Electronic money institution licence in Malta
Malta licenses electronic money institutions under the Financial Institutions Act, with the MFSA as regulator. A Maltese EMI can passport e-money and payment services across the EU/EEA. Since 1 January 2025 MFSA fees are considerably higher than the figures still quoted by many vendors, and the MFSA expects the business to be run from Malta by real people.
Facts under review · last checked 2026-10-08 · confirm figures with the regulator before relying on them
Regulator · Malta Financial Services Authority (MFSA) ↗
Key facts
- Minimum initial capital
- €350,000EMD-Art-4as of 2026-10-08Source ↗
- MFSA application fee
- €10,000 for e-money issuance alone; €15,000 where the licence covers both e-money and payment services (non-refundable)Malta L.N. 366 of 2024, reg. 3as of 2026-10-08Source ↗
- MFSA annual supervisory fee
- From €25,000 (e-money only) or €35,000 (e-money and payment services) plus a variable element based on assets, transaction volume or outstanding e-money, capped at €250,000 for the variable partMalta L.N. 366 of 2024, reg. 4as of 2026-10-08Source ↗
- Local direction
- Business must be effectively directed from Malta by at least two individuals (executive directors and/or senior management); the MFSA may require moreMFSA FIR/03 R3-2.7.2as of 2026-10-08Source ↗
- EU reform status (PSD3/PSR)
- Negotiated text approved by the European Parliament ECON committee on 5 May 2026; plenary indicatively scheduled for 14 December 2026. EMIs are licensed under the current rules until the new framework appliesas of 2026-10-08Source ↗
Realistic timeline
Who does what, and how long each phase usually takes once work starts. The regulator’s share is outside anyone’s control.
- HartsizScoping, structure and gap analysis2–4 weeks
- YouCompany set-up, hires, capital and application pack8–16 weeksHartsiz drafts the pack; the client supplies people, capital and decisions
- RegulatorMFSA review, questions and licensing decision20–52 weeksOutside our control; depends on MFSA workload and the quality of answers
Estimated end to end: 7–17 months. Not a guarantee.
What the regulator expects to see
- Maltese company with head office and effective direction in Malta, at least two individuals directing the business locally (FIR/03)
- Directors and key function holders of good repute, with the knowledge, experience and time the MFSA expects
- MLRO and AML/CFT framework under Maltese AML rules
- Safeguarding arrangements for e-money holders' funds
- ICT risk-management framework under DORA
Questions we get
Are the €3,500 application and €2,500 supervisory fees still valid?
No. Those figures come from the old fee rules. Since 1 January 2025 the application fee is €10,000 or €15,000 and the annual supervisory fee starts at €25,000 or €35,000, depending on whether you issue e-money only or also provide payment services.
Can the two people directing the business be based outside Malta?
The MFSA rulebook requires the business to be effectively directed from Malta by at least two individuals. Plan for real, resident management, not names on a board.
Will PSD3 change our EMI licence?
The new EU payments package is not yet adopted. Until it applies, EMIs are authorised under the current E-Money and Payment Services Directives as implemented in Malta.