In the European Union, Electronic Money Institutions (EMIs) can be authorised under two different regimes:

1. Full EMI Authorisation

This is a full license under the Electronic Money Directive (2009/110/EC) and allows a company to:

• Issue electronic money (e-money)

• Provide payment services (like those under the Payment Services Directive – PSD2)

• Passport its services across the EEA (European Economic Area)

• Hold client funds and issue payment instruments (e.g. prepaid cards, wallets)

Key Requirements typically include:

• Minimum capital: €350,000

• Robust governance and risk management

• Anti-money laundering (AML) policies and procedures

• Business plan and financial projections

• External audit and compliance requirements

• Fit and proper assessment of directors and shareholders

2. Small EMI Authorisation

This is a light version of the EMI license, designed for smaller e-money issuers operating on a limited scale only in their home country.

Key Differences and Limitations:

• No passporting: Cannot offer services in other EEA countries.

• Lower capital requirement: Usually much less than €350,000 (e.g., as low as €50,000 or depending on local rules).

• Turnover limits: Annual average outstanding e-money is often limited (e.g., less than €5 million).

• Simplified compliance: Reduced requirements for governance, AML, and reporting.

• No access to central banks’ settlement systems

Summary Table