# Cash withdrawal from a payment account

Source page: https://protegra.io/licensing/activities/cash-withdrawal/

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.

## 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Services enabling cash to be withdrawn from a payment account, and the operations required to run that account.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](https://eur-lex.europa.eu/eli/dir/2015/2366/oj)

## Which licence you need

Licence families that typically permit this activity:

- [Payment institution (PI)](https://protegra.io/licensing/licences/payment-institution/)
- [Electronic money institution (EMI)](https://protegra.io/licensing/licences/emi/)
- [Bank / credit institution](https://protegra.io/licensing/licences/bank/)

- [EMI · LithuaniaElectronic money institution licence for non-limited activityLB · capital EUR 350,000](https://protegra.io/licensing/licences/emi/lithuania/)

## Where it can be licensed

| | EU/EEA passport | Domestic |
| --- | --- | --- |
| [Lithuania: Electronic money institution licence for non-limited activity](https://protegra.io/licensing/licences/emi/lithuania/) | ✓ | |

## 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.

## Sources

1. [PSD2 Annex I (2)](https://eur-lex.europa.eu/eli/dir/2015/2366/oj): retrieved 2026-09-24

Last verified 2026-09-24 · Author: Danil Marmysh · Reviewed by Anastasia Sidorenkova · © Protegra. Data: CC BY 4.0, cite "Protegra Licensing Atlas". Not legal advice.