EMI licence checker: which payment licence does your business need?

What decides it is what your balance legally represents

Do not ask whether your customer can see a balance. Ask what that balance legally represents. A payment-account balance used only to execute payment transactions can sit inside a payment institution permission. Stored value the customer holds and later spends with third parties is e-money, and e-money is EMI territory. EMD2 draws that line in the European framework. PSD2 draws the payment-services line beside it.

The practical test is what happens to the money between arriving and leaving. If it rests, and your customer decides later where it goes, you are storing value. Passing straight through on an instruction you already received is a payment transaction instead. Digital wallets almost always land on the storing side.

There is a caveat on one of those rows. Moving money between third parties points to a payment institution in the United Kingdom and Germany only. In the other seven markets our dataset maps that shape to full authorisation.

IBAN provisioning sits on the e-money side of the line too. We cover how that works on our multi-currency IBAN page. Multi-currency IBAN accounts.

Licence requirement by market: 9 markets, 4 paths

Of the 9 markets whose rules we checked against the regulator or the statute, 6 publish a route to operate without holding the main licence yourself, counting only routes under the market's own regulator rather than operating under a principal. In 2 of them, the United States and Canada, the regulator says it outright: an agent of a registered money services business does not register at all. None of the 17 organic results ranking for "EMI licence" in the US and UK publishes these thresholds.

Each row applies only to the market named in it, as at the verified date on that row, per the regulator or statute cited on that row.

The United States is shaped differently from the rest of the table. There is no single federal licence. A money services business (MSB) registration is filed with the Department of the Treasury and renewed every two years. Money transmitter licences are issued separately by each state, and each state sets its own net-worth and surety-bond minimums. That two-layer shape is why money transmitter license carries several times the US search volume of emi license.

Both North American regulators publish the agent rule in plain words. FinCEN A person that is an MSB solely because that person serves as an agent of another MSB is not required to register. FinCEN, 31 CFR 1022.380 FINTRAC You are not a money services business ... if you offer one or more money services business services strictly as an agent or mandatary for a money services business. It is the money services business for which you are an agent or mandatary that has to register with FINTRAC. FINTRAC, PCMLTFA paragraphs 5(h) and 5(h.1)

Nigeria works the other way. Its agent route is itself a CBN authorisation category, Super-Agent, rather than a registration-free arrangement. Thresholds are not all euro-denominated either: the Philippines sets benchmark capital for its Electronic Money Issuer category at 100,000,000 PHP, in BSP Circular No. 942, Sec. 4511N.2, category C. That circular sets the figure for the E-Money Issuer category as authorised under Subsection X780.2 of the Manual of Regulations for Banks. So the category and its capital benchmark sit in two BSP instruments that cross-reference each other.

Three markets carry a cell we could not read at the source, and the reason prints on the row. Brazil: regulator page returns HTTP 200 with a JavaScript-only shell. Vietnam: regulator confirmed at portal root, instrument-level page not located. Australia carries two, the AUSTRAC obligation where the source times out, and the representative regime where the specific page was not resolved on the date checked. No figure is inferred and no threshold is carried over from a vendor page. That is why no Brazilian, Nigerian or Vietnamese capital figure appears above.

The four regulatory models in the last column come from the World Bank's taxonomy. The per-market assignment is ours, made from each market's own regulator pages. World Bank, e-money regulatory models. The four-model taxonomy is the World Bank's. The per-market assignment below is ours, made from each market's own regulator pages. The World Bank publishes the models and a role matrix, not a country-by-country classification, so do not attribute the assignment to it.

How we verify this

Every figure on this page comes from the named regulator or the statute for that market, linked on the row it appears in. Every cell in the dataset carries a source URL, a source reference and the date we read it. Six of the 9 markets are primary-verified on every core path. The dataset is downloadable as JSON, and a script re-fetches every source on a quarterly review and fails on drift. The next review is due 3 November 2026.

Our competitor frame is stated so you can check it: all organic results on page one of two DataForSEO queries, emi license for the United States in English and emi licence for the United Kingdom in English, both to depth 10, both re-pulled on 3 August 2026. That is 17 organic positions, 9 in the US and 8 in the UK, from 14 distinct domains. We parsed six sources in full, and all six sit inside that frame: the FCA, which holds two of the 17 positions, Advapay, Crassula, Buckingham Capital Consulting, Edenred Payment Solutions and the World Bank. Not parsed: Wikipedia, LinkedIn, sdk.finance, StablR, DashDevs, Prifinance, BVNK help, International Fintech Business, and the YouTube video block. One caveat on the frame itself: we pulled the UK query twice on the same day and position 7 changed hands between em.bank and Buckingham Capital Consulting, so the count of 8 is stable but the composition of that one slot is not.

Limitations, plainly. A published threshold is a statutory requirement, not a supervisory decision: a regulator can impose extra conditions, and clearing a threshold does not guarantee an authorisation. Three markets carry a cell we could not verify to primary and say so on the row. Each conclusion applies only to the market it names, on the date that row records. This page is not legal advice.

Written and verified by Claude Igrow, Payments Specialist.