Obtaining a Payment Institution license

Obtaining a Payment Institution (PI) license is a significant milestone on the path to entering the financial market. This step is preceded by a comprehensive set of preparatory measures. While such a license ensures the legality of your operations, enhances client trust, and provides access to international financial products, the process of obtaining it is often complex. Our team will assist you in successfully completing this procedure and laying a solid foundation for your business development.

Before applying for a Payment Institution license, it is essential to understand the scope of functions such a company possesses, as well as its organizational structure and reporting obligations. Moreover, you must assess your readiness to comply with all regulations and legal acts issued by the State (Central) Bank of the jurisdiction in which you plan to operate.

A Payment Institution (PI) is a legal entity established in accordance with applicable law, whose primary objective is to provide payment services (financial transactions and intermediary services related to money transfers).

Failure to comply with regulatory requirements can lead to serious consequences: fines, license revocation, subsequent bans on holding relevant positions, or even criminal liability. Regulators exercise strict oversight over the observance of standards, including AML (Anti-Money Laundering) procedures, and ensure the security of clients’ data. Legal support from qualified Law&Trust attorneys will help you avoid mistakes and expedite the licensing process.

Obtaining a Payment Institution license

We offer a full range of services for licensing Payment Institutions, including:

- Analysis and selection of a suitable jurisdiction;
- Preparation and submission of documentation;
- Support throughout all stages of the licensing process;
- Consultation on compliance with regulatory requirements.

Our Law&Trust team consists of seasoned experts with years of experience, ready to provide top-level assistance.

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Why do you need a Payment Institution license?

This license confirms the legal status of the institution’s activities and allows you to:

Operate officially in the field of payment services in compliance with local and international legislation;
Earn the trust of clients and partners thanks to stringent regulatory oversight;
Gain access to international payment systems and financial markets;
Protect client interests through mandatory adherence to security and fund protection standards.

Which jurisdiction options can we offer?

Payment Institutions are primarily registered in European jurisdictions, though offshore options are also used. PI requirements vary accordingly.

Minimum capital	On average for a small PI (Small Payment Institution, SPI) from 50,000 EUR, and for a PI from 125,000 EUR
Local employees	There is a requirement for the presence of local qualified personnel (e.g. Directors, AML officers, etc.)
Legal structure	Registration of a legal entity within the state in the established organizational and legal form
License fees	For a small PI the license fees are around 1,000 EUR, and for a PI on average 5,000-10,000 EUR

EU jurisdictions operate under a common legal framework — PSD2 — though some aspects differ from country to country. Below, we present a list of jurisdictions along with their key advantages and requirements.

Country, Region	Advantages	Requirements	Minimum capital
Netherlands, EU	Fully PSD2 compliant; EU/EEA rights passporting. The regulator's strong reputation builds trust.	It is necessary to demonstrate reliable governance, AML/KYC systems, protection of client funds, risk management.	140,000 EUR for PI
Lithuania, EU	Fast processing (2 months for SPI, 3 months for full PI), competitive fees, reliable EU passporting. The regulator offers support and guidance.	Founders must pass a fit and proper check. Board of directors of at least 3 people + CEO, plus anti-money laundering officer, chief information security officer, etc. Protection of client funds through segregated accounts or insurance.	There is no minimum requirement for SPI For different services it varies from 20,000 to 125,000 EUR
Estonia, EU	Entrepreneur-friendly, fast digital adoption. Strategic gateway for fintech/cryptocurrency (though recently tightened).	Local registered office and management. AML/KYC protocols, management, qualified advice.	Up to 6,000 EUR for SPI 15,000 EUR for PI
Malta, EU	EU passporting with a relatively simplified process. Malta has dedicated fintech/licensing teams.	Management structure, AML/KYC, risk management, security assurance.	24,000 EUR for PI and SPI
United Kingdom, Europe	Access to the UK market after Brexit; prestigious FCA approval. Clear process for both full and small PIs.	Good and compliant directors, AML systems, security, reporting systems.	Approximately 145,000 EUR for PI

It is important to note that each country has its own unique risks or specific conditions for license revocation. For example, failure to submit annual reports within the established deadlines in Lithuania leads to license revocation, while violations of Due Diligence requirements or procedures in the Netherlands may result in fines of up to 500,000 EUR - with repeated violations potentially incurring even higher penalties.

What are the requirements for documents?

Document	Note
Passport details of the founders	Certified copies
Certificate of good conduct	For all key participants
Business plan	Should include a three-year forecast, target market, risk analysis, etc.
Corporate documents	Main corporate/statutory documents
AML documentation	Anti-Money Laundering Policies and Procedures
Authorized capital	Confirmation of the availability of authorized capital in the established amount
IT and Security Strategy	Most jurisdictions require data protection plans and systems and infrastructure to ensure that all data, as well as the bank accounts themselves, are protected.

What are the stages of obtaining a license?

Preliminary Analysis

- Assessment of compliance with the jurisdiction’s requirements;
- Preparation of a business plan, a description of payment services, and a financial model.
Document Preparation

- Collection, formatting, and notarization of all required documents;
- Verification of compliance with regulatory standards.
Application Submission

- Company registration;
- Injection of the authorized capital;
- Preparation and submission of the full set of documents.
Application Review

- Timeline: on average, 3 to 12 months;
- Interaction with the regulator and provision of additional information upon request.
License Issuance

- Commencement of operations and adherence to ongoing regulatory requirements.

What is the time period for obtaining a license?

Our team has also estimated the approximate timeline for obtaining a banking license, assuming the process starts solely from your initial intention:

Document preparation: 2–3 months;
Company registration, account opening, capital injection: 1–3 months;
Application review and license issuance: 3–12 months.

What do we recommend?

When choosing a jurisdiction for registering a payment institution and obtaining the corresponding license, it is important to take into account factors that directly impact the business, such as tax rates, requirements for founders and directors, access to international markets, legal obligations, and much more. To determine the optimal option, it is essential to evaluate as many factors as possible, as different jurisdictions offer unique conditions for each of these aspects.

Our team has prepared the following recommendations to help you successfully complete the first step in this direction:

Research jurisdictional requirements:
Carefully review the requirements of your selected country, including minimum capital, mandatory documents, and regulatory standards.
Plan for long-term objectives:
A license will be most beneficial in jurisdictions that offer strategic access to your target markets.
Seek professional assistance:
Consult legal experts to avoid errors in the application process and to ensure ongoing legal compliance.
Ensure transparency and regulatory alignment:
Prepare detailed documentation, including a business plan, proof of funding sources, and the qualifications of the management team.
Monitor regulatory developments:
Legal and financial environments are evolving rapidly, so staying up to date on changes—particularly those related to cybersecurity, KYC/AML procedures, and regulatory policies—is crucial.

It is worth highlighting that when applying for a payment institution license, legal assistance is strongly recommended. Improper documentation at any stage may result in rejection of company registration or license issuance. Engaging professionals is key to successfully navigating every stage of the process. Law&Trust’s legal team can help you identify the most suitable jurisdiction and guide you based on your specific needs.

F.A.Q.

What services can be provided under a PI license?

Money transfers (including P2P), payment acceptance and processing, issuance of electronic money and debit/prepaid cards, as well as acting as an agent on behalf of other payment systems.

Can the license be used in other EU countries?

Yes. Once licensed in an EU member state, you can use the “passporting” regime to provide services across other EU countries without the need for additional licenses.

Is it possible to purchase a ready-made company with a PI license?

Yes, acquiring an already licensed company is possible. This reduces time to market, but requires thorough legal and financial due diligence. When acquiring a licensed entity, full disclosure of the new key personnel will be required, and corresponding updates must be submitted to the regulator.