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Licence guide

Malta electronic money institution licence.

Malta suits e-money issuers that serve the gaming sector or want a rulebook that sets out governance in full, with one licence covering e-money and every payment service across the EU.

Published 16 October 2026 · Last reviewed 17 October 2026
MFSARegulator
€350,000Initial capital
€15,000Application 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: two directors in Malta, a chair and an MLRO.

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 permissions, the fee category and the own funds position in a written proposal, and prepare and send the presentation for the MFSA’s preliminary meeting ten working days ahead.
  2. Application pack. The application form with the information in the rulebook’s annex, the personal and corporate questionnaires for the board, the compliance officer and the MLRO, and the three lines of defence, submitted through the MFSA’s LH Portal.
  3. Banking. The engagement letter with a credit institution for the dedicated safeguarding account, which the MFSA requires before commencement, and the operating accounts, opened alongside the application.
  4. Regulator engagement. We answer the MFSA’s feedback at each stage, where it replies within 20 working days, through the in-principle approval letter, the pre-licensing conditions met within six months and the pre-commencement conditions, until the licence is issued.

Your team, banking and technology

You will need two directors based in Malta, a Malta-resident board member, an independent non-executive chair, a compliance officer and an MLRO.

Key peopleWe assemble your team: two directors in Malta, a chair and an MLRO.
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 Maltese EMI issues e-money and provides payment services across the EU and EEA on one licence under the Financial Institutions Act.
  • Initial capital is €350,000; own funds are the higher of that and 2% of average daily outstanding e-money.
  • The application fee is €15,000 where both e-money issuance and payment services are applied for; the fixed annual supervisory fee is €35,000 plus a variable element capped at €250,000.
  • The MFSA must decide within three months of receipt; silence is a deemed refusal.
  • A board of at least three with an independent chair and a Malta-resident member, effective direction by two individuals in Malta, and a compliance officer and MLRO at all times.
  • Malta also licenses gaming operators, which makes it a natural base for payment firms serving that sector.

Who needs the licence

A business issuing stored value to customers in Malta or, through passporting, across the EU and EEA needs an MFSA licence. Malta’s rulebook sets out governance in unusual detail, and its gaming and payments sectors are closely linked. An EMI may provide every payment service under the same licence.

What the MFSA requires

  • Legal form and location. A company with its head office and registered office in Malta, effectively directed from Malta by at least two individuals, carrying on at least part of its business in Malta with key function holders and control functions located there.
  • Governance. A board of at least three, including an independent non-executive director as chair and a Malta-resident member, meeting at least quarterly; a compliance officer independent of operations and an MLRO appointed at all times; fit and proper assessment of qualifying shareholders, the board, senior managers, the compliance officer and the MLRO; three lines of defence.
  • Safeguarding. Segregation in a separate account with a credit institution or central bank, or secure low-risk assets, by the end of the business day following receipt, or an insurance policy or guarantee from outside the group; an engagement letter with a credit institution for a dedicated safeguarding account before commencement.
  • Application pack. The application form with the information in the rulebook’s annex, a preliminary meeting with a presentation sent ten working days ahead, then the in-principle approval letter, pre-licensing conditions to be met within six months, and pre-commencement conditions; submissions through the MFSA’s licence holder portal with personal and corporate questionnaires.
  • Capital. Initial capital of €350,000 and own funds thereafter equal to the higher of that amount and 2% of average daily outstanding e-money, plus Method A, B or C capital for payment services not linked to e-money.

Capital

RequirementAmount
Initial capital€350,000
Ongoing own fundsHigher of €350,000 and 2% of average daily outstanding e-money
Unrelated payment servicesMethod A, B or C as the MFSA determines

The current rulebook contains no small EMI waiver; every e-money issuer holds the full licence.

Timing

FigureValueSource
Statutory decision period3 months from receipt; silence is a deemed refusalFinancial Institutions Act, Cap. 376
Regulator’s published figureReplies to applicant feedback within 20 working days, about 1 month, at each stageMFSA authorisation process service charter
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
Application fee€15,000E-money issuance and payment services; €10,000 for one category of activity
Annual supervisory fee€35,000 fixed plus variableVariable element: the higher of 0.02% of total assets, 0.0003% of payment transactions or 0.01% of average daily outstanding e-money, capped at €250,000
Initial capital€350,000Held before authorisation
Professional feesFixedQuoted after scoping

Passporting and scope

A Maltese EMI passports throughout the EU and EEA by branch, agent or distributor, or cross-border services, under the European passport rights regulations.

Why applications are delayed

The MFSA publishes stage-level service targets rather than a list of causes of delay. In our experience the three causes are the same as in every EU regime: incomplete submissions, insufficient substance in Malta, and business plans whose assumptions and flows of funds are not clear.

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 an MFSA EMI licence take?

Three months from receipt by statute, with silence treated as refusal. Counting the in-principle approval and conditions stages, we plan for six to eight months after submission.

What board does the MFSA require?

At least three directors, including an independent non-executive director as chair and a Malta-resident member, meeting at least quarterly, with two individuals effectively directing the business from Malta.

What are the Maltese fees?

€15,000 on application for e-money and payment services, and a fixed annual fee of €35,000 plus a variable element capped at €250,000.

Is there a small EMI regime in Malta?

Not in the current rulebook. Every e-money issuer holds the full licence.

Can a Maltese EMI serve gaming operators?

Yes. Malta licenses gaming operators under the Malta Gaming Authority and many payment firms serving the sector are authorised there; we obtain both licences.

References

  1. Financial Institutions Act, Chapter 376 of the Laws of Malta
  2. MFSA Financial Institutions Rulebook, Chapter 1 (authorisation)
  3. MFSA Financial Institutions Rulebook, Chapter 3 (ongoing requirements)
  4. Financial Institutions (Fees) Regulations, S.L. 376.03
  5. Financial Institutions (Safeguarding) Regulations, S.L. 376.04
  6. European Passport Rights for Financial Institutions Regulations, S.L. 376.07

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.