Electronic Money Institutions (“EMIs”) are entities which issue and manage electronic money, enabling digital financial transactions.
To qualify as an EMI, two essential elements must be present:
- Prepaid electronic money; and
- The ability to transfer electronic money freely to third parties.
Licensing Requirements for Malta-Based EMIs
EMIs established in Malta must meet the following criteria to obtain a licence from the Malta Financial Services Authority (MFSA):
- Initial share capital of €350,000 [1].
- Minimum of two (2) individuals to effectively manage the operations from Malta.
- Sustain sound and prudent management and robust governance arrangements.
Permitted Activities
Subject to MFSA approval, Malta-based EMIs may also undertake the following activities:
- Providing payment services.
- Giving credit related to certain payment services (subject to certain conditions).
- Operational services and related ancillary services related to the issuance of electronic money or payment services.
- Operating payment systems as defined in the second schedule of the Act.
- Conducting other business activities (according to the applicable law regulating such activities).
Advantages of a Malta EMI Licence
Malta has positioned itself as a leading jurisdiction for Electronic Money Institutions within the EU. Its strong regulatory framework, EU membership, and FinTech-friendly environment make it an ideal base for EMIs.
Key benefits include:
- Regulatory clarity and access to EU markets
- A robust FinTech ecosystem supporting innovation and growth
- Ease of accessibility for international investors
- High levels of security and operational efficiency
- EU passporting rights enabling cross-border services
How ARQ Can Help
Applying for an EMI licence with the MFSA can be complex. Our team provides end-to-end assistance to ensure a smooth process, including:
- Structuring, legal, and regulatory advice;
- Guidance through the entire licensing and incorporation process;
- Drafting and reviewing of required policies and procedures;
- Acting as your liaison with the MFSA; and
- Ongoing compliance and advisory support post-licensing.
We understand that your focus should remain on your business. Through our Compliance Services Offering, we ensure your operations remain fully aligned with MFSA expectations.
Our services include:
- Acting as your Compliance Officer;
- Drafting and implementing an Annual Compliance Programme;
- Introducing and monitoring policies and procedures;
- Maintaining complaints and breaches logs and liaising with the MFSA as required;
- Providing staff training on regulatory obligations; and
- Performing other duties ancillary or complementary to the above.
[1] The level of own funds may be higher than the €350,000. Own funds must not fall below this amount of initial share capital, or the amount of own funds as calculated in accordance with the governing rules.
