Operating licence as an electronic money institution (Estonia)

At a glance

What it lets you do

• Issuing electronic money
• Execution of payment transactions
• Money remittance
• Issuing payment instruments and acquiring payment transactions
• Payment initiation services
• Account information services

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

Where it is valid

How long it takes

Statutory: Within 3 months after all necessary documentation is received, and not later than 6 months after initial receipt¹. Observed: not published. The statutory clock usually starts only when the regulator treats the application as complete, and pauses while it waits for answers to its questions.

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.⁵

Laws behind it

• Directive 2009/110/EC on the taking up, pursuit and prudential supervision of the business of electronic money institutions: Directive 2009/110/EC