Regulated activity

Cash withdrawal from a payment account

Providing cash withdrawal services from a payment account and operating related infrastructure requires a payment institution (PI) licence, an electronic money institution (EMI) licence or a banking licence under PSD2 Annex I (2). Initial PI capital ranges from EUR 20,000 to EUR 125,000. European authorisation allows passporting of cash-out services across all EEA member states.

Last verified 2026-09-24Markdown · Data (CC BY 4.0)
Cash withdrawal from a payment account: regulated activityPSD2

Definition

Services enabling cash to be withdrawn from a payment account, and the operations required to run that account.

Which licence you need

Licence families that typically permit this activity:

Where it can be licensed

Jurisdictions where cash withdrawal from a payment account can be licensedLithuania
Licences in the Atlas that permit this activity
EU/EEA passportDomestic
Lithuania: Electronic money institution licence for non-limited activity✓

Frequently asked questions

Does operating an independent ATM network require a full payment institution licence?

Independent ATM deployers that only dispense cash without maintaining customer payment accounts may qualify for specific national exemptions under PSD2. However, institutions that manage user payment accounts and settle transactions directly require payment institution, EMI or banking authorisation.

Can an authorised payment institution offer cashback at retail checkout?

Yes, licensed payment institutions and electronic money institutions can support cashback services where customers withdraw cash during retail purchases, subject to merchant agreements, daily transaction caps and robust fraud-prevention rules.

Last verified 2026-09-24Author Danil Marmysh, Founder & CEO, ProtegraReviewed by Anastasia Sidorenkova, Head of Licensing, ProtegraReport an errorReference information, not legal advice.

Sources

  1. PSD2 Annex I (2) · retrieved 2026-09-24

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