Direct answer
If your business holds customer funds, executes payment transactions or issues stored value, you likely need a Payment Institution (PI) or Electronic Money Institution (EMI) authorisation under PSD2, and soon PSD3 and the Payment Services Regulation. An EMI can issue e-money and wallets; a PI cannot. Both can passport across the EEA once authorised in one Member State.
Who this applies to
- Fintechs offering wallets, cards, IBANs or stored value
- Payment processors and payment facilitators
- Marketplaces holding or routing customer funds
- Non-EU payment companies expanding into the EEA
Regulated activities
- Issuing electronic money and prepaid wallets (EMI)
- Executing payment transactions and money remittance (PI)
- Account information and payment initiation services (PSD2 AIS/PIS)
- Issuing and acquiring payment instruments
Routes to market
Own EMI or PI authorisation
Full control and EEA passporting, higher capital, substance and evidence expectations.
Authorised partner or agent
Operate under an existing licensed institution while you build scale and substance.
Acquisition
Acquire an already authorised PI/EMI to compress time-to-market, subject to change-of-control approval.
Capital and substance
- Initial capital: PI from €20k to €125k depending on services; EMI €350k minimum.
- Own funds and safeguarding of customer funds are supervised on an ongoing basis.
- Local management substance, effective direction from within the EU and outsourcing governance.
Authorisation stages
- 1
Perimeter and model
Confirm whether PI or EMI applies and which services are in scope.
- 2
Pre-application
Draft programme of operations, capital, safeguarding and governance evidence.
- 3
Submission and Q&A
File with the national competent authority and manage supervisory questions.
- 4
Authorisation and launch
Complete conditions, safeguarding accounts and operational readiness.
Where applications commonly fail
- Underestimating safeguarding and reconciliation requirements
- Insufficient EU management substance and local presence
- Weak AML/CTF business-wide risk assessment
- Choosing EMI vs PI incorrectly for the actual product
Frequently asked questions
An EMI can issue electronic money and hold stored value in wallets; a PI can execute payments but cannot issue e-money. Product design usually determines which you need.
Official regulatory sources
Verified external references. Always confirm against the current official text.
RenIQ provides regulatory strategy and programme delivery. It is not a law firm and this content is illustrative guidance, not legal advice. Regime details are summaries that may change, so always verify against current rules and official sources, and take formal advice before acting.