In short
The real cost of an EU authorisation is far more than minimum capital. It includes local substance and hiring, systems and controls, evidence preparation, professional support and the ongoing cost of operating as a supervised institution. Budgeting only for the initial capital figure consistently understates the total, and the initial capital figure itself is often not the binding constraint.13
What the law requires
Capital is the visible part, and often not the binding one
Initial capital is a real requirement: EUR 20 000, EUR 50 000 or EUR 125 000 for a payment institution depending on the services, and at least EUR 350 000 for an electronic money institution.35
It is a floor rather than a budget. Several frameworks then require own funds measured against a proportion of fixed overheads, which means the requirement rises with the cost base rather than staying at the headline number.12
What the law requires
The costs that do not appear in the capital line
RenIQ practitioner observation
Budgeting properly
Model both the one-off authorisation cost and the recurring cost of being a supervised institution, and re-run the model once the perimeter is confirmed, because the perimeter decides which requirement applies.
Related regime guide: Payments & E-money
This is a supporting note behind the decision guide Choosing a Member State, without ranking regulators.
Primary sources for this page
6 citations, each to the article or section the statement rests on. The numbers beside a statement point to the citation behind it. Always confirm against the current official text.
- 1Article 67 and Annex IV, prudential requirements and permanent minimum capital requirements by class of crypto-asset servicesRegulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on markets in crypto-assetsEuropean Parliament and Council of the European Union
- 2Article 11, prudential safeguards and the forms they may takeRegulation (EU) 2020/1503 of the European Parliament and of the Council of 7 October 2020 on European crowdfunding service providers for businessEuropean Parliament and Council of the European Union
- 3Article 7, initial capital, points (a), (b) and (c)Directive (EU) 2015/2366 of the European Parliament and of the Council of 25 November 2015 on payment services in the internal marketEuropean Parliament and Council of the European Union
- 4Article 10, safeguarding requirements for funds received from payment service usersDirective (EU) 2015/2366 of the European Parliament and of the Council of 25 November 2015 on payment services in the internal marketEuropean Parliament and Council of the European Union
- 5Article 4, initial capital of electronic money institutionsDirective 2009/110/EC of the European Parliament and of the Council of 16 September 2009 on the taking up, pursuit and prudential supervision of the business of electronic money institutionsEuropean Parliament and Council of the European Union
- 6Article 2(2), definition of electronic money, and Article 7, safeguarding requirementsDirective 2009/110/EC of the European Parliament and of the Council of 16 September 2009 on the taking up, pursuit and prudential supervision of the business of electronic money institutionsEuropean Parliament and Council of the European Union
Last updated 2026-08-21. 1 min read, calculated from 218 words.