Coverage · Electronic Money

Your EMI license, handled.

Applying for authorisation, running a small-EMI regime you're about to outgrow, or already issuing and carrying the safeguarding load — your gap analysis, policy suite and application pack are built here, from your own data. And when e-money merges into PSD3, you'll cross with a delta report, not a project.

Frankfurt banking towers seen from below
30
EEA states, one passport
€350K
initial capital for a full EMI
9–12
months on the typical EMI route — preparation is the part you control
2%
of average outstanding e-money, your ongoing own-funds floor (Method D)

The framework

What is EMD2?

The E-Money Directive is the EU's rulebook for stored value — issuing it, redeeming it, and protecting the funds behind it. It's what stands between a wallet product and a bank license: you can hold customer balances without being a bank, provided the money is safeguarded, redeemable at par, and backed by your own funds. If your product holds a balance, EMD2 governs you.

Redeemability at par
Holders can redeem at face value, at any time — your terms, fees and SLAs have to honour it.
Safeguarding
Funds received for e-money are segregated or insured, reconciled daily — the obligation regulators test first.
Prudential standards
€350K to enter, own funds of at least 2% of outstanding e-money to stay — recalculated as you grow.
EU passporting
Authorised once, by any NCA, you issue across all 30 EEA states.

Four ways in. One of them is yours.

Stored value has more doors than it seems. What you owe the regulator depends on which one you're walking through.

FULL EMI AUTHORISATION

You issue e-money — wallets, prepaid balances, stored value at scale. €350K initial capital, passportable across the EEA, payment services included. The main route — and the one detailed below.

SMALL EMI REGISTRATION

Your average outstanding e-money stays under the national ceiling (up to €5M). A lighter national regime — faster in, but no passport, and you'll outgrow it. We build the file so the upgrade to full EMI is an update, not a restart.

TOKENISED? THAT'S MiCA TOO

Your e-money lives on-chain — a token pegged to one fiat currency. That's an EMT: you still need the EMI (or credit-institution) authorisation, plus MiCA's white paper and conduct rules on top.

MiCA coverage →
NO STORED VALUE? THAT'S PSD2

Funds only pass through you to complete a payment — nothing sits on a balance. You're a payment institution, one page over — lower capital, same machinery.

PSD2 coverage →

Not sure which applies? That's the first question the readiness check answers.

One authorisation. Two businesses.

An EMI license isn't just permission to issue — it carries the full payment-services scope with it. One authorisation, one supervisor, both sides of your product.

Issuing e-money

Issue and redeem stored value, at par
Distribute and redeem through agents and distributors
Safeguard the float — segregation or insurance, reconciled daily
Hold own funds at 2%+ of outstanding e-money (Method D)

Providing payment services

All eight PSD2 payment services, under the same authorisation
Execute transfers, issue instruments, acquire, remit
Grant limited payment-related credit
Own funds for this side calculated separately (Methods A/B/C)

Initial capital set by EMD2 at €350,000; ongoing own funds are the higher of your combined requirement or the initial capital. NCAs may require more. Small EMIs: national ceilings up to €5M average outstanding, no passport.

The journey hasn't changed. Your side of it has.

From first assessment to authorisation — with months of preparation compressed into weeks, and the regulator's clock kept clean.

Shown for full EMI authorisation — the main route. The same machinery runs small-EMI files, the upgrade between them, and EMT work under MiCA.

The traditional route

12–18+ MONTHS
Consultant scoping
Policy drafting with external counsel
Assembly & internal review
NCA review — repeated RFI clock-stops
6+ MONTHS OF PREP → 1–4 WEEKS

With ComplyBridge

AS FAST AS YOUR INPUTS — WEEKS, NOT QUARTERS
Submission-ready

Gap analysis, full policy suite, safeguarding arrangements and a validated application pack — generated from your data, scoped to how you'll actually issue.

FIXED BY LAW, KEPT ON COURSE
NCA review — the statutory clock

Fixed by law, not by us. A complete, validated package means fewer RFIs and fewer clock-stops — we track every deadline and keep the application on course.

ONGOING
Authorised & beyond

Daily safeguarding reconciliation, own-funds recalculation as your float grows, redemption monitoring, outstanding e-money reporting, passporting. Authorisation is where this page ends — and where most of the platform's life is spent.

Document generation itself takes hours. The pace is set by how ready your inputs are.

What's next

E-money is merging into PSD3.

EMD2's successor isn't a third E-Money Directive — it's the PSD3 package. Agreed in late 2025 and expected to apply from 2027, it repeals EMD2 and folds e-money into the payment institution regime: EMIs become payment institutions authorised to issue e-money. One rulebook, one license category, one supervisor's lens.

Existing authorisations carry over — but your file, governance records and reporting won't update themselves, and the e-money-specific obligations (safeguarding, redeemability, own funds) survive the merger in new clothes. Because your policies live in ComplyBridge mapped to the article level, the transition arrives as a delta: what changed, which paragraph of which policy it touches, and what to do about it. Firms still on spreadsheets get a project. You get a task list.

One regime

The EMI category dissolves into the PI framework; mixed e-money/payments models finally get one door.

Obligations survive

Safeguarding, par redemption and own-funds rules carry into the new regime — renamed, not removed.

Files updated, not reopened

Grandfathered authorisation, refreshed documentation — your delta starts counting now.

How ComplyBridge helps

Months of manual work, automated.

Start a readiness check
Automated policy generation

Safeguarding, redemption, own-funds and outsourcing policies pre-mapped to EMD2 and the EBA guidelines, populated from your specifics, version-controlled from day one.

Intelligent document assembly

License Builder compiles the pack — programme of operations, safeguarding arrangements, business plan — cross-references every requirement, and tells you what's missing before the NCA does.

Ongoing compliance monitoring

Daily safeguarding reconciliation, own-funds tracking against your float, redemption SLAs, outstanding e-money reporting, passporting notifications — for every year after the license.

Start a readiness check
Already authorised?

Start from the other side — the readiness check maps your current obligations instead of your application. And with EMD2's merger into PSD3 agreed, your delta starts counting now. See how the ongoing side works →

FAQ

Common questions.

Do I need an EMI license?
If customer funds sit on a balance in your product — a wallet, a prepaid account, stored value of any kind — yes, or you need to fit an exclusion (limited network, agent of an issuer). If funds only pass through you, you're likely a PI under PSD2 instead. The readiness check tells you which, before you spend money on the wrong assumption.
Full EMI or small EMI — where do I start?
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How does safeguarding actually work?
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We're issuing a stablecoin — is that e-money?
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How long does authorisation take?
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Can I issue across the EU with one license?
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What happens to EMD2 under PSD3?
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We're already authorised — is this page still for us?
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Find out how ready you are.

Two minutes of questions. A gap analysis mapped to EMD2's actual requirements — and the merger that's coming for them — yours to keep either way.

Already authorised? See how the ongoing side works →