EMI Licence: What It Permits and How It Affects Card Acceptance

An electronic money institution is authorised to issue e-money and hold client funds, which places it in a regulated category of its own during payment underwriting: the questions shift from whether the business is legitimate to how client money, safeguarding and financial-crime controls are run.

Last reviewed September 2026

What the authorisation covers

  • Issuing electronic money and holding customer balances.
  • Providing payment services associated with those balances.
  • Safeguarding client funds separately from the firm's own money.
  • Operating under the financial-crime obligations of the issuing regulator.

EMI compared with a payment institution

A payment institution can execute payments but cannot issue e-money or hold stored balances in the same way. If your product gives customers a balance, a wallet or a card they load, that is normally EMI territory. The distinction matters for acceptance because it changes who holds customer funds.

What underwriting focuses on for a licensed firm

  • The exact scope of the licence and the regulator's public register entry.
  • Safeguarding arrangements and where client funds sit.
  • AML and sanctions framework, plus the responsible officer.
  • Whether services are passported, and into which markets.
  • The flow of funds diagram: who holds money at each step.

Why licensed firms are still assessed carefully

Holding a licence is evidence of supervision, not a shortcut through underwriting. Providers still assess the customer base, geography and dispute exposure, and no licence guarantees acceptance by any particular acquirer.

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