EMI License in Finland: How to Obtain an Electronic Money Institution License and Enter the EU Market

An Electronic Money Institution (EMI) license is one of the key financial licenses that enables fintech companies to operate within the European payments market. It allows companies to issue electronic money, open client payment accounts, process transactions, and serve users across countries of the European Economic Area (EEA).

From a practical perspective, an EMI license provides a complete payment infrastructure. Companies can launch e-wallets, process international transfers, issue payment cards, and integrate payment solutions into online platforms and marketplaces.

When selecting a licensing jurisdiction, it is important to consider not only the speed of obtaining authorization but also the credibility of the regulator. For this reason, Finland is increasingly viewed as one of the most predictable and reliable European jurisdictions for fintech companies.

The regulation of electronic money institutions in the EU is primarily based on the Electronic Money Directive (2009/110/EC), which sets out the operational framework and financial requirements for such entities.

Why Finland? Advantages of the Finnish Jurisdiction for FinTech

Finland is not considered the fastest jurisdiction for fintech licensing. The regulator conducts a detailed review of the business model, risk management framework, and operational structure, which means the licensing process typically takes longer.

The assessment goes beyond the legal structure of the company. Authorities evaluate how payments are processed, where client funds are held, how risk management is implemented, and what technological solutions are used.

This approach involves stricter scrutiny by the Finnish Financial Supervisory Authority (FIN-FSA), which ultimately increases trust in companies operating under this license.

In addition to strong regulatory oversight, Finland offers several important advantages:

• a transparent and formalized licensing procedure, with clearly defined requirements and a known application structure;
• a stable legal system based on EU directives, with infrequent and well-signaled changes;
• advanced digital infrastructure and a high level of economic digitalization.

In practice, two factors are particularly important for fintech companies: access to SEPA infrastructure and the ability to provide services across the EU through passporting.

SEPA Access and European Passporting

One of the main advantages of an EMI license in the EU is the ability to operate across multiple national markets. Once authorized in one EU country, a company can provide payment services in other EEA countries without obtaining additional licenses, provided that local regulators are notified. This mechanism is known as passporting.

The legal basis for passporting is established in EU payment services legislation, primarily the Payment Services Directive (PSD2). These provisions also apply to EMI-licensed companies under the Electronic Money Directive (2009/110/EC).

Another key element of the European payments ecosystem is SEPA (Single Euro Payments Area). It includes banks and payment institutions from more than 30 European countries and establishes unified standards for euro transfers. As a result, cross-border payments are processed under the same conditions as domestic transfers, typically within one business day.

Types of EMI Licenses in Finland: Small EMI and Full EMI

There are two types of authorization for electronic money institutions in the EU: a full EMI license and a simplified regime for smaller companies (Small EMI).

Key Differences

• Small EMI:
  • Average outstanding e-money must not exceed €5 million
  • Passporting is not available
  • Operations are limited to the country of registration
  • Capital requirements depend on the business model
• Full EMI:
  • No limit on e-money volume
  • Passporting is available
  • Operations across EU/EEA countries
  • Minimum capital: €350,000

Small EMI

In Finland, the Small EMI regime is intended for companies operating on a local scale. It involves less stringent requirements but comes with limitations:

• the average volume of electronic money in circulation must not exceed €5 million;
• passporting is not available, meaning services cannot be provided in other EEA countries.

For fintech companies planning cross-border operations or scalable payment infrastructure, this model is generally not suitable.

Full EMI License

The Full EMI license is the standard format for fintech companies targeting the European market.

It allows companies to:

• issue electronic money;
• open client payment accounts and e-wallets;
• process payment transactions and transfers;
• provide services across EEA countries via passporting.

The minimum share capital requirement is €350,000.

This license is typically used by international fintech companies, as it allows scaling across the EU without establishing separate licensed entities in each country.

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FIN-FSA Requirements for Electronic Money Institutions

Obtaining an EMI license in Finland involves a comprehensive review by FIN-FSA, including capital adequacy, governance, and operational structure.

1. Capital and Financial Stability

One of the key requirements for obtaining an EMI license in Finland is the availability of sufficient capital. In accordance with the Electronic Money Directive (2009/110/EC), the minimum required capital is €350,000. The company must be able to demonstrate the availability of these funds at the time of application.

At the same time, meeting the minimum capital requirement alone does not guarantee that a license will be granted. During the review process, the regulator evaluates the company’s financial model, as well as its ability to maintain an adequate level of own funds once operations begin.

As part of the authorization procedure, the applicant is required to submit a comprehensive documentation package. This typically includes, among other things:

• a program of operations;
• a business plan and financial projections (minimum three years);
• a description of governance, internal controls, and risk management;
• security and data protection policies;
• business continuity plans;
• ownership structure and management information.

These documents allow the regulator to assess the company’s financial stability and readiness to operate safely in the payment market.

2. Substance Requirements

The Finnish regulator requires that a licensed company has a genuine operational presence in the country. An Electronic Money Institution license is not intended for nominal or shell structures; therefore, FIN-FSA assesses where key management decisions are made and where effective control over the company’s activities is exercised.

One of the core licensing conditions is that the company must be incorporated in Finland, and its actual head office must also be located there. In addition, a portion of the payment operations must be genuinely carried out within the licensing jurisdiction.

As part of the application review, FIN-FSA also evaluates the company’s corporate governance framework. EU regulations require financial institutions to operate in accordance with the principle of sound and prudent management. This implies a transparent organizational structure, clear allocation of roles and responsibilities, as well as effective risk management and internal control systems.

In practice, the regulator assesses:

• the governance structure and composition of the board of directors; 
• risk management and monitoring procedures; 
• internal control and compliance systems; 
• the experience and professional reputation of senior management. 

In addition, the company’s operational infrastructure is reviewed, including the availability of technical systems for payment processing, protection of payment data, and ensuring business continuity.

3. AML/KYC and Compliance

Like other financial institutions in the EU, companies holding an EMI license are required to comply with anti-money laundering (AML) and counter-terrorist financing (CFT) regulations. For this reason, FIN-FSA places particular emphasis on the company’s AML/KYC framework during the licensing process.

Companies must implement customer identification and verification procedures (KYC), transaction monitoring systems, and mechanisms for detecting suspicious activity. Where transactions are identified that may be linked to money laundering or terrorist financing, the company is required to conduct enhanced due diligence and, where appropriate, report such activity to the competent authorities.

As part of the application review, FIN-FSA also assesses the company’s internal compliance framework. The regulator evaluates whether AML/CFT policies are in place, along with internal control procedures and risk management mechanisms related to financial crime.

Particular attention is given to the allocation of responsibilities within the organization. In practice, the company structure must include clearly designated individuals responsible for compliance and AML/CFT functions, as well as established procedures for internal control and reporting.

4. Safeguarding Client Funds

European regulation establishes specific rules for handling client funds received in exchange for electronic money. These requirements are designed to ensure that customer funds are kept separate from the institution’s own funds and are not used for its operational activities. The most common approach is to hold client funds in segregated accounts with banks or other credit institutions.

Directive 2009/110/EC also sets a timeframe within which safeguarding must be implemented — no later than five business days after the issuance of electronic money.

During the licensing process, FIN-FSA reviews the chosen safeguarding model, the accounting procedures for client funds, and the internal control framework. The regulator assesses whether the company is able, at any time, to demonstrate the amount of its liabilities to customers. In addition, the company must maintain transparent records of client funds and perform regular reconciliations.

5. Technological Infrastructure and Operational Resilience

Since the activities of EMI-licensed companies are closely linked to payment processing, the regulator assesses the reliability of their technological infrastructure. FIN-FSA examines how the company’s payment systems are structured, how client data is protected, and what measures are in place to prevent service disruptions.

EU regulation also establishes requirements for managing operational and technological risks. In particular, under the Payment Services Directive 2 (PSD2), payment institutions are required to implement procedures for identifying and handling incidents, ensure the security of payment services, and regularly assess risks associated with their operations (Articles 95–96).

In addition, PSD2 requires the application of strong customer authentication (SCA) mechanisms to protect electronic payments and users’ personal data (Article 97).

In recent years, requirements for the digital resilience of financial institutions have been further strengthened. At the EU level, the Digital Operational Resilience Act (DORA) introduces unified rules for managing IT risks, responding to technological and cyber incidents, and ensuring the continuity and stability of digital services in financial companies.

Step-by-Step EMI Licensing Process in Finland

Obtaining an EMI license in Finland typically takes 9 to 12 months on average. This timeframe includes document preparation, submission of the application, and its review by the regulator. If FIN-FSA requests additional materials or asks the applicant to revise specific parts of the application, the process may take longer.

Step 1. Company Registration and Application Preparation

The process begins with the incorporation of a legal entity in Finland. Once the company has been established, the applicant must prepare the full licensing package, including a description of the proposed business activities, governance structure, and the operational processes of the payment institution.

It is important that the regulator receives sufficient information to assess the company’s business model, governance framework, and financial soundness.

Step 2. Submission of the Application

Once the documentation has been prepared, the company submits its license application to FIN-FSA. The application package is filed electronically together with the application form and the required supporting documents.

After receiving the materials, FIN-FSA checks whether the file is complete and then begins a detailed review of the application.

Step 3. Review of the Application and Dialogue with the Regulator

FIN-FSA conducts an in-depth analysis of the submitted materials, evaluating the company’s business model, ownership structure, financial projections, and internal operational arrangements.

During the review process, the regulator will usually send follow-up questions. The applicant may be asked to clarify specific elements of the business model or provide additional documentation.

Such dialogue between the applicant and the regulator is considered a normal part of the licensing process for financial institutions.

Step 4. Licensing Decision

Once the review has been completed, FIN-FSA makes its decision on the application. If the company meets the applicable regulatory requirements, the regulator grants an Electronic Money Institution license.

After obtaining the license in Finland, the company may provide payment services and issue electronic money, as well as operate in other EU countries through the financial services passporting mechanism.

Taxation of EMI Companies in Finland

Companies holding an EMI license in Finland are typically established in the form of a limited liability company. The standard corporate tax regime applies, with a corporate income tax rate of 20%. Finnish tax residents are taxed on profits derived both within Finland and abroad.

Most payment and fund transfer operations within the EU are exempt from VAT. This is established under the VAT Directive 2006/112/EC (Article 135(1)(d)).

Finnish companies are required to maintain accounting records and prepare annual financial statements. Once approved, these must be submitted to the Finnish Trade Register no later than eight months after the end of the financial year. In addition, licensed EMIs are required to submit regulatory reports to FIN-FSA.

A company must undergo an audit if at least two of the following thresholds are exceeded in the current and preceding financial year:

• total assets exceed €100,000; 
• annual revenue exceeds €200,000; 
• the average number of employees exceeds three. 

Acquisition of an Existing EMI License in Finland

In some cases, fintech projects consider acquiring an already licensed company instead of going through the full licensing process from scratch.

The main advantage of this approach is time savings. If the license has already been obtained and the company remains compliant, the new owner can enter the market more quickly and begin operations.

However, the buyer assumes the company together with its history, including any existing obligations and risks associated with its past activities. For this reason, a comprehensive legal and regulatory due diligence process is typically conducted prior to the transaction.

Regulatory requirements must also be taken into account. When control over a licensed company changes, FIN-FSA assesses the new shareholders and management. The regulator evaluates the business reputation of the investors, their experience in the financial sector, and the origin of their funds.

If the new owners do not meet regulatory requirements or if the transaction presents potential risks, the regulator may refuse to approve the change of control. Therefore, acquiring an EMI-licensed company requires the same level of preparation as obtaining a license from scratch.

Cost of Obtaining an EMI License

The overall cost depends on the business structure, the selected payment model, and the level of readiness of the company for licensing.

The main cost components typically include:

• legal and fintech advisory services (preparation of the license application, business plan, and supporting documentation); 
• company registration in Finland (government fees and corporate documentation); 
• preparation of internal policies required by the regulator (AML/KYC policies, risk management and internal control procedures); 
• setting up safeguarding arrangements for client funds; 
• development of operational infrastructure (payment systems, IT solutions, compliance tools). 

In addition, the minimum capital requirement of €350,000 must be taken into account.

The total budget will depend on the fintech project’s business model and the range of payment services to be provided. Specialists at QWealth can assess licensing costs and estimate the required budget for a specific project.

QWealth Services for Supporting FinTech Projects

QWealth experts support fintech projects at every stage of the EMI licensing process, from assessing the business model to submitting the application to the regulator and launching the payment infrastructure.

As part of this support, we help clients to:

• assess the project before licensing — review the business model, corporate structure, and compliance with regulatory requirements; 
• prepare the licensing documentation — including the program of operations, business plan, and descriptions of the risk management and internal control systems; 
• develop compliance documentation — including AML/KYC policies, internal control procedures, and client funds safeguarding policies; 
• register the company and establish a governance structure that meets regulatory requirements; 
• arrange safeguarding — protection of client funds through a segregated account or another permitted mechanism; 
• submit the license application and interact with the regulator at all stages of its review. 

In addition, QWealth specialists can assist in selecting a partner bank and setting up the payment infrastructure required to launch a fintech project.

Frequently Asked Questions