Estonian E-Money Institution (EMI) Licence

An electronic money institution (EMI) is a company that is authorised to issue electronic money and to provide payment services, without being a bank. In Estonia, e-money institutions are authorised and supervised by the Estonian Financial Supervision Authority (Finantsinspektsioon). The Estonian rules implement the EU E-Money Directive and the Payment Services Directive, so the core concepts are shared across the European Union.

This guide explains in general terms what an EMI licence allows, how it differs from a payment institution licence, what the main stages of the process are, and how we work with clients who want an Estonian e-money institution.

What electronic money is

Electronic money is monetary value stored electronically, issued in exchange for funds, and accepted as a means of payment by people other than the issuer. In practice, e-money is the balance on a prepaid card, on a digital wallet or on an account-like product offered by a non-bank financial company. The customer pays in euros, receives e-money of the same value, and can spend it or redeem it back.

What an EMI licence allows

An e-money institution may, within the scope of its authorisation:

issue electronic money and redeem it at par value;
provide payment services, such as transfers and card payments, including services linked to the e-money it issues;
carry out activities closely related to those services.

An EMI is still not a bank. It may not take deposits or lend out customers' e-money funds, and the funds received in exchange for e-money must be safeguarded as the law requires. It also may not pay interest on e-money balances.

After authorisation in Estonia, an EMI may in principle offer its services in other EU and EEA countries through the passporting procedure, which begins with a notification to the Estonian supervisor. Whether and how that applies to your plans must be assessed case by case.

EMI or payment institution?

If your product only moves money from one party to another, a payment institution licence may be enough. If customers will hold a balance with you and spend it later, you are most likely issuing e-money and need an EMI licence. The EMI licence generally involves a higher initial capital requirement and more extensive safeguarding and control requirements than a payment institution licence. Because the choice affects the whole project, it should be settled at the very beginning.

The main stages of the process

The exact requirements are set by law and by the supervisor's guidance and change over time. In general:

Product and scope. Define the e-money product and the payment services, the target customers and countries, the distribution model (for example through agents or distributors) and the expected volumes.
The Estonian company. The applicant is an Estonian company with management and a real presence in Estonia as required for a supervised institution.
People and ownership. Managers must be suitable and experienced. Owners with a qualifying holding are assessed, including the origin of their funds.
Capital and own funds. The institution must hold the required initial capital and meet ongoing own-funds requirements linked to its e-money in circulation and its payment volumes.
Application documents. Typically a business plan and financial forecast, governance and internal control arrangements, anti-money laundering and counter-terrorist financing rules, safeguarding of customer funds, IT and security, risk management, outsourcing, business continuity and the agreements with key partners such as banks and card schemes.
Assessment by the supervisor. The Financial Supervision Authority reviews the application, usually asks for additional information, and then decides. A state fee is payable.
After authorisation. The institution must continue to meet all requirements, report regularly and keep its systems and documents current.

The overall timeline depends on the complexity of the product, the quality of the documents and the supervisor's questions. We do not promise a fixed date.

How we work with you

The Estonian e-money institution (EMI) is listed on our licensed and regulated companies page with a "from" price, which means it is quoted individually.

Fill in the quote request form: choose "Estonian e-money institution (EMI)", describe the planned activity, the ownership structure and the desired timeline, and add your contact details.
We review your information and reply by email with a quote that states what is included.
No work starts and no payment is taken before you have received and accepted the quote.

State fees are not included in our prices and are charged separately.
The decision is made by the Financial Supervision Authority. We cannot guarantee that a licence will be granted, or when.
We are licensed by the Estonian Financial Intelligence Unit (licence FIU000117) and must carry out due diligence on our clients, including the owners and managers of the planned institution.
All communication takes place by email.

Questions worth answering before you apply

Will customers hold balances with you, or will funds only pass through? This decides EMI versus payment institution.
Which countries will you serve, and will you rely on passporting?
Who will be the owners and managers, and can they document their experience and the origin of their funds?
Which bank will hold the safeguarded funds, and which partners will you rely on for cards or infrastructure?
What volumes do you expect in the first years, and how will the capital be financed?

Having clear answers makes both our quote and the later application much more precise.

Related guides

This guide is general information about Estonian e-money institutions and our service. It is not legal advice and does not replace an assessment of your specific product.