operational procedure, and anti-money laundering measures.
2. Share capital: The share capital for most licences with regards to payment institutions varies from a minimum of €125,000 to a maximum of €1,000,000.
3. Application processing time: The application process can take from 3 to 6 months, depending on the complexity of the application and the information provided.

Oversight and compliance

Payment service providers in Malta should be in a position to meet strict risk management, AML/CFT requirements, and customer data protection. The MFSA conducts regular audits necessary for compliance with applicable regulatory requirements.

The regulatory environment in Malta offers an enabling platform for innovative fintech products and related services to be developed and integrated. It is important to underline, however, that the acquisition of a license, on the one hand, and the running, as such, of a payment services operation, on the other, do presuppose the necessary preparation, awareness of the relevant requirements set out in local legislation, and the advice and consultations provided by well-qualified and experienced lawyers and accountants.

To avail yourself of the most recent information and guidance, it is advisable to contact the MFSA and qualified legal persons specialising in financial services regulation in Malta directly.

PI regulations in Luxembourg

The Commission for the Supervision of the Financial Sector – CSSF- is the main regulator that issues licenses and regulates payment service providers in Luxembourg. It’s guided by the European EMD (Electronic Money Directive) and PSD2 (Payment Services Directive) aimed to establish an EU single market for payment services.

Licensing requirements

1. Application: Applicant organisations need to file a detailed business plan with the CSSF, including a description of the services offered, risk analysis, organisational structure, and anti-money laundering and counter-terrorist financing measures.
2. Authorised capital: As regards payment service providers, the minimum level of authorised capital will depend on the type of services provided by those providers. In the normal course, for most payment institutions, it is in the range from €125,000 up to €2,000,000.
3. Application Review Time: The review process of the application by CSSF will take from 3 to 12 months, depending on whether the documentation submitted is complete and how complex it is.

Oversight and compliance

Payment institutions should follow certain requirements of CSSF, which relate but are not limited to the following: rules regarding risk management, customer data protection, and AML/CFT requirements. CSSF also regularly conducts inspections and audits as regards observing the mentioned requirements accordingly.

The Luxembourg environment for developing business in the payment services industry is highly regulated, innovative, and open. A license can only be obtained when it is carefully planned with deep insight into the understanding of the requirements that the Regulations entail, in close cooperation with the CSSF itself during the application process. It is highly advisable to take aboard professional legal and financial advisors with specific expertise in financial regulation in Luxembourg, who will be able to properly guide the operation through all requirements to achieve a successful market launch.