Electronic money institution (EMI) · Estonia

Electronic money institution operating with an exception (Estonia)

The Electronic money institution operating with an exception is issued by Finantsinspektsioon (FI) under Payment Institutions and E-money Institutions Act. It can be passported to the other EU/EEA states by notification. The official register lists 0 current holders. Ownership changes need the regulator's approval before completion.

Last verified 2026-09-24Regulator FIMarkdown · Data (CC BY 4.0)
Electronic money institution operating with an exception: licenceEMI

At a glance

Official nameElectronic money institution operating with an exception1
Also known asEstonian small EMI · Estonian EMI with derogation · E-money institution with an exception
Issued byFinantsinspektsioon
JurisdictionEstonia
Licence familyElectronic money institution (EMI)
Legal basisPayment Institutions and E-money Institutions Act2
Directive 2009/110/EC on the taking up, pursuit and prudential supervision of the business of electronic money institutions (EMD2)3
PassportingEU/EEA passport available
Public registerofficial register1
Current holders01

What it lets you do

Issuing electronic moneyIssuing monetary value stored electronically against funds received, redeemable at par and accepted by third parties as payment.
Execution of payment transactionsExecuting direct debits, card payments and credit transfers, including standing orders, from a payment account.
Money remittanceReceiving funds from a payer solely to transfer them to a payee or another provider, without opening payment accounts.
Issuing payment instruments and acquiring payment transactionsIssuing cards or other payment instruments to payers, and acquiring card and other payment transactions for merchants.
Payment initiation servicesInitiating a payment order at the user's request from an account held with another provider, as in open banking.
Account information servicesProviding consolidated online information on one or more payment accounts the user holds with other providers.

Where it is valid

Estonia licence, passportable across the EU/EEAATBEBGHRCYCZDKEEFIFRDEGRHUIEITLVLTLUNLPLPTROSKSIESSEISNOMTLI
Issued in Estonia (gold); can be passported to the other EU/EEA states (blue) by notification.

Buying a company that already holds it

Prior approval required. Acquiring or increasing a qualifying holding reaching or crossing 10%, 20%, 30%, or 50% of share capital or voting rights in an Estonian bank, payment institution, EMI, investment firm, or CASP requires prior notification and approval from Finantsinspektsioon. Filings are submitted electronically through the FI Application Portal (or via the ECB SSM portal for credit institutions). The statutory assessment period is 60 working days from receipt of complete documentation, interruptible once by up to 20 or 30 working days to request additional information, evaluating acquirer reputation, financial solidity, and AML/CFT compliance.4

Ready-made companies holding this licence: see verified positions.

EMI in other countries

CountryLicenceRegulatorMin. capitalApplication feeStatutory time
Czech RepublicSmall-scale Electronic Money Issuer authorisationCNBn/aCZK 10,000~1 mo
Czech RepublicElectronic Money Institution licenceCNBn/aCZK 50,000~3 mo
EstoniaElectronic money institution operating with an exceptionFIn/an/an/a
EstoniaOperating licence as an electronic money institutionFIn/an/a~3 mo
GermanyElectronic money institution licenceBaFinn/an/a~3 mo
IrelandElectronic Money Institution AuthorisationCBIn/an/an/a
LatviaRegistered electronic money institutionLBn/aEUR 2,500~1.7 mo
LatviaAuthorised electronic money institution licenceLBn/aEUR 5,000~3.7 mo
LithuaniaElectronic money institution licence for restricted activityLBn/an/an/a
LithuaniaElectronic money institution licence for non-limited activityLBEUR 350,000EUR 1,463~3 mo
LuxembourgElectronic money institution authorisationCSSFn/aEUR 30,000~3 mo
MaltaElectronic money institution licenceMFSAn/aEUR 15,000~3 mo
NetherlandsElectronic money institution licenceElectronic money institution licence (Vergunning elektronischgeldinstelling)DNBn/aEUR 6,800~3 mo
PolandElectronic Money Institution licenceKNFn/aEUR 1,250~3 mo
SlovakiaElectronic money institution licenceNBSn/an/an/a
SpainElectronic money institution authorizationBdEn/an/a~3 mo
United KingdomSmall Electronic Money Institution (SEMI) RegistrationFCAn/aGBP 1,130n/a
United KingdomAuthorised Electronic Money Institution (AEMI)FCAn/aGBP 5,640~3 mo

Values come from each licence's page, where every figure has its source.

Laws behind it

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. fi.ee: supervised entities · retrieved 2026-09-24
  2. Estonian State Gazette (Riigi Teataja) · retrieved 2026-09-24
  3. EUR-Lex: CELEX 32009L0110 · retrieved 2026-09-24
  4. taotlus.fi.ee · retrieved 2026-09-24

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