Regulated activity

Issuing electronic money

EMD2 Article 2(2) covers electronic money, monetary value stored electronically, redeemable at par, accepted by third parties as payment. Issuing it needs an EMI licence or a banking licence. An EMI needs EUR 350,000 of initial capital, must safeguard the funds it receives against its own insolvency, and can then passport across the EEA.

Last verified 2026-09-24Markdown · Data (CC BY 4.0)
Issuing electronic money: regulated activityEMD2

Definition

Issuing monetary value stored electronically against funds received, redeemable at par and accepted by third parties as payment.

Which licence you need

Licence families that typically permit this activity:

Where it can be licensed

Jurisdictions where issuing electronic money can be licensedCzech RepublicEstoniaGermanyIrelandLatviaLithuaniaLuxembourgNetherlandsPolandSlovakiaSpainUnited KingdomMalta
Licences in the Atlas that permit this activity
EU/EEA passportDomestic
Czech Republic: Small-scale Electronic Money Issuer authorisation✓
Czech Republic: Electronic Money Institution licence✓
Estonia: Electronic money institution operating with an exception✓
Estonia: Operating licence as an electronic money institution✓
Germany: Electronic money institution licence✓
Ireland: Electronic Money Institution Authorisation✓
Latvia: Registered electronic money institution✓
Latvia: Authorised electronic money institution licence✓
Lithuania: Electronic money institution licence for restricted activity✓
Lithuania: Electronic money institution licence for non-limited activity✓
Luxembourg: Electronic money institution authorisation✓
Malta: Electronic money institution licence✓
Netherlands: Electronic money institution licence✓
Poland: Electronic Money Institution licence✓
Slovakia: Electronic money institution licence✓
Spain: Electronic money institution authorization✓
United Kingdom: Small Electronic Money Institution (SEMI) Registration✓
United Kingdom: Authorised Electronic Money Institution (AEMI)✓

Frequently asked questions

How does electronic money differ from bank deposits?

A bank deposit is repayable, and the bank can lend it out for interest, backed by a statutory deposit guarantee scheme. Electronic money works differently: it is prepaid digital cash backed by segregated client assets, and it cannot be lent out or earn interest for the cardholder.

Can an authorised EMI provide payment services without a separate licence?

Yes. An EMI licence automatically covers every payment service listed under PSD2, so the institution can execute transfers, acquire card transactions and issue payment cards without a second, separate payment institution licence.

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. EMD2 Art. 2(2) · retrieved 2026-09-24

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