We help e-wallet, prepaid card and stored value projects choose the regime, obtain an e-money authorisation or licence and set up safeguarding, compliance and technology. Lawyers, finance specialists, anti-money laundering (AML) and compliance specialists and engineers work on one project plan.
An electronic money institution (EMI) issues electronic money — prepaid value held in a wallet or account and used for payments — and usually provides related payment services. In Hong Kong and the UAE mainland the equivalent permission is a stored value facility (SVF) licence; in Abu Dhabi Global Market (ADGM), a UAE financial free zone, and in the Astana International Financial Centre (AIFC) issuing stored value falls under the regulated activity Providing Money Services.
In the EU the core rules are set by the Electronic Money Directive (EMD2): initial capital, ongoing own funds linked to outstanding e-money, safeguarding of client funds and limits on how e-money can be distributed. The UK applies its own Electronic Money Regulations 2011 with authorised and small EMI regimes. The EU is reforming its payments framework, and the e-money regime is part of that reform; we confirm the applicable rules at the assessment stage.
In Kazakhstan the issuing of e-money is not open to non-bank companies in the way it is in the EU. Under the Law on Payments and Payment Systems, e-money is issued by the National Bank, banks and the national postal operator, while a payment organisation may distribute e-money, process e-money payments and act as the operator of an e-money system under an agreement with the issuer. E-wallet projects in Kazakhstan are therefore usually built through a partnership with a bank issuer; the current wording of the law is confirmed at assessment.
The table shows the regimes we work with and the requirements confirmed against official sources. Where a figure could not be verified, we confirm it at the assessment stage.
| Jurisdiction | Regulator | Regime | Key points |
|---|---|---|---|
| European Union (EMD2) | National competent authority | Authorisation | Initial capital of at least €350,000. Own funds for e-money issuance of at least 2% of average outstanding e-money. Safeguarding of funds received. Optional small EMI waiver for up to €5 million in average outstanding e-money. |
| Lithuania | Bank of Lithuania | Authorisation | EMD2 capital, own funds and safeguarding requirements apply. National options and the application procedure are confirmed at assessment. |
| United Kingdom | Financial Conduct Authority (FCA) | Authorisation (authorised EMI) or registration (small EMI) | Authorised EMI: initial capital of at least €350,000. Small EMI: average outstanding e-money of up to €5 million; capital of at least 2% of that amount once it reaches €500,000. The safeguarding chapter CASS 15 applies to authorised EMIs from 7 May 2026. |
| UAE — mainland and non-financial free zones | Central Bank of the UAE (CBUAE) | SVF licence | Capital AED 15 million (reduced from AED 50 million in 2020); a bank no longer needs to hold direct control of the shareholding. |
| UAE — ADGM | Financial Services Regulatory Authority (FSRA) | Financial Services Permission — Providing Money Services | Since 9 Nov 2020 the permission has covered issuing stored value and payment accounts. Capital follows the prudential category and is confirmed at assessment. |
| Hong Kong | Hong Kong Monetary Authority (HKMA) | SVF licence | Paid-up capital of at least HK$25 million; company incorporated in Hong Kong; protection of user funds (float). |
| Singapore | Monetary Authority of Singapore (MAS) | Licence: Standard (SPI) or Major (MPI) Payment Institution | SPI base capital S$100,000. An MPI licence is required once average daily outstanding e-money exceeds S$5 million or monthly transaction thresholds are exceeded. |
| Kazakhstan | National Bank of Kazakhstan (NBK) | Issuance by banks and the national postal operator; registration of a payment organisation | Under the Law on payments, e-money is issued by the NBK, banks and the national postal operator. A registered payment organisation may distribute e-money and process e-money payments. The model and the current law are confirmed at assessment. |
| AIFC (Astana) | Astana Financial Services Authority (AFSA) | Authorisation — Providing Money Services | Covers issuing payment instruments and stored value. AIFC law applies only to AIFC participants; capital is confirmed at assessment. |
| Kyrgyzstan | National Bank of the Kyrgyz Republic (NBKR) | Payment organisation licence with the right to issue e-money | Non-bank payment organisations may issue e-money under a separate right recorded in the NBKR register of payment organisations. A new payment organisation needs charter capital of at least KGS 30 million; the conditions for obtaining the e-money right are confirmed at assessment. |
Regulatory capital is separate from state and application fees, operating costs and our fees. Our fees are agreed after the project assessment.
We analyse the product, fund flows and target markets, decide whether the model needs an e-money permission or a payment permission, and compare regimes. Result: recommended jurisdiction and model.
Incorporation or adaptation of the company, governance, safeguarding banks, card scheme or issuer partners; in Kazakhstan, the bank-issuer partnership. Result: an approved structure.
Business plan, financial model, policies, AML/CFT framework, safeguarding and distribution model. Result: a complete application package.
Filing, answers to the regulator's questions, interview preparation. Result: a decision on the application.
Paying in capital, opening safeguarding accounts, setting up the wallet ledger, KYC, monitoring and reconciliations. Result: readiness to operate.
Operational launch, first reports, oversight of distributors and changes to products. Result: a working e-money business that meets its obligations.
Review periods are set by national law or regulator practice and differ between jurisdictions; we confirm them for the chosen regime. In practice, the timeline depends mostly on the quality of the application, the readiness of the safeguarding arrangements and how quickly the regulator's questions are answered. We do not promise a fixed decision date.
Authorisation or registration of a payment service provider in the EU, UK, UAE, Singapore, Kazakhstan or the AIFC — from the choice of regime to launch.
Learn morePayment services linked to digital assets, e-money, payment apps and infrastructure.
Learn moreLicences and registrations for money transfer businesses: EU and UK payment regimes, Canadian and US MSB registration, US state licences, Hong Kong, UAE, Kazakhstan and the AIFC.
Learn moreRisk assessment, policies, KYC/KYB, sanctions and transaction monitoring, travel rule and inspection readiness for licensed and to-be-licensed financial and crypto businesses.
Learn moreDescribe your project in a few sentences. We will give you a substantive reply: which questions need answering and where to start.
Discuss your projectAn EMI may issue electronic money — stored balances that users hold and spend — as well as provide payment services. A payment institution executes payments but does not issue e-money. In the EU this means higher initial capital for an EMI (€350,000) and own funds linked to outstanding e-money.
It depends on the regime: €350,000 for an EMI in the EU and UK, AED 15 million for a CBUAE SVF, HK$25 million for an HKMA SVF, S$100,000 for an SPI in Singapore. This is regulatory capital only; state fees, operating costs and our fees are separate. Our fees are agreed after the assessment.
In the EU e-money may be distributed and redeemed through distributors, but it cannot be issued through agents; agents may provide payment services only. The EMI remains responsible for its distributors, so oversight procedures are part of the application.
Under the Law on Payments and Payment Systems, e-money is issued by the National Bank, banks and the national postal operator. A payment organisation may distribute e-money, process payments with it and operate an e-money system under an agreement with the issuer. We analyse the wallet model and structure the bank-issuer partnership.
No. Stablecoins are regulated separately: for example, the CBUAE Payment Token Services Regulation in the UAE and the Stablecoins Ordinance in Hong Kong. We assess which regime the token falls under.
In the EU, member states may waive some requirements where average outstanding e-money does not exceed a national limit of up to €5 million; the UK has a small EMI registration with the same €5 million limit. Above the limit, full authorisation is required.
No. The decision belongs to the regulator, and banks, card schemes and payment providers make their own decisions on whether to work with a client. We prepare the project so that it meets the requirements and the regulator's questions are answered fully.
Describe the wallet or card product, target markets and expected balances. We will determine how the model is classified, compare the regimes and propose a project plan; fees are agreed after the assessment.
We will review the description and give you a substantive reply: which regime may apply and where to start.
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