PSP & EMI Licensing for Payment & E-Money Businesses
Regulatory and compliance support for businesses seeking authorisation to provide payment services or issue electronic money. LEX ARTA coordinates the licensing workstream from activity classification and jurisdiction strategy through applicant preparation, safeguarding, AML/CFT, governance, business planning and regulator questions.
“PSP” is commonly used as a commercial umbrella term. In EU licensing practice, the applicant normally seeks authorisation as a Payment Institution (PI) or an Electronic Money Institution (EMI), depending on the services and whether electronic money will be issued.
EMIE-money issuance plus permitted payment services
Application-ledStructure, documents, controls and regulatory evidence
Payment business model assessment
Payment Business Model & Licensing Route Assessment.
Before committing to a PI, EMI or other payment structure, the proposed operating model is assessed against the activities the business will actually perform — how customer funds move, whether electronic money is issued, which payment services are provided, expected transaction volumes, target markets and how the product is distributed.
Where more than one structure is legally available, the assessment compares the licensing burden, capital, safeguarding, substance, operational requirements, passporting and scalability of the available routes.
Payment Institution
PI Authorisation
For regulated payment services such as money remittance, payment execution, acquiring, payment initiation or account information, without issuing electronic money unless separately permitted.
Electronic Money Institution
EMI Authorisation
For businesses that issue electronically stored monetary value and may also provide permitted payment services, subject to safeguarding, capital, governance and prudential requirements.
Limited national regime
Small or Restricted PI / EMI
For models that may qualify for a limited national registration, waiver or restricted authorisation route, subject to applicable activity, volume, territorial and passporting limitations.
Partner-led structure
Agent / Distributor / Programme Model
Where a proprietary PI or EMI licence is not required or is not the most proportionate route, the model may be structured through an authorised PI or EMI using an agent, distributor, programme-manager or similar arrangement where permitted.
What the Assessment Covers
A payment-sector regulatory assessment resulting in a reasoned recommendation on the structure that best fits the proposed business model.
What is included →
Business model, product and customer-flow mapping
Payment-service and e-money perimeter analysis
Customer-funds and safeguarding-flow review
Assessment of PI, EMI and available restricted routes
Assessment of agent, distributor, programme-manager or similar partner-led structures where relevant
Comparison of permissions, capital, safeguarding, substance and operational requirements where more than one route is viable
Scalability, passporting and key implementation considerations
Written recommended route and next-step action plan
Outcome: a reasoned recommendation on the regulatory structure that best fits the proposed payment business model. Full licence application preparation and formal local-law opinions are scoped separately where required.
For businesses that already know the intended regulatory route, support can begin with the relevant authorisation, distribution, licence-change, remediation or post-authorisation workstream.
01 · Payment services authorisation
Payment Institution Authorisation
Modular application preparation and regulatory coordination for businesses seeking permission to provide one or more regulated payment services. The final scope is agreed after the proposed services and applicant readiness are reviewed.
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Payment-service classification and permission mapping
Applicant, ownership and qualifying-holder structure
Governance, risk, compliance and internal-control framework
Safeguarding model and customer-funds controls
AML/CFT programme and MLRO arrangements
Programme of operations and business plan
Financial projections, capital and own-funds assumptions
Technology, outsourcing, security and continuity documentation
Application inventory, consistency review and regulator questions
Outcome: coordinated PI application file and readiness evidence for the selected competent authority.
A modular authorisation workstream for businesses issuing electronic money and providing associated payment services, wallets, cards or account-based products. Workstreams are selected according to the actual product and regulator requirements.
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E-money and payment-service perimeter analysis
Issuance, redemption and customer-funds model
Safeguarding, segregation and reconciliation methodology
Capital, own funds and financial sustainability planning
Board, management and key-function arrangements
AML/CFT, fraud, sanctions and transaction-monitoring framework
Card, processor, banking and settlement dependencies
Operational, technology and outsourcing documentation
Application preparation and regulatory coordination
Outcome: coordinated EMI authorisation package aligned with the intended product and operating model.
Assessment and application support for jurisdiction-specific registration, waiver or restricted authorisation pathways where the business model is intended to remain within the applicable limits.
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Eligibility and threshold assessment
Territorial and passporting limitations
Permitted services and prohibited activities
Governance, AML/CFT and safeguarding requirements
Registration or application documents
Growth triggers requiring full authorisation
Important: availability and legal effect depend on national implementation. The route is not presented as a substitute for full authorisation where the intended scale or services exceed the limits.
PI / EMI Agent, Distributor & Programme Structuring
Support for businesses operating through or alongside an authorised payment or e-money institution, including agent, distributor, programme-manager and similar distribution models where permitted.
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Role and regulated-activity perimeter analysis
Principal / agent or distributor responsibility mapping
Registration or notification requirements where applicable
Customer-funds, safeguarding and contractual flow analysis
AML/CFT allocation and operational-control responsibilities
Governance, oversight and outsourcing documentation
Outcome: structured distribution model and regulatory action list aligned with the selected jurisdiction and principal institution.
Licence Variation, Material Changes & Permission Expansion
Regulatory-change and application support for authorised firms adding services or products, changing ownership or governance, expanding distribution models or making other material changes.
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Change classification and regulator-notification analysis
Updated programme of operations and business plan
Capital and safeguarding impact
Governance and staffing changes
AML/CFT and operational-control updates
Variation application, passporting / notification implications and regulatory questions
Outcome: variation package and implementation roadmap for the expanded permission scope.
Modular scope. No single engagement automatically includes every workstream listed above. The statement of work identifies the documents and coordination activities assigned to LEX ARTA. Formal local-law opinions, audited financial statements, capital provision, cybersecurity or penetration testing, technology implementation, recruitment, regulated appointments, banking onboarding and third-party licences are excluded unless separately agreed and delivered by the appropriately qualified provider.
Core application workstreams
What a Credible PI or EMI Application Must Connect.
The application is assessed as a coherent operating system, not as a collection of unrelated policies.
Regulatory perimeter
Services, permissions, customer markets, territorial scope and interactions with banking, crypto or investment regulation.
Applicant & ownership
Entity, shareholders, UBOs, qualifying holdings, group structure and source-of-funds evidence.
Governance & substance
Board, senior management, local presence, compliance, risk, internal audit and fit-and-proper evidence.
Safeguarding
Segregation, safeguarding accounts, reconciliation, shortfalls, insolvency protection and oversight.
AML/CFT & fraud
EWRA, CDD/EDD, sanctions, monitoring, reporting, fraud controls and management information.
Business & financial plan
Revenue model, transaction volumes, capital, own funds, liquidity, staffing and multi-year forecasts.
Document inventory, implementation evidence, consistency checks, regulator correspondence and remediation.
Why LEX ARTA
Payment Licensing Built Around the Actual Money Flow.
PI and EMI applications depend on more than the legal classification of the product. The licensing structure must reflect how customer funds move, where they are safeguarded, which payment services are provided, which third parties are involved and how the institution will operate after authorisation.
Permission & Product Mapping
Payment services, e-money issuance, wallets, cards, acquiring, remittance and other functionality are mapped to the appropriate authorisation scope.
Safeguarding & Financial Model
Customer-funds arrangements, safeguarding, reconciliation, capital, own funds, liquidity assumptions and financial projections are considered together with the proposed operating model.
AML/CFT, Fraud & Governance
AML/CFT, sanctions, transaction monitoring, fraud controls, management responsibilities and key compliance functions are incorporated into the licensing workstream.
Technology & Outsourcing Dependencies
Processors, banking partners, cloud providers, card programmes, settlement arrangements and other critical dependencies are reflected in the regulatory documentation and governance framework.
Support may also include licence variations, material changes, permission expansion, agent or distributor structures, application remediation and post-authorisation compliance.
Confirm regulated services, intended markets, authorisation category and selected jurisdiction.
02
Applicant Design
Define ownership, management, local substance, safeguarding, staffing and third-party dependencies.
03
Framework and Application Build
Develop the business, financial, governance, AML/CFT, safeguarding, technology and operational documentation.
04
Filing and Regulatory Coordination
Coordinate formal submission, local legal input where required, regulator correspondence and supplementary evidence.
05
Remediation and Launch Readiness
Address conditions and queries, complete implementation evidence and prepare the firm for regulated operations.
Scope boundary. Government and regulator fees, required capital, incorporation, local counsel, directors and staff, office, audit, technology, banking and other third-party costs are separate. Where local law requires an admitted lawyer, auditor or other qualified professional, the relevant work is assigned to an appropriately qualified professional partner. Approval and a fixed timeline cannot be guaranteed.
Common questions
PSP / EMI Licensing — FAQ.
Is a PSP licence the same as a PI licence?
“PSP” is a broad commercial term for a payment service provider. Under EU authorisation frameworks, a non-bank applicant is commonly authorised as a Payment Institution or Electronic Money Institution, depending on its services.
What is the main difference between a PI and an EMI?
A PI may provide authorised payment services but does not, by that status alone, issue electronic money. An EMI may issue electronic money and provide the payment services included in its permission scope.
Does a MiCA CASP authorisation replace PI or EMI authorisation?
No. A crypto-asset authorisation does not automatically permit regulated payment services or electronic-money issuance. The payment functionality must be assessed separately.
Can an authorised PI or EMI operate across the EEA?
A fully authorised EU institution may generally use the applicable passporting and notification framework for permitted services. Restricted or exempt national routes usually do not provide equivalent passporting rights.
Does LEX ARTA guarantee authorisation?
No. The competent authority makes the decision. LEX ARTA supports classification, preparation, coordination and remediation but cannot guarantee approval, banking access or a fixed processing period.
Building a payment or e-money institution?
Start with the actual services, customer flows, safeguarding model and target markets. We will determine the correct authorisation workstream and information required.
