A Malta EMI license is an authorization issued by the Malta Financial Services Authority under the Financial Institutions Act (Cap. 376) that allows the holder to issue electronic money, operate payment accounts and provide payment services across the European Economic Area. The minimum paid-up capital is EUR 350,000, the MFSA application fee starts at EUR 10,000, and the fixed component of the annual supervisory fee starts at EUR 25,000. These figures cover only the regulatory minimums. The full launch budget also includes Malta-based substance, staffing, application preparation and audit. EEA passporting does not guarantee that banks in other member states will open accounts for a newly licensed EMI. The payment and fintech licensing hub compares Malta with other EU and non-EU jurisdictions.
What a Malta EMI License Covers
An EMI authorized by MFSA can issue and redeem electronic money, open payment accounts with IBANs, execute credit transfers and direct debits, issue payment cards, provide merchant acquiring, offer money remittance services, and operate as a payment initiation service provider or account information service provider. The license also covers the operation of payment systems and closely related ancillary services.
An EMI may extend short-term credit only where the credit is linked to a payment transaction and is not funded from client balances held as electronic money. Taking deposits and general-purpose lending are not permitted. An EMI is not a bank.
EMI or Payment Institution: Which License Do You Need
The deciding factor is whether the product holds client balances and issues electronic money. If the business model involves wallets, stored-value accounts, IBAN accounts where the funds represent e-money, or prepaid instruments, an EMI authorization is required. If the product only moves funds between third parties without issuing e-money, a payment institution license is sufficient.
The capital difference reflects the distinction: EUR 350,000 for an EMI versus EUR 125,000 for a payment institution.The payment institution figure is the top tier: initial capital is EUR 20,000 for money remittance only and EUR 50,000 for payment initiation services, rising to EUR 125,000 for the full range of payment services. Both license types are issued by MFSA under the same Financial Institutions Act, and both carry EEA passporting rights. The Malta Payment Institution License guide covers the PI route in detail.
Under the agreed PSD3 text, both categories would enter a unified payment institution framework, with e-money issuance retained as a licensed activity. The transition is addressed below.
| Feature | Malta EMI License | Malta Payment Institution License |
|---|---|---|
| Minimum capital | EUR 350,000 | EUR 125,000 |
| E-money issuance | Yes | No |
| Stored client balances | Yes, as electronic money | No stored e-money balances; funds may be held only for executing payment transactions |
| Payment accounts and IBANs | Yes | Yes, without issuing e-money |
| Typical products | Digital wallets, stored-value accounts, prepaid cards, e-money accounts, payment cards | Payment processing, money transfers, merchant acquiring, remittance, payment initiation |
| Best suited for | Businesses that store customer funds and issue electronic money | Businesses that transfer or process funds without issuing electronic money |
| EEA passporting | Yes | Yes |
Malta EMI License Requirements
Capital. The minimum initial capital is EUR 350,000, fully paid up before the license is issued. The EMI must maintain own funds at or above this threshold on an ongoing basis. Depending on the scale of operations, MFSA may require own funds above the statutory minimum, calculated by reference to outstanding electronic money and payment transaction volumes.
People and substance. MFSA requires at least two executive directors who effectively direct the business from Malta. Directors, senior managers and qualifying shareholders holding 10% or more are subject to fit and proper assessments. The institution must appoint a Compliance Officer and a Money Laundering Reporting Officer. Mind and management must be located in Malta, with at least one resident director.
Safeguarding. Client funds received in exchange for electronic money must be segregated from the EMI's own funds. Safeguarding is achieved by depositing client funds in accounts held with credit institutions or by investing them in secure, liquid, low-risk assets. The EMI is liable for any shortfall in safeguarded funds.
Costs and Timeline
MFSA revised its fee schedule for financial institutions effective January 1, 2025. The current fees for an EMI depend on the scope of authorization:
The fee depends on whether the license covers Category 1 activities (payment services), Category 2 activities (issuance of electronic money), or both. The application fee is EUR 10,000 where the license covers one category and EUR 15,000 where it covers both. The annual supervisory fee consists of a fixed component of EUR 25,000 or EUR 35,000, depending on scope, plus a variable component calculated by reference to total assets, payment transaction value or average daily outstanding electronic money.
Beyond MFSA fees, the first-year operating budget for a Malta EMI includes substance and compliance costs. Based on Equilex estimates, annual service-provider costs are approximately EUR 117,000, covering a local director (EUR 15,000), risk officer (EUR 20,000), MLRO (EUR 15,000), compliance officer (EUR 15,000), corporate services including bookkeeping, tax compliance and regulatory reporting (EUR 5,000), external audit (EUR 8,000), internal audit (EUR 10,000), registered office and secretarial fees (EUR 4,000), and the minimum MFSA supervisory fee of EUR 25,000. The EUR 350,000 capital requirement must remain available as regulatory capital and cannot be treated as an operating budget. Incorporation, office lease, IT infrastructure and application preparation costs come on top.
The indicative timeline from submission of a complete application to license issuance is at least eight months. MFSA review rounds and requests for additional documents often extend the process beyond the statutory assessment period. Business plan preparation, financial modeling, policy drafting and fit and proper checks take place before filing, so the full project should generally be planned on a 12-month basis.
If you are structuring an EMI application or deciding between an EMI and a payment institution license, schedule a call with the Equilex licensing team to map the capital, substance and timeline for your model.
The MFSA Application Process
Pre-application. The applicant incorporates a Maltese limited liability company and may request an optional preliminary meeting with MFSA to discuss the business plan and intended scope of services.
Application dossier. The formal submission includes a business plan with three-year financial projections and stress testing, AML/CFT policies and procedures, a risk management framework, IT security and operational resilience documentation, and Personal Questionnaires for all directors, senior managers and qualifying shareholders. MFSA evaluates the completeness and quality of the dossier before proceeding to substantive review.
Review and decision. MFSA conducts an iterative review, raising queries and requesting amendments or additional information. If satisfied, the authority issues an in-principle approval subject to conditions, which typically include confirming that the share capital has been deposited and that key appointments are in place. The license is granted once all conditions are met. Passporting of services to other EEA states follows notification to the relevant host-state authorities. In practice, a six-to-twelve-month operating record may help support plans to establish branches abroad.
EMI and Stablecoins: The MiCA Angle
Under Article 48 of Regulation (EU) 2023/1114 (MiCA), e-money tokens may only be offered to the public or admitted to trading in the EU by credit institutions and authorized electronic money institutions. A Malta EMI license provides the required institutional status, subject to MiCA requirements concerning reserve assets, redemption rights and white paper disclosure.
Malta also supervises crypto-asset service providers under MiCA. An issuer established there can therefore manage its EMI supervision and related MiCA obligations within the same regulatory jurisdiction. The CASP Malta service page covers the crypto-asset licensing side.
What PSD3 Changes for Malta EMIs
The European Parliament and the Council reached a provisional political agreement on PSD3 and the Payment Services Regulation on November 27, 2025. The Council published compromise texts in April 2026, while formal adoption and publication in the Official Journal remain pending. The application timetable will depend on the final texts and their publication date.
Under the agreed PSD3 text, EMD2 would be repealed and electronic money institutions would be integrated into the payment institution framework. E-money issuance would become a licensed activity within the unified payment institution authorization. Existing EMI authorizations are expected to transition through grandfathering arrangements, although competent authorities may require additional information to assess compliance with the new framework.
Applicants in 2026 must still apply under the current EMD2 and Financial Institutions Act framework. For businesses ready to proceed, the existing authorization process remains available, while the detailed PSD3 application and national implementation rules have yet to be finalized. Licenses granted under the current regime are expected to enter the grandfathering process rather than expire when the new rules apply. The transition mechanics are covered in the Equilex analysis of PSD3 and what happens to EMI and payment institution licenses.
Ready-Made EMI as an Alternative
Acquiring an existing EMI with a clean compliance history can reduce the time to market compared with a fresh application. However, any change of qualifying shareholders requires prior MFSA approval, and incoming owners must pass the authority's fit and proper assessment.
Due diligence on the target should cover compliance history and supervisory findings, banking relationships, safeguarded client funds and passporting notifications. Dealable24 lists regulated companies available for acquisition.
The Best Countries to Get a Payment License in 2026 guide compares Malta with other EU and non-EU payment licensing routes.
FAQ
How much does an EMI license in Malta cost?
The minimum paid-up capital is EUR 350,000. The MFSA application fee is EUR 10,000 for one Category 2 activity or EUR 15,000 for both. The annual supervisory fee has a fixed component of EUR 25,000 or EUR 35,000, depending on scope, plus a variable component. Incorporation, Malta-based staff, office substance, audit and application preparation increase the first-year budget.
How long does MFSA EMI authorization take?
The indicative timeline is at least eight months from filing a complete application. MFSA review rounds and requests for additional documents may extend the process. Preparation of the business plan, financial model and compliance policies comes before filing, so the full project should generally be planned on a 12-month basis.
What is the difference between an EMI and a payment institution?
An EMI can issue electronic money and hold client balances in wallets and IBAN accounts, with EUR 350,000 minimum capital. A payment institution executes payments without issuing e-money, with EUR 125,000 capital. If the product stores customer funds as e-money, the EMI authorization is required.
Can a Malta EMI issue stablecoins?
Under MiCA Article 48, e-money tokens in the EU may only be offered to the public or admitted to trading by credit institutions and authorized EMIs. A Malta EMI license provides the required institutional status, subject to MiCA requirements concerning reserve assets, redemption rights and white paper disclosure.
Should I still apply for a Malta EMI before PSD3 takes effect?
Applications filed in 2026 remain subject to the current EMD2 framework. Under the agreed PSD3 text, EMIs would move into the payment institution framework, while existing authorizations would enter grandfathering arrangements rather than expire. The detailed transition and documentation requirements will depend on the final rules and their implementation in Malta.
