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Home › Licensing › Luxembourg › Luxembourg EMI licence

Licence guide

Luxembourg electronic money institution licence.

Large payment and e-money groups run their EU operations from Luxembourg, where the regulator, the banks and the professional infrastructure are built for institutional applicants.

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Published 16 October 2026 · Last reviewed 17 October 2026

CSSFRegulator

€350,000Initial capital

€30,000Examination 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

Volkswagen Macmillan Cancer Support

Payment Institution

Obtained Nexpay’s FCA Authorised Payment Institution licence.

Electronic 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: directors based in Luxembourg.

Same dayWritten proposal

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

How we get you licensed and live

Scoping and proposal. We confirm the permissions, the own funds under Method D and the methods for payment services in a written proposal, and prepare the business plan and the fund and data flow diagrams for the initial CSSF meeting.
Application pack. The CSSF application form, the declarations of honour, the internal control, AML, ICT and security policy with its risk assessment, and the qualifying shareholder files, submitted through the CSSF’s secure file transfer.
Banking. The segregated safeguarding account with a credit institution and the operating accounts, opened alongside the application, so customer funds are protected from creditors from the first day.
Regulator engagement. The CSSF examines the file by correspondence and meetings; each round is answered with the evidence assembled and the flows of funds mapped clearly, until the decision and entry in the CSSF and European registers.

Your team, banking and technology

You will need directors with senior experience in similar businesses who run the company from Luxembourg, plus supervisory board members.

Key peopleWe assemble your team: directors based in Luxembourg.

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 Luxembourg EMI issues e-money and provides payment services across the EU and EEA on one CSSF authorisation.
Initial capital is €350,000; own funds are at least 2% of average outstanding e-money, with Methods A, B or C for payment services.
The CSSF charges a €30,000 lump sum to examine the application and an annual fee of €30,000, rising to €40,000 above €1 billion of combined volume and reduced to €25,000 for the first three years.
The CSSF decides within three months of the application or of missing information, and within twelve months in any case.
Central administration and registered office in Luxembourg.
Luxembourg is the EU base of several of the largest payment groups and its regulator is accustomed to institutional-scale applications.

Who needs the licence

A business issuing stored value in Luxembourg or, through passporting, across the EU and EEA needs CSSF authorisation. Luxembourg hosts the EU operations of several of the largest payment and e-money groups, and its regulator, its banks and its professional infrastructure are built for institutional applicants. An EMI may provide every payment service under the same authorisation.

What the CSSF requires

Legal form and location. A company with its central administration and registered office in Luxembourg, providing at least part of its business there.
Governance. Members of the administrative, management and supervisory bodies evidence professional standing; those responsible for management are competent to direct the business with adequate experience at a high level in similar activities; qualifying shareholders identified and assessed; a statutory auditor; internal control, anti-money laundering controls, ICT and a security policy with risk assessment in the file.
Safeguarding. No commingling; funds still held at the end of the next business day placed in a separate account with a credit institution or central bank, or invested in secure low-risk assets, insulated from creditors; or an insurance policy or comparable guarantee from outside the group.
Application pack. An initial meeting at the CSSF with the business plan and fund and data flow diagrams, then the CSSF application form and declarations of honour submitted through its secure file transfer; examination by correspondence and meetings; publication in the CSSF and European registers.
Capital. Initial capital of €350,000 and own funds thereafter under Method D (2% of average outstanding e-money) for e-money and Methods A, B or C for payment services as the CSSF determines.

Capital

Requirement	Amount
Initial capital	€350,000
Ongoing own funds (Method D)	At least 2% of average outstanding e-money
Payment services	Method A, B or C as determined

The law contains no small e-money regime; every issuer holds the full authorisation.

Timing

Figure	Value	Source
Statutory decision period	3 months from the application or from missing information; 12 months at most	Law of 10 November 2009
Application preparation	6 to 8 weeks	From instruction to submission, including banking in parallel
Our realistic timeline	6 to 8 months after submission	Our 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

Item	Amount	Notes
Examination fee	€30,000	Single lump sum for a new authorisation; €6,000 to extend to additional payment services
Annual fee	€30,000	€40,000 where combined payment and e-money volume exceeds €1 billion; €25,000 for institutions authorised three years or less below that volume
Initial capital	€350,000	Held before authorisation
Professional fees	Fixed	Quoted after scoping

Passporting and scope

A Luxembourg EMI passports throughout the EU and EEA by branch, agent or distributor, or cross-border services, on notification to the CSSF.

Why applications are delayed

The CSSF publishes no list of causes of delay. In our experience the causes are the same as in every EU regime: incomplete files, insufficient substance in Luxembourg, and flows of funds that are not clearly mapped.

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 CSSF EMI authorisation take?

Three months from the application or from the missing information, and twelve months at most, after which silence is a deemed refusal. We plan for six to eight months after submission.

What are the CSSF fees?

A €30,000 examination fee on application and an annual fee of €30,000, €40,000 above €1 billion of volume, reduced to €25,000 for the first three years.

Who must be in Luxembourg?

The central administration and registered office, with the people responsible for management competent to direct the business from there.

Is there a small EMI regime?

No. Every issuer holds the full authorisation.

Why do large groups choose Luxembourg?

A regulator and banking sector accustomed to institutional scale, a stable legal environment, and a position at the centre of the EU.

References

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.

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