Electronic money institution licence (Germany)
The Electronic money institution licence (Erlaubnis für das E-Geld-Geschäft nach § 11 ZAG) is issued by Federal Financial Supervisory Authority (BaFin) under German Electronic Securities Act (Gesetz über elektronische Wertpapiere - eWpG). It can be passported to the other EU/EEA states by notification. The official register lists 14 current holders. The legal decision period is 3 months from receipt of complete application, maximum 12 months overall. Ownership changes need the regulator's approval before completion.
At a glance
| Official name | Electronic money institution licence1 |
|---|---|
| Local name | Erlaubnis für das E-Geld-Geschäft nach § 11 ZAG |
| Also known as | EMI · E-Geld-Institut · Erlaubnis für das E-Geld-Geschäft · German EMI licence · BaFin EMI licence · German e-money licence |
| Issued by | Federal Financial Supervisory Authority |
| Jurisdiction | Germany |
| Licence family | Electronic money institution (EMI) |
| Legal basis | German Electronic Securities Act (Gesetz über elektronische Wertpapiere - eWpG)2 Directive 2009/110/EC on electronic money institutions (EMD2)3 |
| Passporting | EU/EEA passport available |
| Application fee | nach Zeitaufwand (billed based on staff time spent)4 |
| Annual fee | Annual cost allocation levy (Umlage) based on transaction volume5 |
| Statutory decision time | 3 months from receipt of complete application, maximum 12 months overall6 |
| Public register | official register7 |
| Current holders | 147 |
What it lets you do
| 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: 3 months from receipt of complete application, maximum 12 months overall6. 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 notification with an objection period. Acquiring or increasing a qualifying holding reaching or crossing 10%, 20%, 30%, or 50% of capital or voting rights, or gaining control of a credit institution, payment institution, or investment firm, requires prior written notification to BaFin and the Deutsche Bundesbank. BaFin conducts an assessment of acquirer reliability, professional competence, financial soundness, and money laundering risks within 60 working days from receipt of a complete filing, interruptible once by up to 20 working days (or 30 working days if non-EEA) to request additional information, under Section 2c KWG, applied mutatis mutandis to payment and e-money institutions via Section 14 ZAG and to investment firms via Section 24 WpIG.8
EMI in other countries
| Country | Licence | Regulator | Min. capital | Application fee | Statutory time |
|---|---|---|---|---|---|
| Czech Republic | Small-scale Electronic Money Issuer authorisation | CNB | n/a | CZK 10,000 | ~1 mo |
| Czech Republic | Electronic Money Institution licence | CNB | n/a | CZK 50,000 | ~3 mo |
| Estonia | Electronic money institution operating with an exception | FI | n/a | n/a | n/a |
| Estonia | Operating licence as an electronic money institution | FI | n/a | n/a | ~3 mo |
| Germany | Electronic money institution licence | BaFin | n/a | n/a | ~3 mo |
| Ireland | Electronic Money Institution Authorisation | CBI | n/a | n/a | n/a |
| Latvia | Registered electronic money institution | LB | n/a | EUR 2,500 | ~1.7 mo |
| Latvia | Authorised electronic money institution licence | LB | n/a | EUR 5,000 | ~3.7 mo |
| Lithuania | Electronic money institution licence for restricted activity | LB | n/a | n/a | n/a |
| Lithuania | Electronic money institution licence for non-limited activity | LB | EUR 350,000 | EUR 1,463 | ~3 mo |
| Luxembourg | Electronic money institution authorisation | CSSF | n/a | EUR 30,000 | ~3 mo |
| Malta | Electronic money institution licence | MFSA | n/a | EUR 15,000 | ~3 mo |
| Netherlands | Electronic money institution licenceElectronic money institution licence (Vergunning elektronischgeldinstelling) | DNB | n/a | EUR 6,800 | ~3 mo |
| Poland | Electronic Money Institution licence | KNF | n/a | EUR 1,250 | ~3 mo |
| Slovakia | Electronic money institution licence | NBS | n/a | n/a | n/a |
| Spain | Electronic money institution authorization | BdE | n/a | n/a | ~3 mo |
| United Kingdom | Small Electronic Money Institution (SEMI) Registration | FCA | n/a | GBP 1,130 | n/a |
| United Kingdom | Authorised Electronic Money Institution (AEMI) | FCA | n/a | GBP 5,640 | ~3 mo |
Values come from each licence's page, where every figure has its source.
Laws behind it
Sources
- gesetze-im-internet.de: 11 · retrieved 2026-09-24
- gesetze-im-internet.de: ewpg · retrieved 2026-09-24
- EUR-Lex: CELEX 32009L0110 · retrieved 2026-09-24
- gesetze-im-internet.de: anlage · retrieved 2026-09-24
- bafin.de: finanzierung node · retrieved 2026-09-24
- gesetze-im-internet.de: 10 · retrieved 2026-09-24
- portal.mvp.bafin.de · retrieved 2026-09-24
- gesetze-im-internet.de: 2c · retrieved 2026-09-24
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