We run the whole file - the service list and the licence tier it sets, the local company, the capital, the people the supervisor vets by name, and the safeguarding, AML and IT architecture it audits, and we tell you before you pay which authorisation reaches the customers you are actually going after, and which one stops at the border.
Updated
PSD3 and the PSR were provisionally agreed on 27 November 2025 and are close to formal adoption. Between them they end the parallel-licence era: e-money institutions fold into a unified payment-institution regime, and the conduct rules. Fraud, authentication, refunds. Move into a regulation that applies directly rather than through twenty-seven transpositions. National law is still EMD2 and PSD2 today, which is exactly why the file you build now decides whether you convert or rebuild.
EMIs are folded into the payment-institution regime, not abolished, and existing institutions carry into it rather than starting again. The exposure is not the licence. It is the gap between the permission set you were granted and the business you have since become. That gap is far cheaper to close now, on your own timetable, than during a conversion.
A payment licence is scoped by service, not by ambition. The regime lists the payment services, attaches a capital tier to each, and puts e-money issuance in its own class above them, which is why the first real question is never 'which country', but 'which of these are you really going to do'. Fixing that fixes the capital, the safeguarding design and the timeline in one move.
Scope is jurisdiction-specific and the boundaries are real. Switzerland issues no EMI licence at all: the FINMA fintech licence takes public deposits up to CHF 100 million on the express condition that they are neither invested nor interest-bearing. Hong Kong's MSO licence covers remittance and money-changing but no stored value. That is the SVF boundary. And the United States has no federal payments licence to obtain, only FinCEN registration plus a state-by-state programme.
| Type of activity | Regulatory requirements |
|---|---|
| Issuing e-money and wallets | An EMI authorisation with €350,000 initial capital across the EEA - HK$25 million for a Hong Kong SVF, ₱100-200 million for a BSP e-money issuer - plus ongoing own funds and safeguarding of the whole float |
| Money remittance and transfers | The €20,000 payment-institution tier in the EEA; AUSTRAC registration in Australia; an MSO licence from Customs & Excise in Hong Kong; FinCEN MSB registration plus state money transmitter licences in the US |
| Acquiring and executing payment transactions | The €125,000 tier, with the merchant onboarding, chargeback and settlement architecture the supervisor examines alongside the capital |
| Payment initiation and account information | €50,000 for initiation; account information is a registration with no capital floor in most regimes - the same supervisor, the same register, a lighter file |
| Holding customer funds | Safeguarding evidenced before launch: segregated accounts or insurance with documented reconciliation in the EEA, a trust account holding the full float in Malaysia, at least 50% in trust plus HQLA-grade assets in the Philippines |
| Deposit-taking models | Outside the payments regimes entirely - Switzerland's Art. 1b fintech licence to CHF 100 million, or ADGM's FSRA digital banking licence where the model is genuinely a bank |
Names differ by jurisdiction and so does the paperwork behind them: an E-Geld-Institut under the ZAG, an istituto di moneta elettronica in the Albo IMEL, a KIPE under Poland's Payment Services Act, a stored value facility under Cap. 584, a Major Payment Institution under the Payment Services Act 2019. Underneath, every supervisor asks the same question. Whose money are you holding, and what stands behind it. We map your service list onto the right scope before anything is filed.
There is no best payment jurisdiction. Only the right one for your service list, your customers and the rails you need. Across the 110 jurisdictions we work in, four variables decide it: how far the authorisation reaches, what it connects you to, what the whole stack costs, and how long the desk realistically takes.
An EEA authorisation notifies into every EU/EEA state from one desk, and Iceland and Norway passport into the Union through the EEA agreement. The UK licence stopped passporting at Brexit and is now a market play. A very deep one. Switzerland, Singapore, Hong Kong, the UAE and the US are markets you license into, not from.
A licence that cannot reach the payment system is an expensive certificate. Lithuania is the outlier that matters: CENTROlink admits licensed EMIs and PIs directly, so SEPA transfers, instant payments and IBAN issuance do not depend on a commercial bank agreeing to sponsor you. Almost everywhere else, sponsorship is the real bottleneck, and it is priced on the regime behind your licence.
Capital is the least differentiated number in Europe: €350,000 for an EMI, everywhere. What differs is everything around it. Tax from 0% on retained profit in Estonia and Latvia, 9% in Hungary and 10% in Bulgaria up to ~30-33% effective in Germany; application fees from free in Denmark to €5,000 in Latvia plus supervision charges; and the file itself, drafted in German, Polish, Spanish, Italian, Hungarian, Bulgarian or Romanian rather than English.
The statutory clock is three months from a complete file almost everywhere in the EEA, and almost none of the variance sits with the regulator. Realistic timelines run 6-12 months in Lithuania and the UK, 9-15 in Malta, Cyprus, Poland and Hungary, and 12-18 in Germany, Ireland, Luxembourg and Spain, where the difference is depth of engagement rather than queue length.
| Jurisdiction | Licence & regulator | Initial capital | Tax | What it buys you |
|---|---|---|---|---|
| LithuaniaMore details → | EMI & PI · Bank of Lithuania | €350,000 · none restricted | 17% · small 7% | Direct SEPA through CENTROlink, and the EU's deepest e-money desk |
| IrelandMore details → | EMI · Central Bank of Ireland | €350,000 | 12.5% trading | The headquarters stamp - engagement-led, and slow on purpose |
| GermanyMore details → | E-Geld-Institut · BaFin with Bundesbank | €350,000 · PI from €20,000 | ~30-33% effective | Counterparty weight inside Europe's largest payments market |
| MaltaMore details → | EMI · MFSA (Cap. 376) | €350,000 | 35% nominal · ~5% after refunds | An English-language EU file and the acquiring cluster around it |
| EstoniaMore details → | EMI & PI · Finantsinspektsioon | €350,000 | 0% retained · 22% distributed | EU licensing administered by the digital state |
| United KingdomMore details → | Authorised EMI · FCA | €350,000 · small EMI under €5M | 25% · 19% small | The deepest market and talent pool in Europe - and no EU passport |
| Hong KongMore details → | SVF · HKMA (PSSVFO, Cap. 584) | HK$25 million | 8.25% first HK$2M · 16.5% | The Greater Bay Area wallet licence, with the MSO route beneath it |
| USAMore details → | FinCEN MSB + state MTLs | Per state - capital, bonds, net worth | 21% federal + 0-9% state | The largest market on earth, entered one state at a time |
| Gulf · UAE, Bahrain, Saudi Arabia, Qatar, Oman, Kuwait | PSP / PI & EMI tiers · six central banks | AED 100k-3M · BD 25k-250k · SAR 1M-10M · OMR 100k-500k · KWD 50k-2M | 0-20% · foreign-share and DMTT rules | Corridor capitals with entry sized to volume, and printed clocks in Oman and Saudi Arabia |
| Levant and Türkiye · Israel, Jordan, Türkiye | PI & EMI · ISA, CBJ, CBRT | TRY 20M-105M · JOD 1M-3M · per ISA directives | 23-30% | Three domestic markets with statutes written for fintech and instant rails already live |
| CIS, Caucasus and Central Asia · Kazakhstan, Uzbekistan, Armenia, Azerbaijan, Kyrgyzstan, Mongolia, Ukraine, Moldova | Central-bank licences · AFSA in the AIFC | AMD 100M · UAH 1M-10M · MDL 350k-2.2M · KGS 30M-150M · MNT 2.5bn | 10-20% · AIFC 0% | Short statutory clocks, low capital and, in Astana, an English-law door |
| Europe · fifteen EU and EEA states plus Andorra and the Crown Dependencies | PI & EMI under PSD2 · Class 8 · money service business | EUR 20,000-350,000 · no capital figure in Jersey and Guernsey | 0-25.8% | The same PSD2 capital across the Union; what differs is fees, clocks, language and the passport |
| Asia-Pacific · Japan, South Korea, Taiwan, Thailand, Indonesia, Vietnam, Cambodia, Singapore, Hong Kong, Malaysia, Philippines, Australia | Funds transfer · e-money · PJP · SVF · MSO | JPY none printed · KRW 300M-5bn · NT$100M-500M · THB 10M-100M · IDR 500M-15bn · VND 50-300bn | 17-30% | Twelve destination markets, each with its own rail and its own idea of what a payment company is |
| South Asia · India, Pakistan | PPI and payment aggregator · EMI | INR 5-25 crore · PKR 200M with a ladder to 1.25bn | 25-30% | Two of the fastest-growing retail rails on earth, UPI and Raast, behind two very different regulators |
| Africa · Egypt, Morocco, Tunisia, Kenya, Ghana, Rwanda, Mauritius, Nigeria | PSP, e-money issuer, établissement de paiement | EGP 10-500M · MAD 6-10M · TND 5M · KES 1-50M · GHS 0.8-20M · FRW 30-300M · MUR 1-50M | 15-30% | Mobile money was invented here, and the licences that carry it are cheaper than anywhere else |
| Latin America · Mexico, Brazil, Chile, Colombia, Peru, Argentina, Uruguay, Paraguay, Bolivia, El Salvador | IFPE · IP · prepaid issuer · SEDPE · EEDE · IEDE · EMPE · SPDE | 500k UDIs · R$ 2M · 25,000 UF · COP 5.8bn · S/ 2.9M · USD 200k · none in Argentina or Uruguay | 10-35% | Ten statutes written for fintech, client money ring-fenced by law, and our Spanish- and Portuguese-speaking desk |
| Offshore and North America · Bahamas, Cayman Islands, BVI, Bermuda, USA, Canada | Payment institution · money services business · state MTLs · RPAA registration | B$50k-100k · $30,000 in Cayman · none in Canada · per state in the USA | 0-21% plus minimum-tax regimes | Four zero-tax islands with real supervision, and the two North American regimes beside them |
Prifinance selects the jurisdiction against your service list, your customer geography, your payment rails and your budget, and says plainly when the route you arrived with will not reach the market you are aiming at. From there we run the company, the capital, the application and the launch as one file.
The full list by region. The cards above cover the routes people ask about most; everything else sits here: EMI and PI under PSD2, banking and settlement regimes outside the EU, MSB and MSO.
Supervised regimes check four things: the company, the people, the money and the machine. The requirements below recur across the Bank of Lithuania, BaFin, the Central Bank of Ireland, the MFSA, the Central Bank of Cyprus, Finantsinspektsioon, the KNF, the FCA, MAS and the HKMA. The thresholds move, the questions do not.
Which payment services you will actually run decides the capital tier, the safeguarding design and the country. EMI or payment institution, full licence or a small-scale on-ramp. Fixed in writing before any drafting begins.
The local entity is incorporated, capital paid and evidenced, and directors, the compliance officer and control functions filled with people the supervisor will actually approve. Resident where residence is required.
Programme of operations, safeguarding design, own-funds methodology, AML/CFT pack, IT and resilience documentation and the governance framework. Complete on submission, in the language the desk works in.
The statutory clock starts at completeness, not at filing. Question rounds, fit-and-proper checks and, at engagement-led desks like the CBI and the CSSF, a dialogue that begins before the file does.
Authorisation issued, passport notifications sent, payment-system and banking onboarding completed. CENTROlink admission where it applies, and the reporting and supervision calendar running from day one.
Payments attracts intermediaries who sell a jurisdiction before they have read your service list. We are a legal and advisory firm: we scope what you are actually authorised to do, build the file the supervisor audits, and stay on it after the licence is issued.
60+ specialists work on applications directly. Lawyers, compliance and audit people, not an outsourcing chain of resellers.
Before you pay anyone, you get a written view of which route reaches your customers, what it will cost in full, and where it stops. Including when the answer is that no licence exists for what you described.
The quote you approve is the price you pay. State, supervisory and audit fees are stated separately and upfront, and capital is never quietly counted as a cost of service.
Programme of operations, safeguarding, own funds, AML and DORA-grade IT documentation drafted to the desk's own annexes, and structured for the PSD3/PSR regime rather than for retrofitting later.
Passport notifications, payment-system and banking onboarding, reporting and supervision calendars, variations of permission, and the second licence when one market stops being enough.
15 years in FinTech and payments. Maps your business model to the right licence scope and leads the file to the supervisor's decision, including banking and payment rails.
Builds the application itself: the local company, AML/KYC policy pack, safeguarding design, capital structure and tax registrations. His document sets are the reason reviews finish in months, not years.
First point of contact for international founders. Runs the whole setup remotely, across time zones and languages - from the first call to a live, licensed institution.
Payments carries three separate tax questions, and founders routinely collapse them into one: what the company pays on profit, what the VAT exemption quietly costs you, and what actually lands with the owner. A jurisdiction can be excellent on one and expensive on the others.
0% while profit stays in the company in Estonia, Latvia and Georgia; 9% in Hungary, the EU's lowest; 10% flat in Bulgaria and North Macedonia; 12.5% on trading profit in Ireland; 15% in Cyprus since 1 January 2026 and in Serbia; 16% in Romania; 17% in Lithuania and Singapore; 21% in Czechia; 22% in Denmark and Greece; 23.87% in Luxembourg City; 25% in Spain, Belgium, Norway and the UK; around 28% in Italy; ~30-33% effective in Germany; and 35% nominal in Malta, about 5% after the refund mechanism.
Payment services are VAT-exempt right across the EU, which means the input VAT on your own costs is largely irrecoverable, and the standard rate becomes a cost line rather than a pass-through. That rate runs 27% in Hungary, 25% in Denmark and Norway, 24% in Estonia and Greece, 23% in Ireland, Poland and Slovakia, 22% in Italy, 21% in Latvia, Lithuania, Belgium, Czechia, Spain and Romania, 19% in Germany and Cyprus, 18% in Malta and 17% in Luxembourg. Hong Kong has no VAT at all.
No dividend withholding in Malta, the UK, Hong Kong or Singapore, and none between companies in Hungary. 5% in Greece, Bulgaria and Georgia; 10% in North Macedonia; 15% for Hungarian individuals and in Lithuania, Luxembourg, Czechia and Serbia; 19% in Spain; 26% in Italy; 26.375% in Germany; 27% in Denmark; 27.5% in Austria; 30% in Belgium; and 35% in Switzerland against a treaty refund. Cyprus pairs the corporate rate with 17 years of non-dom status.
The application is free in Denmark and €1,463 in Lithuania (€1,235 restricted); Latvia charges €5,000 - €450 for innovative services. Then €7,000 supervision plus up to 1.4%; Norway takes NOK 30,000 before the review even starts; Nigeria's IMTO application is ₦10 million. Germany adds an annual supervisory levy on top of the statutory fee schedule, Hungary a local business tax of up to 2%, and Norway a 5% finansskatt on payroll where the sector test bites.
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It depends on whether you hold a balance for the customer. If money sits in a wallet or on a card that the customer can redeem at par, that is e-money issuance and it needs an EMI authorisation - €350,000 initial capital across the EEA. If you only move money between accounts, a payment institution licence covers it at €20,000 for remittance, €50,000 for payment initiation or €125,000 for acquiring and execution. Most founders describe an EMI and need a PI, or the reverse.
PSD3 and the PSR - provisionally agreed on 27 November 2025 and close to formal adoption - fold e-money institutions into a unified payment-institution regime and strengthen the fraud, authentication and refund rules, with the conduct half in a directly applicable regulation. Applications today are still assessed under EMD2 and PSD2. Files we build now are structured to convert rather than be rebuilt.
No. EMIs are folded into the payment-institution regime, not abolished, and a licence granted today does not lapse because the directive behind it is replaced. What is worth doing now is a review: whether your granted permission set still matches what you actually do, whether the safeguarding and own-funds design holds at current volumes, and which passports were genuinely notified. Closing those gaps on your own timetable is far cheaper than closing them during a conversion.
Lithuania and the UK at 6-12 months realistically, with Estonia, Latvia, Denmark, Iceland and Czechia at 8-14. Malta, Cyprus, Poland and Hungary run 9-15; Germany, Ireland, Luxembourg and Spain run 12-18. The statutory clock is three months from a complete file almost everywhere - the difference between jurisdictions is how demanding 'complete' is, and the difference between applicants is whether they arrive that way.
An EEA authorisation passports to every EU/EEA state on notification - including from Iceland and Norway, which are outside the EU but inside the EEA agreement. The UK licence does not: since Brexit an FCA authorisation is a UK market licence, and serving EU customers from it requires an EU authorisation as well. Groups serving both routinely hold two.
Safeguarding is the requirement that customer money never sits in the same pool as yours - held in segregated accounts or covered by insurance, with reconciliation that is performed and evidenced. It is the single most examined part of a payments application because it is what protects customers if you fail. Malaysia requires the full float in a trust account, the Philippines at least half in trust plus HQLA-grade assets, and the UK is rebuilding its regime under PS25/12 from 7 May 2026.
€350,000 for an EMI across the EEA and €20,000-€125,000 for a payment institution by service; HK$25 million paid-up for a Hong Kong SVF; CHF 300,000 plus 3% of deposits for the FINMA fintech licence; ₱100 million for a Philippine e-money issuer, rising to ₱200 million above ₱25 billion in annual flows; ₦2 billion for a Nigerian Mobile Money Operator. In the US, capital, bonding and net-worth requirements are set state by state.
Not as a single licence - there is no federal EMI. Non-bank payments run on FinCEN MSB registration plus money transmitter licences in each state where your customers are, filed through NMLS and typically taken in waves of anchor states first: 12-24 months to meaningful coverage. The alternatives are real but constrained - a bank-partnership structure, agent-of-payee exemptions, or acquiring a licensed transmitter. We map which of them your model actually fits.
No, and that is worth knowing before you budget for one. The routes that exist are different: the FINMA fintech licence under Art. 1b of the Banking Act accepts public deposits up to CHF 100 million on the condition that they are neither invested nor interest-bearing, and payment services without deposit-taking run on affiliation with a recognised self-regulatory organisation under the AMLA. Groups that need EU reach pair a Swiss presence with an EEA licence.
A supervised licence makes the conversation possible; it does not finish it. Sponsor banks price the regime behind your seal, your ownership, your customer geography and your AML machinery. The exception that matters is Lithuania: CENTROlink admits licensed EMIs and PIs to SEPA and instant payments directly, without a commercial bank as gatekeeper, which is why we plan the rails alongside the licence rather than after it.
Get a free legal opinion on your project - our legal team will analyse your case at no cost and provide a written opinion: which jurisdiction, licence tier and structure fit your service list, your customers and your payment rails.
