Nikolai Timofejev
15 years in FinTech and payments. Maps your business model to the right licence scope and leads the file all the way to the CSSF decision, including banking and payment rails.
Get an EMI license in Luxembourg.
Where the giants keep their EU payments home: the CSSF authorises e-money institutions under the Law of 10 November 2009, with pre-application engagement, EBA-register publication, and the institutional depth that made Luxembourg the seat of global platforms' European payment arms.
27 yrs
on the international marketon the market
60+
in-house specialistsspecialists
400+
Licenses obtainedlicenses obtained
Updated
Luxembourg in brief
The institutional home of EU platform payments.
Luxembourg authorises payment and e-money institutions through the CSSF under the Law of 10 November 2009 on payment services, and the CSSF's own procedure says what kind of desk this is: applicants typically begin with a meeting to present the business model, flows and partner architecture before the formal file goes in through the regulator's managed file transfer system; authorisation ends with publication in both the national register and the EBA's central register. No one established in Luxembourg may provide payment services or issue e-money without the CSSF's written authorisation - the framework is complete, enforced and institutionally mature. Initial capital is the harmonised €350,000 for the EMI, with payment-institution tiers below.
The reason to pay Luxembourg's prices is what surrounds the licence. This is where global e-commerce and payment platforms seat their European arms - the professional infrastructure of the EU's largest fund centre (depositary banks, Big Four practices, specialised counsel) applies itself to payments daily, the sovereign is AAA, and the 2025 tax reform trimmed the aggregate corporate charge to 23.87% in Luxembourg City (16% IRC plus solidarity and municipal business tax). The CSSF is demanding and the costs are real; what you get is the single most institutional address in EU payments. Realistic end-to-end: 12-18 months; we run the file from our Luxembourg office.
CSSF authorisation under the Law of 10 November 2009: pre-application meeting, MFT filing, €350,000 capital, national + EBA register publication.
The address: where global platforms seat EU payments - fund-centre infrastructure, AAA sovereign, 23.87% aggregate tax after the 2025 reform.
The two routes
Full EMI - or the payment-institution tier.
One supervisor, two entries: the e-money institution at €350,000, or payment-institution licences below. Both beginning with the CSSF's pre-application engagement. We fix the scope first, then build once.
Full EMI at €350,000 - or PI/AISP routes, in the platform-payments capital.
01 - E-MONEY INSTITUTION
EMI authorisation
The flagship CSSF authorisation: e-money issuance plus the payment-services list, €350,000 initial capital, safeguarding, EU/EEA passporting, and publication in the national and EBA registers.
The flagship CSSF authorisation: e-money issuance plus the payment-services list, €350,000 initial capital, safeguarding, EU/EEA passporting, and publication in the national and EBA registers.
- ✓E-money issuance and distribution
- ✓Full PSD2 payment-services list
- ✓€350,000 initial capital · own funds ongoing
- ✓Safeguarding of client funds
- ✓EU/EEA passport on notification
- ✓National + EBA register publication
02 - PAYMENT INSTITUTION · AISP ROUTES
The platform-payments capitalPI and AISP routes
Payment-institution licences run by service tier, with AISP registration alongside. Inside the jurisdiction where platform, marketplace and e-commerce payment structures are daily practice.
PI licences by tier; AISP registration; marketplace and platform flows as daily practice.
- ✓PI licences by service tier
- ✓Marketplace and platform flows
- ✓Acquiring and transfers
- ✓AISP registration alongside
- ✓Upgrade path to the EMI
- ✓Same CSSF supervision
Costs and timelines are confirmed for your case before any work begins. The CSSF process starts with a pre-application meeting; capital, safeguarding and substance costs are itemised in your quote.
Why Luxembourg
The most institutional address in EU payments.
The framework is EMD2/PSD2 under the CSSF. Inside the financial centre that already runs Europe's platform payments.
✓
Where the giants sit
Global e-commerce and payment platforms run their EU operations from Luxembourg entities. Banking partners, auditors and counsel here handle platform-payment structures as routine, not novelty.EU platform payments live here.
✓
A desk that engages first
The CSSF's published procedure begins with a meeting on your model, flows and partners before the file is submitted. Expectations are set face to face, then met on paper.The meeting before the file.
✓
Fund-centre infrastructure
The EU's largest investment-fund centre supplies depositary-grade banking, Big Four depth and specialised counsel. Operational infrastructure most jurisdictions simply lack.Depositary-grade everything.
✓
AAA sovereign, EBA visibility
A AAA state stands behind the register entry, and authorisation publishes into the EBA's central register. The address reads institutional everywhere in Europe.The institutional address.
✓
23.87% aggregate - trimmed in 2025
The 2025 reform cut the IRC to 16%, bringing Luxembourg City's aggregate corporate charge to 23.87%. Mid-table in the EU, attached to top-table infrastructure.Trimmed by the 2025 reform.
✓
PSD3-ready files
With PSD3/PSR close to adoption, e-money folds into the unified payment-institution regime. We structure Luxembourg files to convert rather than be rebuilt.Built to convert, not rebuild.
How it compares
How Luxembourg differs from other routes.
Luxembourg trades cost and queue for institutional depth. The comparison is below.
Luxembourg vs other jurisdictions
| Feature |  Luxembourg | Other jurisdictions |
|---|---|---|
| Regulatory regime | Law of 10 Nov 2009 - CSSF | Same directives, other desks |
| Process | Pre-application meeting first | Paper-first |
| Infrastructure | Fund-centre grade | Varies widely |
| Timeline | 12-18 months realistic | 6-12 at specialised desks |
Regulatory regime
LuxembourgLaw of 10 Nov 2009 - CSSF
Other jurisdictionsSame directives, other desks
Process
LuxembourgPre-application meeting first
Other jurisdictionsPaper-first
Infrastructure
LuxembourgFund-centre grade
Other jurisdictionsVaries widely
Timeline
Luxembourg12-18 months realistic
Other jurisdictions6-12 at specialised desks
Country by country
| Country | License type | Taxation | Requirements |
|---|---|---|---|
| Luxembourg | EMI (CSSF) | 23.87% aggregate | Pre-application, deep file |
 Lithuania | EMI (Bank of Lithuania) | 17% CIT (2026) | CENTROlink, specialised desk |
 Belgium | EMI (NBB) | 25% · SME 20% | Central-bank review, on-ramp |
 Ireland | EMI (CBI) | 12.5% CIT trading | Engagement-led, 12+ months |
LuxembourgLicense typeEMI (CSSF)
Taxation23.87% aggregate
RequirementsPre-application, deep file
LithuaniaLicense typeEMI (Bank of Lithuania)
Taxation17% CIT (2026)
RequirementsCENTROlink, specialised desk
BelgiumLicense typeEMI (NBB)
Taxation25% · SME 20%
RequirementsCentral-bank review, on-ramp
IrelandLicense typeEMI (CBI)
Taxation12.5% CIT trading
RequirementsEngagement-led, 12+ months
Before you apply
Requirements for the CSSF authorisation.Requirements for the authorisation.
The CSSF sets expectations in the pre-application meeting and holds the file to them. The craft is delivering exactly what was framed. The checklist below is what a passing application contains.
01
Luxembourg entity. An S.A. or S.à r.l. with its head office and effective management in Luxembourg.
02
Initial capital - €350,000 for the EMI, evidenced and paid in; PI tiers below.
03
Fit and proper management and holders. Competence, clean records and ownership transparent to UBOs.
04
Business-model presentation. Activities, fund and data-flow diagrams, partner architecture. Framed at the pre-application stage.
05
Programme of operations. Services, volumes and three-year financials the CSSF can interrogate.
06
Safeguarding. Segregated client-fund accounts or insurance, with documented reconciliation.
07
AML/CFT framework. KYC, monitoring and CRF reporting with a resident compliance officer.
08
IT and security documentation. Architecture, DORA-grade resilience and incident procedures.
09
Internal governance. Control functions, outsourcing register and conflicts procedures.
10
MFT filing discipline. The complete file submitted through the CSSF's managed file transfer, to the forms.
01
Luxembourg S.A./S.à r.l., managed locally.
02
€350,000 capital (EMI).
03
Fit & proper holders to UBOs.
04
Model presentation with flow diagrams.
05
Interrogable programme of operations.
06
Safeguarding with reconciliation.
07
AML with resident officer (CRF).
08
DORA-grade IT documentation.
09
Governance and outsourcing register.
10
Complete MFT filing, to the forms.
Reflects the Law of 10 November 2009 and the CSSF's published authorisation procedure as of 2026.Law of 10 Nov 2009 + CSSF procedure, as of 2026.
How it works
From first call to the EBA register.
01
Route and strategy
EMI or PI tier, and the model presentation the CSSF will meet. Fixed in writing before engagement.Scope + the model presentation.
02
Pre-application meeting
The business model, flows and partner architecture presented to the CSSF. Expectations set face to face.Expectations set face to face.
03
Company, people and file
S.à r.l. formation, capital, resident officers, and the complete file through MFT, delivering what was framed.Formation, capital, MFT filing.
04
CSSF review
Institutional scrutiny, question rounds answered - 12-18 months realistic end to end.Institutional depth; 12-18 realistic.
05
Authorisation and launch
Written authorisation, national and EBA register publication, passport notifications. Live from the platform-payments capital.EBA-published, passported.
Quick facts
RegulatorCSSF
EMI capital€350,000
ProcessPre-application meeting first
FilingCSSF MFT system
PublicationNational + EBA registers
Realistic timeline12-18 months
Aggregate tax23.87% · Lux City
PassportEU/EEA on notification
The CSSF frames expectations in the first meeting and holds the file to them. Delivering exactly that is the entire game, and our job.
On the ground in Luxembourg
Run from our Luxembourg office.
Prifinance - Luxembourg
Luxembourg
Luxembourg
01
Luxembourg company formation
S.à r.l. or S.A. incorporation, capital placement and the corporate layer the CSSF expects. Structured for the licence from day one.S.à r.l. + capital, structured for the file.
02
The pre-application, prepared
The model presentation, flow diagrams and partner architecture built before the CSSF meeting, because the file that follows must deliver exactly what was framed.Frame it right. Then deliver it.
03
The CSSF file
Programme of operations, safeguarding design, AML pack and IT documentation to the forms. Submitted through MFT complete, and defended through the rounds.Through MFT, complete, defended.
04
Substance and staffing
Resident directors, compliance officer and MLRO from Luxembourg's deep financial talent pool. Real substance at fund-centre standard.Fund-centre-grade, real ops.
We also have offices in
Tallinn
Estonia
Roseni 13
Vilnius
Lithuania
Gedimino pr. 2
Prague
Czech Republic
Vlkova 532/8, Žižkov
Dubai
UAE
33 Level, Al Saqr Business Tower
Madeira
Portugal
Rua da Alegria 31, 1F
Budapest
Hungary
Korányi Sándor u. 4
Istanbul
Turkey
Perpa Ticaret Merkezi, A Blok
Good to know
Taxation of payment companies in Luxembourg.
The 2025 reform trimmed the aggregate: 16% IRC plus solidarity and municipal layers lands Luxembourg City at 23.87%. Mid-table rates on top-table infrastructure.
Aggregate 23.87%
IRC at 16% (cut from 17% in 2025), a 1.12% employment-fund surcharge and 6.75% municipal business tax in Luxembourg City. The all-in corporate charge on an EMI's income.16% IRC + layers, Lux City.
VAT 17% - and exempt services
Payment and e-money services are VAT-exempt; Luxembourg's 17% standard rate. The EU's lowest. Touches only ordinary supplies.EU's lowest rate; services exempt.
Dividends 15%
15% withholding on outbound dividends, reduced by treaties and eliminated intra-EU under the Parent-Subsidiary Directive. With Luxembourg's participation exemption above.Treaty and EU-directive relief.
The holding tradition
Participation exemption, a vast double-tax network and decades of holding-structure practice. The layer above the EMI models better here than anywhere in the EU.Participation exemption above.
Fund-centre synergies
Payment flows that touch funds, custody or securitisation find every counterpart in-country. Structuring conversations happen across the street, not across borders.Every counterpart in-country.
Treaty network 85+
A deep, actively maintained treaty network. Group structures above the Luxembourg entity model cleanly.Deep, maintained network.
Tax summary
IRC16% · since 2025
Aggregate (Lux City)23.87%
VAT on payment servicesExempt
Standard VAT17% - EU's lowest
Dividend withholding15% · treaty/EU relief
Participation exemptionYes - holding layer
Tax treaties85+
*Figures as of 2026 per the Administration des contributions directes. Holding and founder-level outcomes are modelled per structure.
Turnkey professional support
Experienced lawyers and international consultants.
We provide end-to-end support, from company registration and the application file to regulatory interaction and compliance oversight - with an individualized approach to each client.
Oleksii Kindratenko
Builds the application itself: Luxembourg S.à r.l., AML/KYC policy pack, capital structure and tax registrations. His document sets are the reason reviews finish in months, not years.
Eugeniu Bevziuc
First point of contact for international founders. Runs the whole setup remotely, across time zones and languages - from the first call to a live, authorised institution.
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Luxembourg · CSSF
Launch your payment project in Luxembourg with expert support.
Full-service assistance - from company registration to the CSSF authorisation, register publication and ongoing compliance.
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Is Luxembourg the right fit for your project?
Our legal team will analyze your case at no cost and provide a written legal opinion: which jurisdiction, licence scope, or route fits your business.
Written assessment within 2-5 business days
Request a free conclusion →FAQ
The Luxembourg EMI licence: the practical answers.
What licence does an e-money business need in Luxembourg?+
An e-money institution authorisation from the CSSF under the Law of 10 November 2009 - €350,000 initial capital, safeguarding and EU/EEA passporting. Payment-institution licences and AISP registration sit alongside. No one established in Luxembourg may provide these services without the CSSF's written authorisation.
How does the CSSF process actually run?+
It starts before the application: a pre-application meeting where you present the business model, fund and data flows and partner architecture. The formal file then goes through the CSSF's managed file transfer system, and authorisation ends with publication in the national and EBA registers. We prepare the meeting as carefully as the file.
How long does licensing take?+
Realistically 12-18 months end to end - the CSSF reviews at institutional depth. The speed lever is delivering a file that matches exactly what was framed in the pre-application engagement; that is our job.
What does it cost?+
CSSF fees and Luxembourg operating costs are real - this is a premium jurisdiction. The investment is capital (€350,000), fund-centre-grade substance and the file, all itemised in your quote before we start.
Why do global platforms seat EU payments in Luxembourg?+
Institutional depth: AAA sovereign, the EU's largest fund centre, depositary-grade banking, Big Four bench strength and a supervisor experienced with complex cross-border flows. When the structure matters more than the cost line, Luxembourg wins.
What substance is expected?+
A Luxembourg company effectively managed locally, resident directors and compliance officer, AML reporting to the CRF, real safeguarding arrangements and DORA-grade systems documentation - at the standard the fund centre takes for granted.
How are payment companies taxed?+
The aggregate corporate charge in Luxembourg City is 23.87% from 2025 (16% IRC plus solidarity and municipal business tax), with VAT-exempt payment services, 15% dividend withholding subject to relief, and the participation exemption for the holding layer.
Does the licence passport across the EU?+
Yes - the authorisation notifies into every EU/EEA state, and publication in the EBA register gives the entity Europe-wide visibility from day one.
What changes under PSD3?+
PSD3 and the PSR - provisionally agreed in November 2025 and close to formal adoption - fold e-money institutions into a unified payment-institution regime. Files we build now are structured to convert.
Why Luxembourg rather than Lithuania or Belgium?+
Lithuania wins on speed and CENTROlink; Belgium on the infrastructure-operators' address. Luxembourg wins where the corporate structure above the licence matters - platform groups, fund-adjacent flows, holding layers. If your counsel and your CFO both care, you already know the answer.
What licence is needed?+
CSSF EMI - €350k; PI/AISP alongside.
The process?+
Meeting first, then MFT filing, then registers.
How long?+
12-18 months realistic.
Cost?+
Premium jurisdiction; itemised up front.
Why here?+
Where platforms seat EU payments.
Substance?+
Fund-centre standard, resident officers.
Taxes?+
23.87% aggregate; VAT-exempt services.
Passport?+
EU/EEA + EBA-register visibility.
PSD3?+
Agreed Nov 2025 - files convert.
Vs Lithuania?+
Their speed; your structure depth.
Client notes
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Founders who wanted it done right.
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Prifinance is an independent law and advisory firm. We are not a regulator and are not affiliated with, endorsed by, or acting on behalf of the Commission de Surveillance du Secteur Financier (CSSF) or any other public authority. Authorisations are granted by, and obtained directly from, the competent authorities.