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Financial Services Regulation, Financial Technology

FinTech Licenses EU: Types, Rules & Use Cases (2026)

April 1, 2026 Neil Mathieson Comments Off on FinTech Licenses EU: Types, Rules & Use Cases (2026)
FinTech Licenses EU

Providers of eMoney, payment, banking, account information, and crypto asset services in the EU must be licensed to ensure firms operate in a legal and sustainable manner that safeguards clients and wider financial markets.

Multiple license types exist; businesses must ascertain which is appropriate for their business model and jursidiction.

Barriers to entry are manageable for those that plan and resource appropriately, however regulatory requirements are increasing and the authorisation process intensive. In most cases, regulators will test capability in advance, making applying for a license a front-loaded process.

Ongoing compliance obligations exist; authorised entities must meet these, adjacent legislation like DORA, and adapt to regular changes.

FinTech Licenses EU Types

Payments, eMoney and Data

– Payment Institution (API)

– Small Payment Institution (SPI)

– Electronic Money Institution (AEMI)

– Small Electronic Money Institution (SEMI)

– Account Information Service Provider (AISP)

– Payment Initiation Service Provider (PISP)

Specialised Banking

– Specialised Banking License

Digtal Assets

– Crypto Asset Service Provider (CASP)

Authorised Payment Institution (API)

A Payment Institution license authorises an entity to provide regulated payment services within the EU.

Under EU Payment Services regulations, a payment service is defined as:

  1. Services enabling cash to be placed on a payment account as well as all the operations required for operating a payment account.
  2. Services enabling cash withdrawals from a payment account as well as all the operations required for operating a payment account.
  3. Execution of payment transactions, including transfers of funds on a payment account with the user’s payment service provider or with another payment service provider:
    • execution of direct debits, including one-off direct debits;
    • execution of payment transactions through a payment card or a similar device;
    • execution of credit transfers, including standing orders.
  4. Execution of payment transactions where the funds are covered by a credit line for a payment service user:
    • execution of direct debits, including one-off direct debits;
    • execution of payment transactions through a payment card or a similar device;
    • execution of credit transfers, including standing orders.
  5. Issuing payment instruments and/or acquiring payment transactions.
  6. Money remittance.
  7. Payment initiation services (see Payment Information Service Provider).
  8. Account information services (see Account Information Service Provider).

An authorised Payment Institutions (often called payment service providers or PSPs) can offer a wide range of payment services:

  1. Money transfer: remitting money from one country to another.
  2. Foreign exchange: converting currencies and hedging forward positions.
  3. Card schemes: providing debit and credit cards.
  4. Payment processing: providing online and mobile payment solutions.
  5. Payment acquiring: accepting payments from merchants, marketplaces and payment gateways.
  6. Payment gateway operations: specialist technology solution to accept and process payments.
  7. Open Banking: providing data and payment initiation on 3rd party bank accounts.

Deferred payment models such as Buy Now Pay Later (BNPL) are moved into credit regulation such as the Consumer Credit Directive (CCD2),

See more

Authorised Electronic Money Institution (AEMI)

An Electronic Money Institution license authorises an entity to issue, redeem and store eMoney, and to provide payment services as permitted by Payment Institutions.

Under EU Electronic Money Regulations, an eMoney service is defined as:

  1. Issuance of Electronic Money: issuing digital representations of fiat currency that can be used for payments.
  2. Redemption of Electronic Money: allowing customers to redeem eMoney back into fiat currency at par value.
  3. Storage of Electronic Money: holding funds as e-money in digital wallets or similar accounts for future transactions.

…plus all services permitted as a Payment Institution.

An authorised Electronic Money Institutions can offer a wide range of financial services:

  1. IBAN Issuance: client named accounts in multiple currencies.
  2. Neobanking: bundled offer of accounts, payments, FX and cards, often augmented with software for easy management.
  3. Banking-as-a-Service: allowing 3rd parties to offer account and payment services on your infrastructure in return for a revenue share.
  4. Prepaid Cards: cards that are loaded with a specific amount of money and can be used for purchases later.
  5. Online Payment Platforms: websites and apps that orchestrate online transactions and may hold a balance for users.
  6. Digital Wallets: platforms like PayPal and Revolut that store eMoney to facilitate online payments or money transfers.
  7. Bank-Linked Digital Wallets: wallets like Google Pay and Apple Pay, where eMoney is linked to bank accounts.
  8. Mobile Money Services: allow users to store, send, and receive money using their mobile phones, like M-Pesa and GCash.
  9. Stored-Value Cards: cards like Oyster which are preloaded with money and used for transportation or other services.
  10. Voucher Schemes: users purchase vouchers online or at kiosks then use them to redeem for online purchases, like PaySafeCard (ex Skrill).

…plus all services permitted as a Payment Institution:

See more

Small Electronic Money Institution (SEMI)

A Small Electronic Money Institution license authorises an entity to issue, redeem and store eMoney, subject to certain volume restrictions. Small EMIs are not permitted to trade across borders.

Under EU Electronic Money Regulations, an eMoney service is defined as:

  1. Issuance of Electronic Money: issuing digital representations of fiat currency that can be used for payments.
  2. Redemption of Electronic Money: allowing customers to redeem eMoney back into fiat currency at par value.
  3. Storage of Electronic Money: holding funds as e-money in digital wallets or similar accounts for future transactions.

…plus most services permitted as a Payment Institution.

Authorised Electronic Money Institutions can offer a wide range of financial services:

  1. IBAN Issuance: client named accounts in multiple currencies.
  2. Neobanking: bundled offer of accounts, payments, FX and cards, often augmented with software for easy management.
  3. Banking-as-a-Service: allowing 3rd parties to offer account and payment services on your infrastructure in return for a revenue share.
  4. Prepaid Cards: cards that are loaded with a specific amount of money and can be used for purchases later.
  5. Online Payment Platforms: websites and apps that orchestrate online transactions and may hold a balance for users.
  6. Digital Wallets: platforms like PayPal and Revolut that store eMoney to facilitate online payments or money transfers.
  7. Bank-Linked Digital Wallets: wallets like Google Pay and Apple Pay, where eMoney is linked to bank accounts.
  8. Mobile Money Services: allow users to store, send, and receive money using their mobile phones, like M-Pesa and GCash.
  9. Stored-Value Cards: cards like Oyster which are preloaded with money and used for transportation or other services.
  10. Voucher Schemes: users purchase vouchers online or at kiosks then use them to redeem for online purchases, like PaySafeCard (ex Skrill).

…plus most services permitted as a Payment Institution:

See more

Account Information Service Provider (AISP)

An AISP license authorises an entity to access account balance and transaction data held at third-party banks and e-money institutions, with the account holder’s consent, under Open Banking rules.

Provision of consolidated account information services across one or more payment accounts held with other providers.

Credit scoring and affordability checks

AML/CTF verification and identity checks

Treasury and cash-flow management dashboards

Open Banking data aggregation apps

Payment Initiation Service Provider (PISP)

A PISP license authorises an entity to initiate payments directly from a customer’s account held at a third-party bank or e-money institution, without holding the funds itself.

Initiation of payment transactions on behalf of the payment service user, at the user’s request, from an account held with another provider.

Direct bank-to-bank checkout (bypassing card networks)

Treasury and payment automation

Embedded payments for e-commerce and marketplaces

Crypto Asset Service Provider (CASP)

A CASP license, introduced under MiCA (Markets in Crypto-Assets Regulation), authorises an entity to provide regulated services relating to crypto-assets across the EU.

Custody and administration of crypto-assets

Operating a trading platform for crypto-assets

Exchanging crypto assets for fiat currency or other crypto assets

Execution of purchase, placement, accepting or transmitting orders

Portfolio management of crypto-assets

Asset transfer services

Crypto asset advisory services

Cryptocurrency

Stablecoin issuance and distribution

NFTs

Other tokens and tokenisation services.

FinTech Licenses EU: Summary

The opportunities provided by fintech licenses are huge: issuing accounts, processing payments, holding client funds, and accessing valuable data. Financial and retail businesses can embrace this to improve their value proposition, client service, and profitability.

Barriers to entry are moderate however up-front and ongoing investment are required, it is therefore essential to validate which license is required and how the business will achieve sustainability.

Business environments, taxation, and regulatory approaches vary between EU regulators, validate these in advance.

Sure FinTech supports clients end‑to‑end — regulatory strategy, license applications, technology and BaaS sourcing, and ongoing compliance. Contact us today for an exploratory call about FinTech Licenses EU.

  • Crypto Assets
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Neil Mathieson

Neil has 20yrs in experience in global FinTech advisory and 10yrs in Corporate Banking, gaining deep technical knowledge of corporate finance, financial markets, and software development. He has advised banks, lenders, fintechs, PSPs, corporates, private equity and governments across strategy, regulation, technology and operational challenges. Systems experience includes treasury, risk, core banking, credit scoring, client engagement, payment gateways, trading, and blockchain.

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