Cash withdrawal from a payment account
Cash withdrawal from a payment account, and the infrastructure behind it, sits under PSD2 Annex I (2), a PI licence, an EMI licence or a banking licence. PI capital ranges from EUR 20,000 to EUR 125,000. Once authorised anywhere in the EU, the cash-out service passports to the rest of the EEA.
Definition
Services enabling cash to be withdrawn from a payment account, and the operations required to run that account.
- PSD2, Annex I (2): official text
Which licence you need
Licence families that typically permit this activity:
Where it can be licensed
| EU/EEA passport | Domestic | |
|---|---|---|
| Lithuania: Electronic money institution licence for non-limited activity | ✓ |
Frequently asked questions
Does operating an independent ATM network require a full payment institution licence?
Not always. An independent ATM operator that only dispenses cash, with no customer payment account behind it, can often rely on a national exemption under PSD2. Managing the payment account itself, and settling the transaction, is what triggers PI, EMI or banking authorisation.
Can an authorised payment institution offer cashback at retail checkout?
Yes. A licensed PI or EMI can offer cashback at checkout, where the customer withdraws cash alongside a retail purchase. It runs through merchant agreements, daily transaction caps and the institution's own fraud-prevention controls.
Sources
- PSD2 Annex I (2) · retrieved 2026-09-24
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