Electronic Money Institutions Licensing | FAQ

What is an Electronic Money Institution?

According to the EU Directive 2009/110/EC and the Cyprus Electronic Money Law (2012):

  • “Electronic money institution” is defined as a “legal person that has been granted authorisation to issue e-money“.
  • “Electronic money” is defined as “electronically, including magnetically, stored monetary value as represented by a claim on the issuer which is issued on receipt of funds for the purpose of making payment transactions […], and which is accepted by a natural or legal person other than the electronic money issuer”.

What activities can be carried out by an Electronic Money Institution?

An electronic money institution can among others:

  • maintain a readily available electronic device or instrument for the purpose of electronic money storing, distribution, circulation;
  • receive monetary value in exchange for the distribution of electronic money;
  • distribute and place e-money in circulation;
  • sell or resell e-money products;
  • redeem e-money etc.

What requirements (regarding the personnel) should be satisfied for a successful application?

The legal entity, which must be incorporated and maintain its head offices in Cyprus, should have:

  • four (4) directors minimum (2 executive and 2 non-executive), who in their majority should be Cyprus residents. Please note that they should be fit and proper and approved by the Central Bank of Cyprus;
  • anti money laundering and compliance manager;
  • risk manager;
  • accountants;
  • internal auditors;
  • external auditors;
  • external legal consultants. 

There are specific provisions regarding the outsourcing of some of the operations. For further details, please get in touch with our regulatory consultants.

What documents have to be submitted to the Central Bank of Cyprus?

The following documents must be prepared and submitted inter alia with the application:

  • business plan;
  • three (3) year financial forecast;
  • operations manual;
  • AML, risk management and compliance manual;
  • questionnaire for each shareholder and director;
  • clear criminal record for each shareholder and officer;
  • non-bankruptcy certificate for each shareholder and officer.

What is the minimum initial capital requirement?

EUR 350,000 (at least).

Please note that the above information is provided for general purposes only. If you require legal advice on EMI licensing, you can get in touch with our Regulatory Advisory Team.

Click here to find out more about the latest EMI licence we have obtained on behalf of our clients.