Payment gateway license: when a gateway, processor or acquirer needs one.

In the EU and the UK, a payment gateway that only carries payment data between merchant, acquirer and card scheme is usually a technical service provider outside licensing. Contract with merchants to accept their payments, or hold their money before settlement, and you provide a regulated payment service. Singapore, Canada and Pakistan draw the line wider. Below: the test, market by market.

€125,000
EU and UK initial capital for acquiring
3 months
EU and UK decision on a complete file
11
markets compared below

Updated · Reviewed by the Prifinance team

Country by country

Payment gateway and processing licenses by country

European Union flag
European Union
Payment institution · PSD2
✓Acquiring is a payment service (Annex I, point 5)✓Technical service providers excluded (Article 3(j))✓One authorisation, EEA passport
3 months, complete fileCapital: €125,000More details →
United Kingdom flag
United Kingdom
Authorised payment institution · PSRs 2017
✓Acquiring listed in Schedule 1, Part 1✓Technical service providers excluded✓No EU passport since Brexit
3 months, complete fileCapital: €125,000More details →
United States flag
United States
FinCEN MSB · state money transmission
✓Federal rule exempts qualifying payment processors✓State exemptions worded state by state✓Exclusion: 31 CFR 1010.100(ff)(5)(ii)(B)
State by stateCapital: set by each stateMore details →
Canada flag
Canada
RPAA registration · Bank of Canada
✓Transmitting an EFT instruction is a payment function✓Holding end-user funds is another✓FINTRAC MSB rules may apply alongside
Capital: none under the RPAAMore details →
Brazil flag
Brazil
Instituição de pagamento · Banco Central do Brasil
✓Acquiring (credenciador) is a payment-institution modality✓BCB authorisation before operating since Res. 494/2025✓Acquirers count as credit and intermediation
Capital: by activity (Joint Res. 14/2025)More details →
India flag
India
RBI payment aggregator · 2025 Directions
✓Gateways that never handle funds: out of scope✓Domestic PA: escrow with a scheduled commercial bank✓Online, physical and cross-border PA
Capital: ₹15 crore net worthMore details →
Pakistan flag
Pakistan
PSO / PSP · State Bank of Pakistan
✓Electronic payment gateways are named PSO/PSP services✓SBP rules for PSOs and PSPs, PSD Circular 03 of 2014✓+25% capital for each additional PSO/PSP business
Capital: PKR 200M paid-upMore details →
Singapore flag
Singapore
Merchant acquisition · Payment Services Act 2019
✓Merchant acquisition applies even without holding the money✓Standard PI up to S$3M a month per service✓MPI security of S$100,000 or S$200,000
Capital: S$100,000 or S$250,000More details →
Malaysia flag
Malaysia
Registered merchant acquirer · FSA 2013 · BNM
✓Registration with BNM under FSA 2013, ss. 17(1) and 18✓Payment facilitators act for a registered acquirer✓Gateways assessed against the four acquiring activities
Capital: RM300,000 or RM1M (non-bank, by volume)More details →
Thailand flag
Thailand
Payment Systems Act B.E. 2560 · Bank of Thailand
✓Acquiring and payment facilitating need a licence✓Licence from the Finance Minister on BOT advice✓Payment facilitating: THB 10M capital
Capital: THB 50M for acquiringMore details →
United Arab Emirates flag
United Arab Emirates
Retail payment services · CBUAE
✓Merchant acquiring and aggregation: Categories I-III✓Capital tiered at AED 10M monthly volume✓Payment tokens only in Category I
Capital: AED 500,000-3MMore details →
The licensing test

Who signs the merchant, who holds the money

Regulators do not license the word "gateway". They ask two questions: do you contract with merchants to accept and process their payments, and does the money pass through you? A provider that only carries payment data does neither: in the EU and the UK it is a technical service provider outside licensing, and India's payment aggregator Directions leave it out. Sign the merchant and you are acquiring under PSD2, the UK rules and Singapore's Act - the FCA and the Singapore Act say so even where no money passes through you. Hold the money and you need a licence or registration in every market on this page, unless an exemption such as the US payment processor rule applies.

✓Data onlyPurely technical support - data processing and storage, authentication, IT and network provision, terminals - is excluded in the EU and UK while you never hold the funds. Routing and fraud screening are judged case by case.✓Merchant contractContracting with a merchant to accept and process its payments, with funds transferred to it, is acquiring under PSD2. The FCA counts payment facilitators that contract with payees as likely acquirers.✓Funds in your accountReceiving settlement and paying merchants out brings you inside the payment rules in every market on this page - as acquiring, aggregation or, in the USA, money transmission unless an exemption applies.✓One activity, different namesAcquiring in the EU and UK, payment aggregation in India, merchant acquisition in Singapore, merchant acquiring in Malaysia and the UAE.
Card-scheme registration of a payment facilitator is made through the sponsoring acquirer under the schemes' rules; it does not replace a licence.
Apply the test to my model
PayFacs and aggregators

PayFac license: when a sub-merchant model needs one

A payment facilitator onboards sub-merchants under its own acquiring relationship and usually receives their settlement. The licence for that depends on the market: a payment institution covering acquiring or money remittance in the EU and UK, the RBI payment aggregator authorisation in India, a merchant acquisition licence in Singapore, a Category I-III retail payment services licence in the UAE. In Malaysia a payment facilitator works on behalf of a registered merchant acquirer, which must settle with the facilitator's merchants if the facilitator fails to.

✓EU and UK: acquiring or money remittance permission✓India: ₹15 crore net worth, ₹25 crore by year three✓Singapore: standard or major PI, by monthly volume✓UAE: merchant acquiring and payment aggregation
Banks acquire under their banking licence; in India a bank needs no separate payment aggregator authorisation.
Scope a PayFac licence
Related guides

Other payment licenses

EMI and payment licenses in 109 jurisdictions

Country by country: regulator, capital, timelines and tax for e-money and payment institution licences.

Payment institution license (PSD2)

Annex I services, €20,000-€125,000 capital, small PI and AISP routes, the EU passport and PSD3 status - 11 EU countries and the UK compared.

Model by model

Gateway, processor, acquirer or PayFac: who needs a license

The same business can sit in different rows depending on its contracts and on whether merchant money passes through it.

ModelHolds merchant funds?EU and UKIndiaUSA, federal
Data-only gatewayNoUsually excluded as a technical service providerOutside the PA DirectionsNot money transmission if it never accepts funds
Processor for an acquirerNoUsually excluded as a technical serviceOutside the PA Directions if no funds handlingNot money transmission if it never accepts funds
Merchant acquirerYes, settles merchantsPayment institution, €125,000Bank, or an authorised payment aggregatorPayment processor exemption may apply
PayFac or payment aggregatorYes, receives and pays outPayment institution: acquiring or remittanceRBI PA authorisation, ₹15 croreFederal and state analysis of the flow
Important: The label on your website does not decide the licence; the contracts and the funds flow do. We map both before naming a jurisdiction.
Before you apply

Payment processing license requirements: what supervisors examine

Across the markets above, an acquiring or aggregation licence file is built from the same blocks.

01
Initial capital €125,000 for acquiring in the EU and the UK, ₹15 crore net worth in India, S$100,000 or S$250,000 base capital in Singapore, AED 500,000 to AED 3 million in the UAE, THB 50 million for acquiring in Thailand, PKR 200 million paid-up in Pakistan, RM300,000 or RM1 million of capital funds, depending on monthly transaction value, for a non-bank acquirer in Malaysia.
02
Safeguarding of merchant funds Money received for merchants kept apart from your own: safeguarding in the EU and UK, an escrow account with a scheduled commercial bank in India (separate collection accounts for cross-border PAs).
03
Programme of operations Which services, which flows, which schemes and acquiring partners. PSD2 requires it in every application (Article 5).
04
Governance and people Directors and managers of good repute with relevant experience, a compliance officer and an MLRO with real authority.
05
AML and sanctions Merchant onboarding and monitoring, transaction screening and sanctions checks. PSD2 asks for a description of the AML controls (Article 5).
06
IT, security and outsourcing Payment-data security (PCI DSS if you store, process or transmit card data), incident reporting and control over the processors and gateways you rely on.
Note: Exact figures and documents depend on the services you need; each country page lists its own law and register.
Verify it yourself

Official sources

The laws and regulator pages behind the rules on this page.

Each country page carries its own regulator, law and register. EU references are to PSD2 as in force on 19 October 2026: PSD3 and the Payment Services Regulation are provisionally agreed but not yet adopted.

On the ground

Offices from Hong Kong to Miami.

Hong Kong flag
Hong Kong
Hong Kong
HQ
5/F, Yau Lee Centre, 45 Hoi Yuen Road, Kwun Tong
+852 5808 0297
Czech Republic flag
Prague
Czech Republic
Vlkova 532/8, Žižkov
Germany flag
Berlin
Germany
Rankestraße 26
Singapore flag
Singapore
Singapore
3 Church Street, #29-68 Samsung Hub
Thailand flag
Bangkok
Thailand
Unit P01, Penthouse, VASU1, 1 Sukhumvit 25 Alley
China flag
Foshan
China
A-Tower, Yuneng Digital Plaza, 46 Lishui Avenue South
Kyrgyzstan flag
Bishkek
Kyrgyzstan
32 Razzakov Street
How it works

How to get a payment gateway or processing license: stages

STEP 01
Model and funds flow

We map your contracts, schemes and the money: data-only gateway, acquirer or aggregator. This decides whether you need a licence at all.

STEP 02
Jurisdiction

Where your merchants are and which market access you need: the EU passport, the UK, India, Singapore, the UAE or North America.

STEP 03
Company and substance

Local company, directors, office and the compliance team the supervisor expects to meet.

STEP 04
Application file

Programme of operations, business plan, safeguarding, AML, IT security and outsourcing - filed and defended with the regulator.

STEP 05
Launch

Licence or registration, scheme and acquiring partners, then your first merchants.

Why Prifinance

A law firm, not a license broker.

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.

01
In-house licensing team

60+ specialists work on applications directly. Lawyers, compliance and audit people, not an outsourcing chain of resellers.

02
The written review first

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.

03
Fixed, itemised fees

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.

04
Complete files, structured for PSD3/PSR

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.

05
Support after issuance

Passport notifications, payment-system and banking onboarding, reporting and supervision calendars, variations of permission, and the second licence when one market stops being enough.

Our experts in payment licensing

The people who will prepare your file

Nikolai Timofejev
Nikolai Timofejev
Licensing expert

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.

Oleksii Kindratenko
Oleksii Kindratenko
Licensing & AML advisor

Builds the application itself: the local company, AML/KYC policy pack, safeguarding design, capital structure and tax registrations.

Eugeniu Bevziuc
Eugeniu Bevziuc
International business consultant

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.

Follow Prifinance

Active across our channels.

Client notes
Google4.7★★★★★

Founders who wanted it done right.

Google4.7★★★★★
★★★★★Google
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K N
K N
Google
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“I had their assistance in company registration and I would recommend them. They were answering all my clarification during the process and offering all their supportThank you Daniel and Irinia”
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Google
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Google
FAQ

Payment gateway licenses: the questions we hear.

Does a payment gateway need a license?+

In the EU and the UK, usually not if it only carries payment data: a technical service provider that never takes possession of the funds is excluded (PSD2 Article 3(j), PSRs 2017 Schedule 1 Part 2), and the FCA confirms that providing terminals or online gateways is not in itself acquiring. India's 2025 payment aggregator Directions also leave out gateways with no involvement in handling funds. Other regimes draw the line wider: in Canada, transmitting an instruction for an electronic funds transfer is a payment function under the RPAA; in Singapore, merchant acquisition applies whether or not you hold the money; Pakistan's rules name electronic payment gateways. Once a gateway contracts with merchants to accept their payments or receives their money, expect a licence requirement - acquiring in the EU and UK, payment aggregation in India.

What is the difference between a payment gateway, a processor and an acquirer?+

A gateway carries the transaction data from the merchant's checkout; a processor routes and authorises transactions for an acquirer; the acquirer contracts with the merchant to accept and process its payments and transfers the funds to it. That last step is why acquiring is the licensed activity (PSD2 Article 4(44)).

How much capital does a payment processing license need?+

For acquiring, €125,000 initial capital in the EU and the UK. In India, ₹15 crore net worth when applying as a payment aggregator, rising to ₹25 crore by the end of the third financial year. In Singapore, S$100,000 base capital for a standard and S$250,000 for a major payment institution. In Thailand, THB 50 million for acquiring and THB 10 million for payment facilitating; in Pakistan, PKR 200 million paid-up for a PSO or PSP. In Brazil, capital follows the activities under Joint Resolution BCB/CMN 14/2025, and an acquirer counts as both credit and intermediation. In the UAE, from AED 500,000 to AED 3 million depending on category and monthly volume. In Malaysia, a non-bank merchant acquirer must maintain minimum capital funds of RM300,000 at all times, or RM1 million if its actual or projected average monthly transaction value exceeds RM10 million (since 15 September 2023).

Do I need a license to become a payment facilitator (PayFac)?+

Usually yes. A PayFac receives its sub-merchants' settlement before paying them out, and in the UK the FCA treats payment facilitators that contract with payees for acquiring services as likely to be acquiring (PERG 15.3, Q21). The card schemes register payment facilitators through the sponsoring acquirer under their own rules, but that registration does not replace a licence: a PayFac that receives the settlement usually needs a payment institution authorisation in the EU and UK and the RBI payment aggregator authorisation in India.

Is a payment aggregator license the same as a payment gateway license?+

Not in India: the RBI authorises payment aggregators, which collect and settle merchants' funds through an escrow account (cross-border PAs through separate collection accounts), while payment gateways that only supply technology fall outside the 2025 Directions. Elsewhere, "payment gateway license" usually means the acquiring or aggregation licence.

Is PCI DSS compliance a payment gateway license?+

No. PCI DSS is the card industry's data security standard, set by the PCI Security Standards Council for everyone who stores, processes or transmits cardholder data - merchants, processors, acquirers, issuers and service providers. Whether you must comply and how you prove it is decided by the card brands and your acquirer. An attestation of compliance is not a licence to provide payment services. Regulators can still require it: India's 2025 payment aggregator Directions make PCI-DSS controls mandatory for payment aggregators, ask for PCI-DSS compliance reports to their IT committee and require a check of merchants' PCI-DSS status at onboarding.

Do payment processors need a money transmitter license in the USA?+

At federal level, FinCEN's definition excludes a person that only acts as a payment processor to facilitate the purchase of goods or services through a clearance and settlement system by agreement with the seller. State money transmission laws are separate, and their exemptions - often for an agent of the payee - are worded differently from state to state.

Which license covers merchant acquiring in Singapore, Malaysia and the UAE?+

In Singapore, merchant acquisition is a payment service under the Payment Services Act 2019, licensed as a standard or major payment institution depending on monthly volumes. It applies whether or not the provider comes into possession of the money, and MAS notes that it usually includes providing a point-of-sale terminal or an online payment gateway. In Malaysia, merchant acquiring needs registration with Bank Negara Malaysia under sections 17(1) and 18 of the Financial Services Act 2013, and only a company incorporated in Malaysia can apply. For payment facilitators and gateways BNM checks the activities that together make up merchant acquiring: contracting with merchants, handling settlement, facilitating merchants' acceptance of payment instruments and taking part in a payment instrument network; the name alone neither requires nor exempts registration. In the UAE, merchant acquiring and payment aggregation fall under the Central Bank's Retail Payment Services and Card Schemes Regulation, in Categories I to III.

How long does it take to get a payment processing license?+

In the EU the supervisor must decide within three months of a complete application, and in the UK within three months of a complete application and twelve months at most. The clock starts only once the file is complete, so plan for longer; each country page gives its own timeline.

Can one license cover the whole EU?+

Yes. A payment institution authorised in one member state can passport its services across the EEA by notification. UK payment institutions have had no EU passport since Brexit.

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