Malta / European Union

Malta EMI Licence: MFSA Requirements, Capital, Fees, Timeline and EEA Passporting

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Malta EMI licence from the MFSA: €350,000 capital, €10,000 or €15,000 application fee, supervisory fee from €25,000, safeguarding audit and the real timeline.

€350,000 initial capital€10,000 or €15,000 MFSA feeSupervisory fee from €25,000
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Key dates for 2026 and 2027

1 January 2025PassedNew MFSA fees apply: €10,000 or €15,000 to apply and a supervisory fee from €25,000 or €35,000 for e-money issuers.
21 January 2025PassedThe MFSA publishes thematic review findings on outsourcing and safeguarding at payment and e-money institutions.
19 August 2026PassedThe MFSA names safeguarding of client funds an enforcement priority after €570,673 of penalties in 2025.
1 January 2027UpcomingFirst 2027 supervisory fee instalment is due: 50% of the fee paid for 2026.
9 April 2027UpcomingMalta EMIs, as euro area firms, must be able to send and receive instant euro credit transfers.
10 July 2027UpcomingThe EU Anti-Money Laundering Regulation (EU) 2024/1624 applies to EMIs and other obliged entities.
30 July 2027UpcomingBalance of the 2027 MFSA supervisory fee is due.

The short answer

A Malta EMI licence is a licence under the Financial Institutions Act (Chapter 376) that lets a company issue electronic money, and provide payment services, in or from Malta and passport them across the EEA. The Malta Financial Services Authority (MFSA) requires initial capital of at least €350,000 and own funds of at least the higher of €350,000 and 2% of average daily outstanding e-money. Since 1 January 2025 the application fee is €10,000 to issue e-money, or €15,000 to issue e-money and provide payment services, and the annual supervisory fee starts at €25,000 or €35,000 plus a variable element capped at €250,000. The MFSA must decide within 3 months of a complete application, and its service charter commits to first feedback within 6 weeks of its submission review. The firm needs at least two people directing the business from Malta, a board of at least three with an independent director and a Malta resident, and an annual safeguarding audit.

Key facts at a glance

RegulatorMalta Financial Services Authority (MFSA), FinTech Supervision function
Legal basisFinancial Institutions Act (Cap. 376), item 10 of the First Schedule (issuing e-money); FIR/01 and FIR/03
Initial capitalAt least €350,000 (FIR/03 R3-2.11.2). The MFSA may set more where services from several Schedules are combined
Own fundsHigher of €350,000 and 2% of average daily outstanding e-money, plus the payment services amount for unrelated payment services. At least 75% Common Equity Tier 1
Application fee€10,000 to issue e-money; €15,000 to issue e-money and provide payment services (S.L. 376.03 since 1 January 2025)
Annual supervisory fee€25,000, or €35,000 with payment services, plus a variable element based on assets, e-money and payment volume, capped at €250,000
Statutory decision period3 months from receipt of a complete application (Article 5(2) of the Act)
MFSA service commitmentsReceipt of intention confirmed in 2 working days; meeting scheduled within 10; first feedback on a Financial Institutions Act application within 6 weeks of the submission review
Local substanceAt least 2 individuals effectively directing the business in Malta; board of at least 3 with at least 1 independent non-executive director and 1 Malta resident
SafeguardingEEA credit institution, secure low-risk assets or insurance; same-day correction of reconciliation gaps; annual safeguarding audit with reasonable assurance
PassportYes, across the EEA under S.L. 376.07 using the EBA notification forms

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What is the Malta Electronic Money Institution (EMI) Licence?

A Malta EMI is a company licensed by the MFSA under the Financial Institutions Act to issue electronic money: stored value that customers pay in advance and spend with other businesses, held as a claim on the issuer and redeemable at par. The same licence can cover payment services from the Second Schedule to the Act, such as payment accounts, transfers, card issuing and acquiring.

The MFSA's Financial Institutions Rulebook sets the detail. Chapter 1 (FIR/01, October 2025) covers the application process and licensing expectations, and Chapter 3 (FIR/03, last updated June 2025) sets the ongoing rules for e-money issuers and payment institutions: governance, outsourcing, safeguarding, capital, reporting and, since March 2025, rules for issuers of e-money tokens under MiCA.

Malta works in English, and a Malta EMI can passport across the EEA. The MFSA has said clearly that it will not accept letterbox entities: firms must show local mind and management, key function holders and internal control functions planned for Malta.

Who needs a Malta Electronic Money Institution (EMI) Licence?

Any company that issues e-money in or from Malta needs an EMI licence under the Financial Institutions Act before it starts, and adds the payment services it will provide to the same licence.

  • - UK EMIs seeking an English-speaking EU base after losing the passport on 1 January 2021
  • - Wallet, prepaid card and multi-currency account providers targeting EEA customers
  • - Gaming, marketplace and platform payment businesses that hold customer balances
  • - Crypto groups that need an EU e-money issuer to hold fiat or issue e-money tokens under MiCA
  • - Non-EU fintech groups comparing Malta with Ireland, Lithuania and the Netherlands

The first misconception is that Malta is a light-touch, outsourced option. The MFSA says it will not accept letterbox entities, requires at least two people directing the business in Malta, and in January 2025 questioned compliance, risk and audit functions outsourced for only a few hours a week. The second is that the application fee is the main regulator cost. Since 1 January 2025 the annual supervisory fee starts at €25,000 for an e-money issuer, or €35,000 with payment services, before the variable element. The third is that safeguarding is a one-off account opening. FIR/03 requires reconciliations with a preparer and a reviewer, same-day correction of any shortfall, a named individual responsible for safeguarding and an annual safeguarding audit with reasonable assurance.

Who a Malta EMI suits

Malta suits groups that want an English-speaking EU regulator, a full EEA passport and a defined fee schedule, and that can build a genuine Maltese team. It can suit UK firms that lost their passport on 1 January 2021, and platform, gaming and crypto groups that need an e-money issuer in the EU.

It does not suit firms looking for a remote shell. The MFSA requires at least two individuals effectively directing the business in Malta, a board with a Malta resident, and key function holders and control functions planned locally. Its 2025 supervision of financial institutions included more than 50 supervisory meetings and 8 onsite inspections, and its thematic reviews found concentration risk, lean governance and gaps in business continuity and succession planning, especially at smaller firms.

Capital and own funds

FIR/03 requires initial capital of at least €350,000 at authorisation for any licence holder authorised to issue e-money. The MFSA may set a higher figure where the firm combines services from several Schedules of the Act.

Own funds must be at least the higher of €350,000 and 2% of average daily outstanding e-money. Where the EMI also provides payment services not linked to e-money, it adds the payment services own funds amount. At least 75% of own funds must be Common Equity Tier 1 capital and no more than 25% Tier 2. The MFSA may require up to 20% more or allow up to 20% less based on its review of risk management.

MFSA fees since 1 January 2025

L.N. 366 of 2024 replaced the Financial Institutions fee schedule from 1 January 2025. The Act's First Schedule lists payment services as item 4 and e-money issuance as item 10, and the fees depend on how many of these a firm holds.

FeeE-money issuance onlyE-money issuance and payment services
Application fee€10,000€15,000
Annual supervisory fee, fixed part€25,000€35,000
Annual supervisory fee, variable partHigher of 0.02% of total assets or 0.01% of average daily outstanding e-moneyHigher of 0.02% of total assets or 0.0003% of payment transaction value plus 0.01% of average daily outstanding e-money
Cap on variable part€250,000€250,000
First year€25,000 pro rata, paid on the date the licence is granted€35,000 pro rata, paid on the date the licence is granted
Later years50% on 1 January, balance on 30 July50% on 1 January, balance on 30 July
Adding activities laterApplication fee reduced by 25%Application fee reduced by 25%
Removing some activities€1,000€1,000

Source: Financial Institutions (Fees) Regulations, S.L. 376.03, as amended by L.N. 366 of 2024. Fees are not refundable.

Substance, governance and key people

FIR/03 sets minimum board rules: at least three directors, at least one independent non-executive director, a balance of executive and non-executive members, and at least one director resident in Malta. The chair should be an independent non-executive director, although the MFSA can grant a temporary derogation. The board meets at least every quarter and keeps minutes that show the reasoning behind decisions.

The MFSA assesses as fit and proper every qualifying shareholder, beneficial owner, director, senior manager, MLRO and Compliance Officer. The Compliance Officer must not be involved in operations, and the MLRO must be in place at all times. Oversight of internal audit belongs to a board member, not the Compliance Officer, a point the MFSA raised in its January 2025 Dear CEO letter.

Outsourcing is allowed but tested hard. A key function holder or executive director must own outsourcing risk, compliance, risk and internal audit are treated as critical or important functions, and the firm must keep enough substance not to become an empty shell.

Safeguarding and the annual safeguarding audit

Malta EMIs safeguard client funds under the Safeguarding of Funds Regulations (S.L. 376.04) and FIR/03. Deposit accounts must be with a credit institution authorised in an EEA state, designated as safeguarding or client accounts, used only for client funds and backed by a safeguarding acknowledgment letter from the bank. Firms may also use secure, low-risk assets or insurance, and must tell the MFSA in advance of any change to their safeguarding arrangements.

The firm names an individual responsible for safeguarding, keeps a board-approved safeguarding policy, and reviews its banks and insurers for concentration and credit risk. Reconciliations use a preparer and a reviewer, are dated and signed, and any shortfall or excess must be corrected no later than the same business day. Each year an auditor with the right skills gives reasonable assurance on whether systems and controls are adequate and whether the firm complied throughout the period, and must alert the MFSA to any possible breach.

  • - MFSA January 2025 finding: a significant rise in firms using the investment method rather than bank deposits, which needs a documented assessment that the assets are secure, low-risk and liquid
  • - MFSA recommendation: more than one safeguarding arrangement to reduce concentration risk
  • - MFSA recommendation: firms using the investment method should keep a proportion of client funds with credit institutions for liquidity

What the MFSA's recent supervision and enforcement say

The MFSA's Dear CEO letter of 21 January 2025 reported thematic reviews of outsourcing and safeguarding at financial institutions. It found arrangements classified as both outsourcing and third-party services, control functions not treated as critical, heavy intragroup reliance without risk assessment, and concentration on common providers of risk, compliance and audit services, often for only a few hours a week. A further Dear Board letter on 9 September 2025 covered business resilience.

On 19 August 2026 the MFSA published its 2025 enforcement overview: 91 enforcement actions and administrative penalties totalling €570,673, with 63 penalties, about 69%, for late or missing statutory documents. It named safeguarding of client funds an enforcement priority, citing inadequate segregation, irregular reconciliations and weak governance at certain payment and e-money institutions, and cancelled the licence of one financial institution in part for safeguarding breaches. It also stated that it does not issue reminders for deadlines.

Passporting and ongoing reporting

A Malta EMI passports under the European Passport Rights for Financial Institutions Regulations (S.L. 376.07). It files Annex II of Commission Delegated Regulation (EU) 2017/2055 for a branch (with questionnaires for branch managers and the MLRO), Annex III for agents, Annex IV for e-money distributors and Annex V for services without a local presence. It cannot start in the host state until the MFSA has entered the branch, agent or distributor in its register.

Reporting follows FIR/03. The automated Annual FI Return is due within 1 month of the accounting reference date. The audited Annual FI Return, audited financial statements, the auditor's management letter and the auditor's report to the MFSA are due within 4 months. The directors' report must state any breaches that led to a regulatory sanction, and the firm also reports under Central Bank of Malta Directive 5.

Rule changes to plan for in 2026 and 2027

  • - MFSA supervisory fee instalments: 1 January and 30 July each year under S.L. 376.03
  • - Instant euro credit transfers: EMIs in euro area states, including Malta, must send and receive them by 9 April 2027
  • - EU AML Regulation (EU) 2024/1624 applies from 10 July 2027; AMLA plans direct supervision of selected firms during 2028
  • - PSD3 and the Payment Services Regulation: provisionally agreed on 27 November 2025, approved by ECON on 5 May 2026, awaiting formal adoption
  • - MiCA: FIR/03 has included rules for issuers of e-money tokens since March 2025

EMI licence: Malta vs Ireland vs Lithuania vs Netherlands vs UK

Capital is the same across the EU. Regulator fees, timing commitments, substance and language differ.

PointMaltaIrelandLithuaniaNetherlandsUK
RegulatorMFSACentral Bank of IrelandBank of LithuaniaDe Nederlandsche Bank (DNB)FCA
Initial capital€350,000€350,000€350,000€350,000€350,000
Application fee€10,000, or €15,000 with payment servicesNone€1,463 state fee€10,400 (DNB fee from 22 September 2026), payable even if refused£5,640
Annual regulator charge€25,000 or €35,000 plus a variable element capped at €250,000Levy: minimum €6,625 plus variable shareVariesAnnual supervision charge set by DNBAnnual periodic fees, varies
Statutory decision period3 months from complete application3 months from complete application3 months from complete documents3 months from complete application3 months complete, 12 months incomplete
Published real-world timingService charter: first feedback within 6 weeks of submission reviewAverage 763 days in 2025, shortest 497Completeness check within 5 business days; no average publishedDNB says the process usually takes longer than 3 monthsNo average published by the FCA on its fees page
Substance signalsAt least 2 people directing the business in Malta; board of 3 with one Malta residentPCF approvals including Head of SafeguardingHeads of good repute; clear organisational structureAssessed by DNB case by caseHead office in the UK
Language of filingEnglishEnglishLithuanian or EnglishApplication form in DutchEnglish
EEA passportYesYesYesYesNo, since 1 January 2021

Sources: S.L. 376.03 and MFSA, Central Bank of Ireland, Bank of Lithuania, DNB and FCA pages listed below, as at 29 October 2026.

Key requirements

Maltese company with local substance

The business must be carried out at least in part in Malta, with at least two individuals effectively directing it in Malta and key function holders and internal control functions planned locally.

Board composition

At least three directors, including at least one independent non-executive director and at least one Malta resident, with a balance of executive and non-executive members. The chair should be independent, and the board meets at least quarterly.

€350,000 initial capital

Held at authorisation and evidenced by audited statement or public register before the licence issues. Own funds then track the higher of €350,000 and 2% of average daily outstanding e-money.

Compliance Officer and MLRO

A Compliance Officer independent of operations and an MLRO in place at all times, both assessed as fit and proper alongside directors, senior managers, beneficial owners and qualifying shareholders.

Safeguarding framework

A board-approved safeguarding policy, designated safeguarding accounts at EEA credit institutions with acknowledgment letters, four-eyes reconciliations and an annual safeguarding audit.

Outsourcing governance

A designated person responsible for outsourcing, assessment of every arrangement against FIR/03, and internal control functions treated as critical or important.

Internal audit

An independent internal audit function. The MFSA can require an independent internal audit report covering the first 12 months as a post-licensing condition.

What does a Malta EMI licence cost in year one?

Malta publishes its regulator fees in law. A firm pays the application fee when it applies, and the first supervisory fee on the day the licence is granted, pro rated to the end of that calendar year. From the second year the supervisory fee adds a variable element and is paid in two instalments. Third-party costs depend on the model, so they are listed without invented figures.

ItemAmountSource or note
MFSA application fee€10,000, or €15,000 with payment servicesS.L. 376.03, regulation 3, not refundable
First annual supervisory fee€25,000, or €35,000 with payment services, pro rata to 31 DecemberPaid on the date the licence is granted
Initial capitalAt least €350,000Own funds held by the firm, not a fee
Annual safeguarding auditVariesReasonable assurance by a suitably skilled auditor (FIR/03 R3-2.9.25)
Statutory audit and audited Annual FI ReturnVariesDue within 4 months of the accounting reference date
Malta-resident director and independent non-executive directorVariesFIR/03 board composition rules
Compliance Officer, MLRO and internal auditVariesFit and proper approval required
Safeguarding insurance, if usedVariesAlternative to deposit or investment methods
Regulatory Counsel professional feeA fixed fee set out in a written proposal

The application process

1

Statement of intent and preliminary meeting

We file the statement of intent, which the MFSA confirms within 2 working days, and prepare the required presentation at least 10 working days before the preliminary meeting.

2

Prepare the presentation and application

We build the group chart, regulatory history, activities, flow of funds, three-year projections, Malta organisation chart, operating model, DORA approach, outsourcing and safeguarding arrangements.

3

Submit and complete

We submit within the MFSA's 40 working day window after clarifications, pay the €10,000 or €15,000 fee, and close any missing documents within the 20 working day window.

4

Manage MFSA feedback rounds

We respond to the first feedback, due within 6 weeks of the MFSA's submission review, and to each later round within the 15 working day reply window.

5

Satisfy in-principle conditions

We close the pre-licensing conditions within the 6-month limit: final documents, recruitment of key staff, capital evidence and executed outsourcing agreements.

6

Licence, commencement and passport

We complete the post-licensing conditions for the commencement of business letter, then file EEA passport notifications on the EBA forms.

The Financial Institutions Act requires the MFSA to decide within 3 months of receiving a complete application, and the clock only starts once the application is complete. The MFSA's service charter adds working-day commitments at each step: 2 working days to confirm a statement of intent, 10 to schedule the meeting, 6 weeks for first feedback on a Financial Institutions Act application after its submission review, and 20 working days per later feedback round. After in-principle approval, the applicant has up to 6 months to meet pre-licensing conditions, then post-licensing conditions apply before business can start. The MFSA does not publish an average end-to-end time for EMI licences.

How long does a Malta EMI licence take?

The legal deadline is 3 months from a complete application. The MFSA's Authorisation Process Service Charter sets working-day commitments for each stage, for both the MFSA and the applicant, but the MFSA does not publish an average end-to-end time for EMI licences. Applicants who do not reply within 4 months receive a final month's notice, after which the MFSA may treat the application as withdrawn and a new fee is due to restart.

StageMFSA commitmentApplicant commitment
Statement of intentConfirm receipt within 2 working days; schedule meeting within 10 working daysPresentation at least 10 working days before the preliminary meeting
Application submissionCheck required documents within 5 working daysSubmit within 40 working days of clarifications; missing documents within 20 working days
Initial reviewFirst feedback within 6 weeks of the submission reviewReply within 3 weeks
Later roundsReply within 20 working daysReply within 15 working days
In-principle approvalPre-licensing conditions setMeet them within 6 months, extension on request
Licence and commencementLicence issued, then commencement of business letterPost-licensing conditions, with further conditions over 6 to 18 months

Source: MFSA Authorisation Process Service Charter (version 1.1, 19 September 2024) and FIR/01 (October 2025).

Why applications fail, and how we prevent it

A letterbox structure

The MFSA will not accept letterbox entities and assesses heavy outsourcing closely. We design a Malta team and governance that meets FIR/01 and FIR/03 before the presentation.

Thin outsourced control functions

The MFSA flagged compliance, risk and audit roles outsourced for only a few hours a week. We size each role against time commitment and the business plan.

A single safeguarding arrangement

The MFSA recommends more than one safeguarding arrangement to avoid concentration risk. We plan at least two arrangements and the bank due diligence behind them.

Late regulatory returns

Late or missing returns drove about 69% of MFSA enforcement actions in 2025, and the MFSA does not send reminders. We build the return calendar before the licence issues.

Changing the model during review

Significant changes during the application require a new submission. We fix activities and the operating model before the statement of intent.

Missing the in-principle deadline

Pre-licensing conditions must be met within 6 months of the in-principle letter or it lapses. We track each condition from day one.

Practitioner notes: pre-application checklist

  • - Activities mapped to items 4 and 10 of the First Schedule, which also fixes the fee band
  • - Full group chart, regulatory history of every group entity and beneficial owners traced to individuals
  • - Flow of funds diagram for each product
  • - Three-year projections and a capital plan for €350,000 plus 2% of average daily outstanding e-money
  • - Malta organisation chart for three years showing who is based in Malta and the three lines of defence
  • - Board of at least three with an independent non-executive chair and a Malta-resident director
  • - Named Compliance Officer, MLRO and person responsible for outsourcing, with time commitments that match the plan
  • - Safeguarding policy, at least two safeguarding arrangements and bank acknowledgment letters in draft
  • - DORA compliance approach for IT systems and third-party ICT providers
  • - Outsourcing register with critical or important functions identified
  • - Presentation for the preliminary meeting ready 10 working days in advance
  • - Reporting calendar for the Annual FI Return, audited return and Central Bank of Malta Directive 5

How we help

Structure and substance

We design the Malta board, key function holders and outsourcing model the MFSA expects, and compare Malta with Ireland and other EU options.

MFSA application

We prepare the presentation, application, business plan, safeguarding policy and fit and proper files, and manage every feedback round.

Ongoing compliance

We run the annual FI return, audited return, safeguarding audit, Central Bank of Malta reporting and passport notifications.

Regulatory Counsel is a licensing and compliance practice for regulated finance in 65+ jurisdictions, with more than 200 licence and registration engagements. We prepare Malta EMI applications alongside Irish, UK and MiCA filings, so groups can compare EU bases on one plan. Professional fees are a fixed fee set out in a written proposal, and every enquiry is answered the same business day.

Frequently asked questions

At least €350,000 of initial capital at authorisation. Own funds must then be at least the higher of €350,000 and 2% of average daily outstanding e-money, plus the payment services amount if the EMI provides unrelated payment services.

Since 1 January 2025 it is €10,000 to issue e-money only, or €15,000 to issue e-money and provide payment services. The fee is not refundable.

€25,000 for an e-money issuer, or €35,000 if it also provides payment services, plus a variable element based on total assets, average daily outstanding e-money and payment volume, capped at €250,000. The first year's fixed fee is pro rated and paid when the licence is granted.

The law requires a decision within 3 months of a complete application. The MFSA's service charter commits to first feedback within 6 weeks of its submission review and 20 working days for later rounds, but it does not publish an average end-to-end time.

Yes. At least two individuals must effectively direct the business in Malta, and FIR/03 requires a board of at least three with at least one independent non-executive director and at least one director resident in Malta.

Through designated accounts at EEA credit institutions with acknowledgment letters, secure low-risk assets, or insurance. Reconciliations need a preparer and reviewer, shortfalls must be fixed by the same business day, and an annual safeguarding audit gives reasonable assurance to the MFSA.

Yes. It notifies the MFSA under S.L. 376.07 using the EBA forms for a branch, agents, distributors or services, and can start in the host state once entered in the MFSA register.

Both have €350,000 capital and an English-speaking regulator. Ireland charges no application fee but its published average time was 763 days in 2025. Malta charges €10,000 to €15,000 to apply and at least €25,000 a year, and publishes stage-by-stage service commitments instead of an average.

Regulatory Counsel charges a fixed fee set out in a written proposal, separate from MFSA fees and third-party costs. Every enquiry is answered the same business day.

Primary sources

The requirements, fees and timeframes on this page are taken from the following primary regulatory and legislative sources. Rules change, and firms should confirm the current position before relying on any figure.

By · Updated

Harry Khan advises payment, e-money and money transmission firms on licensing and compliance.