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

An electronic money institution (EMI) may issue e-money and hold customer balances, which puts it in a regulated category of its own when it applies for card acquiring. The question is no longer whether the business is legitimate, but how customer money is safeguarded, which markets the licence covers and how financial crime is controlled.

Last reviewed October 2026

What an EMI licence allows

  • Issuing electronic money and holding customer balances, such as wallets and prepaid cards.
  • Providing the payment services linked to those balances.
  • Redeeming e-money at par value whenever the customer asks.
  • Operating across the EEA through passporting, if the licence is from an EEA regulator.

EMI or payment institution?

A payment institution can execute payments but cannot issue e-money or keep stored balances for customers. If your product gives customers a balance, a wallet or a card they top up, that is normally EMI territory. The difference also shows in capital: an EMI needs at least €350,000 of initial capital in the EU, while a payment institution needs between €20,000 and €125,000 depending on its services.

The EU has agreed to fold e-money institutions into the payment institution category under its new payment rules. The change is agreed but not yet in force, so today's EMI licences and rules still apply.

Safeguarding is what acquirers look at first

Customer money must be safeguarded: either kept strictly separate from the firm's own funds, or covered by an insurance policy or a comparable guarantee. In the EU, money received for e-money must be safeguarded no later than five business days after it is issued, and EMIs may not pay customers interest on their balances.

In the UK, the FCA's new safeguarding rules for payment and e-money firms have applied since 7 May 2026. They require daily reconciliation, a monthly safeguarding return to the FCA, a resolution pack so customer money can be returned quickly if the firm fails, and an annual safeguarding audit for most firms. UK EMIs also lost their EEA passport after Brexit and need separate authorisation to serve EEA customers.

What acquirers check before boarding an EMI

  • The exact scope of the licence and its entry on the regulator's public register.
  • Safeguarding: method, accounts and recent reconciliations or audit results.
  • A flow-of-funds diagram showing who holds the money at each step.
  • Which markets the licence covers, through passporting or local authorisation.
  • The AML and sanctions framework and the responsible officer.
  • Customer base, expected card volume and how card payments load balances.

A licence is not a shortcut

Holding a licence shows that you are supervised, but acquirers still assess your customer base, geography and dispute exposure. Card payments that load a wallet or prepaid balance can also attract fraud, so expect questions about limits and verification before a balance can be used.

How Acquipayer helps

Acquipayer is not a payment provider. We match licensed EMIs with acquirers that board regulated financial institutions, through one online application.

  • Add your licence, markets, flow of funds and volumes once.
  • We match you with an acquirer that accepts licensed EMIs in your markets.
  • Your account is prepared with the acquirer so you can start accepting cards.

Check your own situation

Whether a provider boards you depends on your licence, markets, volume and history. Answer four questions to see which payment routes may fit your business.

Four questions about your business

Industry, company country, customer markets and estimated monthly volume, that is all we need to begin.

Check which payment routes may fit your business

Answer a short set of questions about your business and we will check your profile against the requirements providers have given us. No approval is decided here.

Check my payment options

Nothing is shared with a provider until you submit your onboarding pack. Approval is always the provider's decision.