LKS Consult – Practice areas – Financial Licenses in Estonia – EMI License in Estonia

EMI License in Estonia

Fintech is a rapidly evolving industry and attracts more and more entrepreneurs. Therefore, online banking has vast and promising potential. While traditional banking steps aside, businesses such as TransferWise, Paysera, Payoneer, Monese and Revolut are blooming.

E-money license in Estonia allows to set up a payment system and operate as a financial institution in Estonia.

Speaking of such businesses within Estonia, payment service providers need to obtain an operating e-money license to provide payment services. EMI license is acceptable across the EU, and once obtained, could be used in all states.

EMI license is issued by the Estonian Financial Supervision Authority (EFSA). To apply for it, a written application must be submitted to FSA. It is also required to submit additional documents that the Estonian Payment Institutions and E-money Institutions Act (MERAS) requires.

Electronic money institution

Some of the E-money institution areas of activity are:

  • Money transfers
  • Cash depositing and withdrawal
  • Issuing of Electronic Money
  • Issuing of payment instruments
  • Payment Initiation Service (PSD2)
  • Account Information Service (PSD2)

Share capital

The minimum capital in Europe is 350,000 EUR together with a 3-year budget followed by a business plan. Initial capital cannot be formed of the property. Also, it is required to confirm the source of funding.

The entire process takes about 8-12 months.


To apply for an operating license to issue e-money in own company’s name, the following information needs to be gathered and submitted to EFSA:

  1. A copy of the statutes for a business that is operating, any decision by the general meeting to amend the statutes, and the amended text of the statutes
  2. A notarised copy of the foundation contract or decision for a business being founded
  3. Documentation proving the existence of share or equity capital paid in or to be paid in
  4. An operating plan describing above all the planned payment or e-money services
  5. A business plan that meets the requirements of MERAS
  6. The initial balance of the applicant and a review of income and expenses or the balance and profit report as at the end of the month before the application for an operating business, and annual reports for the past three years if they exist
  7. A description of how the general requirements of MERAS for holding client assets and client protection will be applied
  8. The internal rules and internal bookkeeping rules following MERAS, or proposals for them
  9. Data on the information technology and other technological equipment and systems, security systems, and control mechanisms and systems that will be needed to provide the planned services
  10. A description of internal controls and measures to ensure compliance with anti-money laundering and terrorist financing obligations and obligations for information about the payer to be sent when transferring money
  11. A description of the organisational structure of the applicant, covering where necessary the use of agents or branches or the procedures for transferring services, and its participation in domestic and international payment systems
  12. A list of the shareholders of the applicant showing the name of each shareholder, their registry code or ID code, or date of birth if they have none, and details on the share or equity holdings of each shareholder and the voting weight given to them
  13. The data listed in MERAS on the significant shareholders of the applicant
  14. Information on the managers or the applicant, including their first and family names, personal ID codes or date of birth if they have no ID code, place of residence, description of education, complete list of jobs and positions held, and for members of the management board a list of their areas of responsibility, together with any documentation that the applicant considers relevant for demonstrating their trustworthiness and compliance with the requirements
  15. Data on any business that the applicant or its management holds more than 20% of, where those data include the size of its equity, a list of its areas of activity, and the size of the holding of the applicant and each manager
  16. Information on the auditor and internal auditor of the applicant, giving their names, places of residence or locations of operations, and personal ID codes or dates of birth or registry code if there is no ID code
  17. Documentation certifying the value of own funds for a business that is already operating, together with the auditor’s report
  18. The technical, economic and legal principles approved by Eesti Pank for the functioning of the payment system and the draft of the rules organising the work of this system if the applicant intends to engage in managing payment systems


LKS Consult OÜ can help obtain EMI license, thereby ensuring a smooth start for your business.



Managing Associate

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