Payment institution license: PSD2 authorisation, capital and the EU passport.

A payment institution license, often called a PSD2 license, authorises a firm to provide payment services from PSD2 Annex I without taking deposits or issuing e-money. Initial capital is €20,000 for money remittance, €50,000 for payment initiation and €125,000 for services 1 to 5. The supervisor decides within three months of a complete file, and the licence passports across the EEA.

€20k-€125k
initial capital by service (Article 7)
3 months
decision on a complete file (Article 12)
12
countries compared below

Updated · Reviewed by the Prifinance team

Country by country

Payment institution licenses in the EU and the UK

Lithuania flag
Lithuania
Bank of Lithuania · Law on Payment Institutions No XI-549
✓CENTROlink: direct SEPA and instant payments for licensed PIs✓A Lithuanian UAB with management and a resident compliance officer✓€898 state fee for a payment institution licence
6-12 monthsTax: 17% · small 7%More details →
Netherlands flag
Netherlands
De Nederlandsche Bank · Wft, Article 2:3a
✓€20k / €50k / €125k under Article 48 of the Prudential Rules Decree✓€10,400 application fee, charged even if refused✓Registered exemption for services 1-5 up to €3M a month, Netherlands only
12-18 monthsTax: 19% / 25.8%More details →
Ireland flag
Ireland
Central Bank of Ireland · Payment Services Regulations 2018 (S.I. 6/2018)
✓The CBI expects pre-application engagement before the file✓Irish company with its registered office and real operations in Ireland✓Fitness and probity vetting, with interviews of PCF holders
20-25 monthsTax: 12.5% tradingMore details →
Germany flag
Germany
BaFin with the Bundesbank · Zahlungsinstitut under the ZAG
✓Safeguarding of client funds under section 17 of the ZAG✓AML controls under the GwG, with a resident MLRO✓A German-language file and a public ZAG register
15-21 monthsTax: ~30-33% effectiveMore details →
France flag
France
ACPR · Code monétaire et financier, L.522-1
✓Simplified licence under L.522-11-1: €40,000, services 1-5, up to €3M a month✓The simplified licence works in France only, with no EU passport✓The Banque de France gives its opinion before the ACPR decides
9-15 monthsTax: 25% · SME 15%More details →
Spain flag
Spain
Banco de España · Royal Decree-Law 19/2018 and Royal Decree 736/2019
✓No decision within three months of a complete file counts as refusal✓Low-volume register up to €3M a month, without PIS or AIS✓SEPBLAC reports on the file before the Banco de España decides
12-18 monthsTax: 25% · new cos 15%More details →
Luxembourg flag
Luxembourg
CSSF · Law of 10 November 2009 on payment services
✓A Luxembourg company managed locally, with resident directors✓The process opens with a CSSF pre-application meeting✓€30,000 CSSF fee to examine the application
12-18 monthsTax: 23.87% · Lux CityMore details →
Malta flag
Malta
MFSA · Financial Institutions Act, Cap. 376
✓A staged, risk-based MFSA review with question rounds✓An English-language file, start to finish✓€10,000 application fee under S.L. 376.03, non-refundable
12-18 monthsTax: 35% nominal · ~5% after refundsMore details →
Cyprus flag
Cyprus
Central Bank of Cyprus · Payment Services Laws of 2018 to 2023
✓€10,000 application fee, plus €5,000 for the pre-application stage✓Dual-licensing guidance for crypto firms whose flows cross into payments✓17 years of non-dom tax status for the founder
≈27 monthsTax: 15% · since 1 Jan 2026More details →
Poland flag
Poland
KNF · Payment Services Act 2011 · KIP / MIP
✓Two-stage KNF review: formal completeness first, then substance✓The MIP is a registration, not an authorisation: up to €1.5M a month, Poland only✓Central Europe's largest home market; the file is in Polish
12-18 monthsTax: 19% · small 9%More details →
Czech Republic flag
Czech Republic
Czech National Bank · Act No 370/2017
✓A Czech-language file, assessed against the EBA guidelines✓Small-scale payment service provider: CNB authorisation up to a €3M monthly average✓Electronic-only filing on the Decree 1/2022 forms
12-18 monthsTax: 21%More details →
United Kingdom flag
United Kingdom
FCA · Payment Services Regulations 2017 · API / SPI
✓FCA supplementary safeguarding rules in force since 7 May 2026✓SPI registration up to a €3M monthly average, counting agents' transactions✓No AIS or PIS under the SPI; no EU passport since Brexit
6-12 monthsTax: 25% · 19% smallMore details →
What the license covers

Eight payment services, three capital tiers

Annex I of PSD2 lists the services a payment institution can be authorised for: placing cash on and withdrawing it from a payment account (1-2), executing payments from an account or a credit line - direct debits, card payments and credit transfers (3-4), issuing payment instruments and acquiring (5), money remittance (6), payment initiation (7) and account information (8). The authorisation names the services you choose, and the widest one sets the capital.

✓Money remittance only€20,000 initial capital (Article 7).✓Payment initiation only€50,000 and professional indemnity insurance (Articles 7 and 5(2)).✓Any of services 1-5€125,000: accounts, transfers, card issuing and acquiring (Article 7).✓Account information onlyRegistration with professional indemnity insurance and no initial capital (Articles 33 and 5(3)).
These amounts are the minimum for authorisation. After that, own funds may not fall below the higher of the initial capital and the figure under method A, B or C, which the supervisor chooses (Articles 8 and 9). Firms that provide only payment initiation or account information are outside the three methods.
Map my services to Annex I
Lighter routes

Small payment institution: up to €3 million a month

Member states may exempt firms that provide services 1 to 6 if the total value of their payment transactions, averaged per month over the previous 12 months, stays within a limit they set - at most €3 million (Article 32). A small payment institution keeps its head office where it trades, its managers must have no money-laundering, terrorist-financing or financial-crime convictions, and it cannot passport. Once it no longer meets the conditions, it has 30 days to apply for authorisation.

✓Netherlands: registered exemption for services 1-5, up to €3M a month✓France: simplified licence at €40,000, up to €3M a month✓Spain: low-volume register up to €3M a month✓Poland: MIP registration up to €1.5M a month, Poland only✓Czech Republic: small-scale provider up to a €3M monthly average✓United Kingdom: SPI registration up to €3M a month, no AIS or PIS
Not every member state uses the exemption, and those that do set their own threshold and conditions.
Check if a small PI fits
What it costs

Payment institution license cost: official fees by country

The application fee is set in each country's law or in the supervisor's own fee rules. Initial capital of €20,000-€125,000, the company, local staff and the file come on top.

CountrySupervisor's fee for a PI licenceLegal basis
Lithuania€898 state fee; restricted licence €682; account information only €693Government Resolution No 1458, items 3.94, 3.95 and 3.153
Netherlands€10,400, also charged if the licence is refused or the application withdrawnRegeling bekostiging financieel toezicht eenmalige handelingen, Wft.D1.01
IrelandNo application fee; an annual funding levy once authorisedCentral Bank of Ireland
GermanyCharged by time spent under the BaFin fee scheduleFinDAGebV, Annex, item 11.1.1
FranceNo application fee in the ACPR list of charges; annual contribution of 0.66‰, minimum €500Code monétaire et financier, L.612-20
SpainNo fee in the Royal Decree-Law, the Royal Decree or the Banco de España procedureRDL 19/2018, RD 736/2019
Luxembourg€30,000 to examine the application, then €25,000-€40,000 a yearGrand-Ducal Regulation of 23 December 2022 on CSSF fees, point X.1
Malta€10,000, non-refundable; €25,000 annual supervisory fee from licensingFinancial Institutions (Fees) Regulations, S.L. 376.03
Cyprus€10,000, plus €5,000 for the pre-application stage since 3 August 2026Central Bank of Cyprus
Poland€1,250 for issuing the KIP permit; from 11 February 2027 a fee on the application of up to €1,500Regulation of the Prime Minister of 23 April 2020, § 8; Payment Services Act, art. 114
Czech RepublicCZK 50,000 for a PI and CZK 10,000 for a small-scale provider, non-refundableAct No 634/2004 on administrative fees, item 65
United Kingdom£5,640, or £2,820 for remittance, PIS or AIS only; small PI £1,130; non-refundableFCA Handbook, FEES 3 Annex 1AR and 8R

Fees checked against the official sources listed below on 20 October 2026. Several supervisors also charge an annual fee once you are licensed.

Related guides

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Payment gateway and processing license

When a gateway, processor, acquirer or PayFac needs a licence: the two questions that settle it, then acquiring and aggregation licences by country, with capital and timelines.

Route by route

PSD2 license types: payment institution, small PI, AISP - or an EMI

A small PI moves to full authorisation when it outgrows the volume limit or needs the passport. An AISP does so when it wants to offer other payment services.

RouteInitial capitalEU passportFits
Payment institution (PSD2, Article 11)€20,000, €50,000 or €125,000 by serviceYesAcquiring, transfers, remittance, payment initiation
Small payment institution (Article 32)Set nationally; volume up to €3M a monthNoTesting a model in one member state
Account information only (Article 33)None; professional indemnity insuranceYesAccount aggregation with the user's consent
E-money institution (EMD2, Article 4)€350,000YesIssuing e-money and holding balances
Important: Funds a payment institution receives for payments are not deposits, and it may not take deposits (Article 18(3) and (5)); to issue e-money you need the e-money institution licence.
Before you apply

Payment institution license requirements: the Article 5 file

Article 5 of PSD2 lists what the application must contain. Supervisors read it as one file, and mismatches come back as questions: capital that does not cover the services applied for, or AML controls that do not fit the customers in the business plan.

01
Programme of operations and business plan The services you will provide and a three-year budget forecast showing the firm can operate soundly (Article 5(1)(a) and (b)).
02
Initial capital Evidence of the €20,000, €50,000 or €125,000 your services require (Article 5(1)(c)).
03
Safeguarding Client funds kept apart and, if not paid out by the end of the next business day, placed in a separate account at a credit institution or a central bank (at the central bank's discretion) or in secure low-risk assets - or covered by insurance or a guarantee (Articles 5(1)(d) and 10; Article 10 as amended by Regulation (EU) 2024/886).
04
Governance and AML controls Organisation, risk management and accounting procedures, plus the internal controls you run against money laundering and terrorist financing (Article 5(1)(e) and (k)).
05
Security and continuity Incident handling, access to sensitive payment data, business continuity, fraud statistics and a security policy (Article 5(1)(f) to (j)).
06
Owners and managers Qualifying shareholders and directors with evidence of suitability and good repute, and a head office in the state of the registered office (Articles 5(1)(m), (n) and 11(3)).
Note: Each country page lists its own regulator, fees and filing format.
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 institution license: stages

STEP 01
Services and route

We map your model to the Annex I services and choose between full authorisation, the small PI regime or account information registration.

STEP 02
Home member state

We choose the state where you will apply and keep your head office.

STEP 03
Company and people

A local company with its head office and part of its business in that state, directors, a compliance officer and an MLRO.

STEP 04
Application file

The Article 5 file, safeguarding and own-funds method, AML and IT security - filed and defended with the supervisor.

STEP 05
Passport and agents

A notification to the home supervisor for each new EEA state, and agents registered before they start.

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
“As a software development crew at FewMoreTaps OÜ, we've had the pleasure of working with Prifinance on some key financial moves.First of all, navigating the world of corporate banking and finance can be a maze, but Prifinance made it feel like a walk in the park. They helped us set up a corporate bank account without the hassle of jumping on a plane or drowning in paperwork. Everything was done remotely, smoothly…”
K N
K N
Google
★★★★★Google
“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”
Mina Kedis
Mina Kedis
Google
★★★★★Google
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Юрий Валерьевич
Юрий Валерьевич
Google
★★★★★Google
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Anna Anna
Anna Anna
Google
★★★★★Google
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Анастасия Одокиенко
Google
★★★★★Google
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Maria Jose Santome
Maria Jose Santome
Google
FAQ

Payment institution licenses: the questions we hear.

What is a payment institution license?+

Authorisation under PSD2 to provide one or more payment services listed in Annex I - acquiring, transfers, money remittance, payment initiation and the others - without being a bank or an e-money institution. Only a legal person established in a member state can hold it, with its head office in the state of its registered office, and once granted it is valid across the EU (Article 11). Every authorised institution appears in its supervisor's public register and in the EBA register (Articles 14 and 15).

What is a PSD2 license?+

PSD2 has no licence of that name: the phrase usually means payment institution authorisation, or payment initiation and account information status for open banking. Payment initiation needs authorisation with €50,000 initial capital and professional indemnity insurance; account information alone needs registration and the insurance, with no initial capital (Articles 5, 7 and 33).

How much capital does a payment institution need?+

€20,000 for money remittance only, €50,000 for payment initiation only and €125,000 for any of services 1 to 5 (Article 7). Once licensed, the institution calculates own funds by one of three methods the supervisor chooses (Article 9): A is 10% of the previous year's fixed overheads, B a share of payment volume, C an income-based indicator. Own funds may never fall below the initial capital (Article 8), and firms providing only payment initiation or account information are outside the three methods.

How much does a payment institution license cost?+

Initial capital of €20,000-€125,000 by service (Article 7), plus the supervisor's fee where one is charged. Ireland charges nothing for the application, Lithuania €898, Malta and Cyprus €10,000, the Netherlands €10,400 and Luxembourg €30,000; in the UK the FCA charges £5,640. Several supervisors add an annual fee once you are licensed. Company set-up, local staff and the file come on top; the table above lists each fee with its legal basis.

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

The supervisor must decide within three months of receiving the application or, if it is incomplete, of receiving all the information it needs, and must give reasons for a refusal (Article 12). In practice it takes longer: for applications filed in 2022-2024 the EBA found averages from 4-6 months in six member states to 27 months in Cyprus, with an EU median of 9.5 months leaving Cyprus aside, counted from filing to decision. Company set-up and pre-application talks come on top; each card above shows the timeline for its country.

What is a small payment institution?+

A firm that a member state exempts from full authorisation under Article 32. The exemption covers only services 1 to 6 of Annex I, so no payment initiation or account information, and applies only while the total value of the firm's payment transactions, averaged per month over the previous 12 months, stays within a national limit of at most €3 million. A small payment institution keeps its head office where it trades and cannot passport; once it no longer meets the conditions, it has 30 days to apply for authorisation. The Netherlands, France, Spain, Poland and the Czech Republic run such routes in different forms; Poland caps its MIP at €1.5 million a month.

Can a payment institution passport across the EU?+

Yes. An authorised payment institution notifies its home supervisor, which forwards the notification to the host supervisor within a month; agents and branches start once they are entered in the register (Article 28). Small payment institutions cannot passport, and UK payment institutions have had no EU passport since Brexit.

What is the difference between a payment institution and an EMI?+

An e-money institution can also issue e-money and needs €350,000 initial capital under the E-Money Directive (Article 4). A payment institution moves money but does not issue it, needs from €20,000 of initial capital and may not take deposits; the funds it receives for payments are not deposits but must be safeguarded (PSD2 Articles 10 and 18).

Can a payment institution work through agents?+

Yes, with each agent registered first: the institution sends its home supervisor the agent's details, AML controls, managers and services, and the supervisor says within two months whether the agent is entered in the register (Article 19). The institution must make sure its agents tell customers they act on its behalf.

What changes with PSD3 and the Payment Services Regulation?+

Council and Parliament reached a provisional agreement on 27 November 2025 on a new Payment Services Regulation and a revised directive, widely called PSD3, that also covers e-money and repeals the E-Money Directive. Coreper confirmed the deal on 22 April 2026 and Parliament's ECON committee on 5 May 2026; the Council's first-reading position is pending, and Parliament's final vote is indicatively set for 14 December 2026. Until the texts are published and apply, national laws transposing PSD2 govern authorisation.

Which EU country is best for a payment institution license?+

Capital and the passport are the same everywhere, so the choice comes down to market, language, fees and timing. Lithuania gives licensed payment institutions direct SEPA access through CENTROlink, France offers a €40,000 simplified licence for its domestic market, Malta and Ireland file in English, and the Netherlands publishes a €10,400 application fee. The cards above compare 11 EU countries and the UK.

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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 Bank of Lithuania, BaFin, the Central Bank of Ireland, the Financial Conduct Authority, the Monetary Authority of Singapore, the Hong Kong Monetary Authority, FINMA or any other public authority. Licences are granted by, and obtained directly from, the competent authorities. Our services consist of legal consulting and corporate and administrative support.

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