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Licence guide

Cyprus electronic money institution licence.

An English-speaking, common-law EU base for e-money issuers that want one authorisation passported across the EU and EEA, with the owners assessed at a pre-application stage before the formal file.

Published 16 October 2026 · Last reviewed 17 October 2026
Central Bank (CBC)Regulator
€350,000Initial capital
€10,000Application fee
6 to 8 monthsOur realistic timeline
EU and EEAPassporting

Firms we have licensed.

Selected engagements from more than 250 licences obtained since 2013, for payment, e-money and cryptoasset firms.

Since 2013Advising global payment firms
60+Countries licensed in
250+Licences obtained globally
Clients
ClearBankVolkswagenMacmillan Cancer SupportRoyal College of MusicStaysureOval MoneyEMQCentus
nexpayPayment Institution

Obtained Nexpay’s FCA Authorised Payment Institution licence.

dzingElectronic Money Institution

Obtained Dzing Finance’s FCA Authorised Electronic Money Institution licence.

Payment Institution

Obtained Orbital’s FCA Authorised Payment Institution licence.

What you get

6 to 8 monthsLicence granted

Our realistic timeline from submission to decision.

Day oneReady to trade

Safeguarding, operating and settlement accounts opened alongside the application, so you trade on authorisation.

Your teamKey people in place

We assemble your team: independent directors and senior managers.

Same dayWritten proposal

The licence, the requirements, the cost and the timing for your business.

How we get you licensed and live

  1. Scoping and proposal. We confirm the capital method, the fees and the beneficial owners’ file, and prepare the Pre-Application Document for the Central Bank’s preliminary assessment within 30 working days, or 50 with an enhanced due diligence report.
  2. Application pack. The application form, the personal questionnaires and time commitment tables, the programme of operations, the three-year business plan and the risk policies written for the business under the EBA guidelines for the Central Bank’s e-platform.
  3. Banking. Your safeguarding account with a credit institution and your operating accounts, opened alongside the application.
  4. Regulator engagement. We answer every Central Bank request by its deadline, so the application stays active through to the decision within three months of a complete application.

Your team, banking and technology

You will need a board with enough independent directors, and senior managers in the key roles, each assessed by the Central Bank under its 2025 suitability rules.

Key peopleWe assemble your team: independent directors and senior managers.
BankingSafeguarding, operating and settlement accounts, card acquiring and payment processing, opened alongside the application.
TechnologyWhite-label technology for accounts, payments, wallets and card programmes, ready to go live with the licence.

One programme, from scoping to launch. Speak to an expert about this licence.

The licence in detail

Requirements, capital, timing, fees and common questions, drawn from the regulator’s own publications.

Key takeaways
  • A Cyprus EMI issues e-money and provides every payment service across the EU and EEA on one authorisation under the Electronic Money Laws of 2012 and 2018.
  • Initial capital is €350,000 and own funds may never fall below it; ongoing own funds add the e-money and payment services calculations under the Central Bank’s directive.
  • From 3 August 2026 every application starts with a mandatory pre-application stage: a €5,000 fee and a preliminary assessment within 30 working days, or 50 where an enhanced due diligence report is commissioned.
  • The application fee is €10,000; the Central Bank publishes no annual supervisory fee.
  • The statutory period is three months from a complete application; we plan for six to eight months after submission.
  • The company must be incorporated in Cyprus with its registered and head office there and part of the business carried out in Cyprus; every board member and key function holder is assessed under the 2025 suitability directive.

Who needs the licence

A business issuing stored value to customers in Cyprus or, through passporting, anywhere in the EU and EEA needs authorisation from the Central Bank of Cyprus. Cyprus is a common-law, English-speaking EU jurisdiction with an established payments and investment firm sector, and since August 2026 its licensing process begins with a preliminary assessment of the owners and the project before the formal application. An EMI may provide every payment service in the Payment Services Law under the same authorisation.

What the Central Bank of Cyprus requires

  • Legal form and location. A legal person incorporated in Cyprus with its registered office and head office in Cyprus, carrying out at least part of its e-money or payment business in Cyprus.
  • Pre-application stage. From 3 August 2026 every applicant first pays a non-refundable €5,000 fee and submits a Pre-Application Document to the Licensing Section. The Central Bank of Cyprus completes its preliminary assessment within 30 working days, or 50 working days where it commissions an enhanced due diligence report on the beneficial owners at the applicant’s cost, and then meets the beneficial owners. Completion of the stage is not an approval.
  • Governance and suitability. Each proposed member of the management body and each key function holder completes the Central Bank’s personal questionnaire (October 2024 version) and a time commitment table, and is assessed under the 2025 suitability directive; major shareholders (10% or more) complete the legal person or natural person questionnaire. The Central Bank looks for an adequate number of independent board members and for internal organisation under its 2026 governance directive.
  • Safeguarding. Funds received for e-money and for payment transactions are kept separate and placed in a separate account with a credit institution or in secure, liquid, low-risk assets under the Central Bank’s 2026 directive, or covered by an insurance policy or comparable guarantee from an unaffiliated insurer or credit institution; safeguarded funds rank ahead of other creditors.
  • Application pack. The application form (May 2024 version), the €10,000 fee receipt, the questionnaires and the documents listed in the EBA guidelines on authorisation (EBA/GL/2017/09), which the Central Bank has adopted in full: programme of operations, business plan with three-year projections, group structure, governance, risk policies written for the business, outsourcing, security, anti-money laundering and the own funds calculation, submitted through the Central Bank’s e-platform. An applicant that misses a Central Bank deadline receives notice that the application will be classified as withdrawn.
  • Capital. Initial capital of €350,000 at authorisation; own funds thereafter at least the sum of the e-money calculation on e-money in circulation and the payment services calculation for unrelated payment services, under the method the Central Bank sets by directive, and never below €350,000.

Capital

RequirementAmount
Initial capital€350,000
Ongoing own fundsE-money calculation plus payment services calculation; never below €350,000
E-money elementSet by Central Bank directive; the EU floor is 2% of average outstanding e-money
Unrelated payment servicesMethod A, B or C as the Central Bank directs

The Electronic Money Laws permit a directive for issuers below an average outstanding limit, but the Central Bank publishes no small EMI regime; every issuer holds the full authorisation.

Timing

FigureValueSource
Statutory decision period3 months from a complete applicationPayment Services Law, section 12, applied to EMIs by section 4A of the Electronic Money Laws
Regulator’s published figurePreliminary assessment within 30 working days of the Pre-Application Document, or 50 working days with an enhanced due diligence report, about 1.5 to 2.5 months, before the formal applicationCentral Bank of Cyprus, pre-application exploratory stage
Application preparation6 to 8 weeksFrom instruction to submission, including banking in parallel
Our realistic timeline6 to 8 months after submissionOur own figure, from the regulator’s published data and our applications

Regulator figures are quoted as published and converted to months. Our realistic timeline assumes a complete, well-prepared application.

Fees and costs

ItemAmountNotes
Pre-application fee€5,000Non-refundable; paid before the Pre-Application Document is submitted
Application fee€10,000Receipt attached to the application
Enhanced due diligence reportAt costWhere the Central Bank commissions a third-party report on the beneficial owners
Annual supervisory feeNot publishedThe law allows the Central Bank to charge its supervision expenses; no amount is published
Initial capital€350,000Held before authorisation
Professional feesFixedQuoted after scoping

Passporting and scope

A Cyprus EMI passports throughout the EU and EEA under the right of establishment and the freedom to provide services, by branch, agent or distributor, with notifications under Delegated Regulation (EU) 2017/2055. The Central Bank publishes a register of authorised EMIs with their branches, agents, distributors and passported states.

Why applications are delayed

The Central Bank of Cyprus publishes the errors it sees most often in applications, and in 2026 introduced the pre-application stage to settle questions of good repute before the formal file is submitted.

  1. Incomplete information on the people. Unanswered questionnaire items, the wrong questionnaire, incomplete management body information, an inadequate number of independent board members and insufficient evidence of the source of the investment funds.
  2. Generic documents. Risk policies taken from templates, a thin programme of operations and business plan, thin outsourcing detail, and information that conflicts between documents.
  3. Financials. Unsupported or optimistic projections and a missing own funds calculation. The Central Bank may not take financial need into account; suitability of the board and management is a mandatory ground of decision.

Your bank accounts

An EMI needs a safeguarding account, an operating account and settlement accounts in the currencies it serves. We open each alongside the application, so you trade from authorisation. See banking and payment processing.

Common questions

How long does a Cyprus EMI licence take?

Three months from a complete application by statute, after the pre-application stage of 30 or 50 working days. We plan for six to eight months after submission.

What is the pre-application stage?

A mandatory first step since 3 August 2026: a €5,000 fee, a Pre-Application Document, a preliminary assessment by the Central Bank within 30 working days (50 with an enhanced due diligence report) and a meeting with the beneficial owners. It settles questions of good repute before the formal application.

What does a Cyprus EMI licence cost?

€5,000 at pre-application and €10,000 on application, plus the cost of any due diligence report the Central Bank commissions. The Central Bank publishes no annual supervisory fee.

Is there a small EMI regime in Cyprus?

No. The law permits one by directive but the Central Bank publishes none; every issuer holds the full authorisation.

Who must be in Cyprus?

The company is incorporated in Cyprus with its registered and head office there and carries out at least part of its business in Cyprus. Every board member and key function holder is assessed for suitability, and the Central Bank looks for an adequate number of independent directors.

References

  1. Central Bank of Cyprus: EMI application submission and assessment
  2. Electronic Money Laws of 2012 and 2018, consolidated English text
  3. Central Bank of Cyprus: common errors observed in EMI applications
  4. Central Bank of Cyprus: pre-application exploratory stage
  5. Central Bank of Cyprus: new licensing process, announcement of 31 July 2026
  6. Payment Services Laws of 2018 to 2023, Central Bank of Cyprus unofficial English consolidation, before the 2025 amendments
  7. Law 100(I) of 2025 amending the Payment Services Laws, Greek text

About Buckingham Capital Consulting

A regulatory advisory firm to payment, e-money and cryptoasset companies since 2013, with more than 250 licences obtained in more than 60 countries. The firm builds licensed payment, e-money, crypto and stablecoin businesses: the licence, the team, the technology, the bank accounts and card issuing.

This guide is general information, not legal advice. Requirements and fees change, and the regulator’s own publications take precedence.

How we work.

  • Senior-ledThe same senior team handles your application from the first call to approval, including every question the regulator raises.
  • Same dayA reply within three business hours and a written proposal the same day: the licence, the requirements, the cost and the timing.
  • ConfidentialYour plans, your application and any listing stay private. Clients are named only with their agreement.
  • Live workspaceDocuments, regulator questions, messages and progress in a shared client workspace, visible to your team at every stage.

Why firms choose BCC.

  • OperatorsWe have run regulated payment businesses, held regulator-approved roles and licensed payment firms in more than 60 countries since 2013.
  • One teamOne in-house team runs the whole programme, from the application to the day you go live.
  • ArrangedBank and safeguarding accounts, card issuing and payment processing, arranged directly through our relationships with banks, card schemes, issuers and processors.

Apply for this licence.

The licence, your team, banking and technology, delivered as one programme.