Payments & E-Money Licensing

Before choosing between licences, establish whether your activity is regulated at all. The trigger isn’t your product category — it’s what your product does in regulatory terms. Two apps that look identical to a user can sit on opposite sides of the line depending on how money flows through them.

Start by writing your money flows out plainly: who holds funds, for how long, and who they belong to at each step. A marketplace that lets a payment processor handle settlement is in a very different position from one that takes funds into its own account and pays out later.

Most teams’ path comes down to one question: do you store value, or only execute payments?

• E-money institution (EMI) — can issue and hold electronic money. If your users top up a balance and spend it later, you’re storing value, and this is usually the route.
• Payment institution (PI) — executes payment transactions but generally can’t hold e-money. If you move funds from A to B without parking a stored balance, this is often the lighter-weight fit.

The distinction sounds clean but turns on the detail of your actual flows, which is why step 01 matters first. The right answer is the one that matches how money really sits in your system — not the licence that sounds most impressive.

There is no universally "best" fintech jurisdiction — only the best fit for your markets, budget, timeline, and how much regulatory credibility you need to win customers and partners. The useful output is a ranked shortlist, not a single recommendation handed down from on high.

What goes into the ranking:

• Capital requirements — the minimum you’ll need to hold, which varies by licence and place.
• Timeline — how long authorisation realistically takes in that regulator’s queue.
• Cost — application, advisory, and ongoing-supervision costs across the options.
• Passporting — whether one authorisation lets you serve a whole region, or you’ll need more.
• Credibility — how much weight the licence carries with your banking partners and customers.

Once you’ve chosen a route, the requirements become concrete. Across jurisdictions, supervisors look hard at the same few areas — and a thin showing in any one of them slows or sinks an application:

• Governance — a credible structure, clear responsibilities, and people actually running the firm.
• Safeguarding — how customer funds are protected and kept separate from your own money.
• Fit-and-proper — the suitability and track record of directors and key function holders.
• Substance — real operations in the jurisdiction, not a nameplate.

These aren’t boxes to tick at the end — they shape your hiring, your banking, and your operating model, so it pays to design for them early.

The submission is where a strong plan becomes an approvable one. Regulators want a coherent pack that shows you understand your own business and its risks — not blank templates filled in at the last minute. The core of it:

• Business plan — your model, financials, and how the numbers hold together.
• Governance and safeguarding policies — written to your actual operations, not copied from a generic library.
• The submission pack — assembled the way the specific regulator expects to receive it.