Obtaining an Electronic Money Institution (EMI) License in Cyprus

Obtaining an EMI license in Cyprus is a task that should only be entrusted to a team of professional lawyers.
The country’s legislation imposes specific requirements on applicants seeking a license.
Activities involving virtual currency turnover or its use are subject to licensing. Applications are reviewed by the specialized department of the Central Bank of Cyprus.
The primary regulatory acts governing payment systems using electronic payment instruments are EU Directive 2009/110/EC and the Cyprus Electronic Money Law (2012).
In accordance with the requirements of these acts, a license can only be issued to a legal entity registered or having a representative office in Cyprus.

Why is an EMI license necessary in Cyprus?

The turnover of virtual currency is easier to track, which means it is generally taxed at lower rates than physical assets;
In Cyprus, transactions in any currency are permitted—conversion of capital is not necessary;
A certificate for using virtual funds simplifies and accelerates many financial operations;
The license allows for growth in developing new tools for working with interactive money, supporting clients, issuing loans to e-wallets, etc.;
Enables monetary equivalents for operations in e-money and resale of products using electronic payment instruments;
Cyprus’s EU membership and compliance with the EU E-Money Directive allows service provision across the entire European Union.

For more detailed information about the benefits of modern payment instruments and the Cypriot license, please consult our specialists.

Who needs an EMI license in Cyprus?

Cyprus has long been one of Europe’s key fintech hubs, offering balanced regulation and access to the EU market. The Central Bank of Cyprus (CBC) issues EMI licenses under PSD2 standards, making them attractive for:

Startups seeking to scale within the EU;
Crypto businesses looking for legal fiat gateways;
Payment services working with international transactions.

At the same time, Cyprus maintains more flexible requirements than Germany or France, with reasonable capital (€350,000) and an expedited review process (6–9 months).

E-money licensing in Cyprus: requirements

Cyprus remains one of the most attractive destinations for fintech companies seeking an Electronic Money Institution (EMI) license. As an EU member with a favorable tax regime, a Cypriot EMI license grants access to the entire European Economic Area under PSD2 Directive.
However, the licensing process requires strict compliance with the requirements of the Central Bank of Cyprus (CBC). Here's what must be met to obtain the license:

Legal entity presence. The company’s Articles of Association must state that it will engage in activities related to electronic money and payment services. A physical office and payment of the authorized capital of €350,000 are required. An additional reserve of 2% of the average electronic money in circulation (calculated monthly) is also required.
Office. The company must maintain a physical office in Cyprus.
Experienced executives. At least three years of experience in the payment field is required. Management must have an impeccable reputation and provide a clean criminal record.
Board of Directors. At least two directors must be Cypriot residents, with a total of at least four board members.
Payment form or agreement with a licensed processing center. Compliance with PCI DSS (for card operations), PSD2 (for open banking APIs), and GDPR (data protection) is mandatory. Data must be stored on servers within the EU (preferably in Cyprus).
Staff. The company must employ officially hired local personnel.
Developed KYC/AML policy. Must be approved by MOKAS (the Cyprus financial intelligence unit).
MLRO. A dedicated compliance and risk assessment officer is mandatory.
Audit. The company must have an on-staff auditor who is a licensed Cypriot resident.
Financial transparency. Annual audit by a CBC-approved auditor. Liquidity ratio must be maintained at no less than 1:1. Client funds must be insured (at least €100,000 in case of bankruptcy).

Documents Required to Obtain an EMI License in Cyprus

Business plan;
3-year financial plan;
Description of activities;
Documentation on anti-fraud and AML/CFT procedures, risk management;
Questionnaire, criminal record statement, bankruptcy clearance certificate – completed for each shareholder and director;
Additional documentation package is prepared by our specialist based on details about the corporation, its beneficiaries, business area, etc.

Document collection is performed without client participation. The package includes translation and notarization of all documents. From the time of submission to the Central Bank of Cyprus, it may take 4 to 6 months to receive a response.

EMI license acquisition features in Cyprus

To obtain an EMI license in Cyprus, a company must meet the following conditions:

The company’s head office must be in Cyprus, and it must be registered in the jurisdiction;
The company must have a fraud prevention officer, risk manager, and accountant;
The board of directors must include at least four individuals (two of whom must be executive directors), the majority of whom must be Cypriot residents and meet CBC requirements;
The company must have external and internal auditors and third-party legal consultants;
Minimum authorized capital must be €350,000.

This information provides a general overview of the registration process and may vary in specific cases. For more details, consult with our specialist.

Our Services for Obtaining an EMI License in Cyprus

Law and Trust International offers full legal support to obtain an EMI license in Cyprus in compliance with all legal requirements. We provide a wide range of services for every client. L&T International will assist in the following areas:

Highly qualified legal support;
Preparation and filing of necessary documents and applications;
Legal support and representation in drafting contracts with third parties (auditors, service providers);
Company and trademark registration;
Opening of a bank account in Cyprus;
Issuing legal opinions for payment systems, crypto, and banking operations.

If you are ready to obtain an EMI license in Cyprus, contact our lawyers for a free consultation.

FAQ

Can we use white-label banking software from the US/China?

Yes, but under certain conditions. The software must be certified with European standards (ISO 27001, PCI DSS). The source code will be checked by the CBC for backdoors. A support agreement with a local Cyprus-based tech provider is required.

Can an EMI license be combined with investment activity?

Technically, yes. However, a separate CySEC license is required since EMI alone does not authorize investment of client funds.

Can an EMI license be granted if a founder is a former bank employee dismissed for violations?

The Central Bank of Cyprus (CBC) conducts a thorough background check on all key company members. If one of the founders is a former bank employee dismissed for violations, this will significantly complicate the licensing process—even if the incidents occurred more than five years ago, the regulator will take them into account.
The CBC places high importance on the professional reputation of applicants, particularly in the financial sector. It is therefore advisable to include only individuals with impeccable professional histories in the company’s management and ownership structure.