Payment, e-money and crypto licences in Europe for companies from outside the EU
You run a payments, e-money or crypto business outside the EU and want EU customers. EU law sets the capital, the legal deadlines and the passport, while each country picks the authority, the fees and the language of the file. This guide compares 15 countries and links each rule to its official text.
Fintech founders and groups with no licence in the EU
Payment institutions (PI), e-money institutions (EMI) and crypto-asset service providers (CASP) under MiCA.
Payment, e-money and crypto firms from abroad
Founders and groups based in the US, the UK, the Gulf, Turkey or India that want to offer payments, e-money accounts or crypto services to EU customers.
Subsidiaries and cross-border plans
Groups that set up an EU subsidiary to hold the licence and passport it, the usual profile of PI and EMI applicants in Ireland (Central Bank of Ireland). And EU-licensed firms looking at Poland, reachable for crypto by passport, or at the UK, where an EU licence is not enough.
What each country adds to the EU rules
Authorities, fees and deadlines found in official sources on 6 November 2026, each with its link.
| Country | What differs there | Guide |
|---|---|---|
| Germany | BaFin, with the Bundesbank, wants two managers (one for a small firm) and refuses a file still incomplete after 12 months (§§ 10 and 11 ZAG); national crypto permissions lapsed by 31 December 2025 (§ 50 KMAG). | On request |
| France | The ACPR decides on an EMI within 3 months of a complete file, after a Banque de France opinion (ACPR); the AMF can take up to 4 months on a CASP, and unlicensed activity carries 2 years in prison and a €30,000 fine (AMF). | On request |
| Netherlands | DNB licenses PIs and EMIs for a €10,400 fee, and the AFM licenses CASPs at €200 per hour of work, capped at €100,000 (fee regulation). | Netherlands guide |
| Spain | The Banco de España decides on a PI or EMI within 3 months, silence means refusal, and the firm enters its special register before starting (RDL 19/2018); the CNMV licenses CASPs (CNMV). | On request |
| Italy | The Banca d'Italia has 90 days at most for a PI or EMI, barring suspension (Banca d'Italia); Consob licenses CASPs and asks a €20,000 contribution to file (Consob). | On request |
| United Kingdom (outside the EU) | The FCA requires a PI to be a UK company with its head office and registered office in the UK, so an EU licence is not enough (PSRs 2017, reg. 6); the crypto application window runs from 30 September 2026 to 28 February 2027, before the regime starts on 25 October 2027 (FCA). | On request |
| Poland | No authority has been designated for CASPs, so no MiCA application can be opened in Poland, and CASPs licensed in another member state serve it through the passport (UKNF position). | On request |
| Ireland | The Central Bank took 763 days on average to authorise a PI or EMI in 2025 and 171 days for a CASP (CBI report), and expects appropriate substance in Ireland (CBI expectations). | Ireland guide |
| Belgium | The FSMA licenses CASPs and had authorised none by 25 June 2026 (FSMA); the NBB handles PIs and EMIs, with national limited statuses, but we found no official guidance on its fees or deadlines (NBB). | On request |
| Sweden | Mostly the EU rules: Finansinspektionen charges SEK 405,000 to examine a PI file and decides within 3 months of a complete, paid file (FI); its crypto page adds nothing national to MiCA (FI). | On request |
| Austria | Mostly the EU rules: the FMA publishes its CASP application form in German only and fees are due whatever the outcome, with no other national specific found (FMA). | On request |
| Portugal | A CASP files with the Banco de Portugal, which passes the file to the CMVM within 2 working days for its opinions on set deadlines (Lei 69/2025). | On request |
| Latvia | Mostly the EU rules: Latvijas Banka has taken MiCA applications since 2 January 2025 and offers free consultations before filing (Latvijas Banka); we found no official guidance on its PI and EMI deadlines or fees. | On request |
| Lithuania | Official sources could not be read yet, so no national rule is stated here; a national e-money licence for restricted activity is reported but not found in an official source, so confirm it with the Bank of Lithuania. | On request |
| Estonia | Finantsinspektsioon charges €3,000 for a CASP application, filed in Estonian through its portal (Finantsinspektsioon), and struck off the old FIU crypto licences on 1 July 2026 (notice). | Estonia guide |
Where a row says mostly the EU rules, the official sources we read add little to EU law.
What EU law fixes for every licence
Capital, legal deadlines and where the company must sit are the same in the 14 EU countries of this guide.
| Licence | EU text | Minimum initial capital | Legal decision deadline |
|---|---|---|---|
| Payment institution (PI) | Directive 2015/2366 (PSD2) | €20,000 for money remittance only, €50,000 for payment initiation, €125,000 for the services in points 1 to 5 of Annex I (art. 7) | 3 months from the complete file (art. 12) |
| E-money institution (EMI) | Directive 2009/110/EC (EMD2) | €350,000 (art. 4), and own funds of at least 2% of average outstanding e-money under method D (art. 5) | See the country table: 3 months in France and Spain, 90 days at most in Italy |
| Crypto-asset service provider (CASP) | Regulation 2023/1114 (MiCA) | €50,000, €125,000 or €150,000 by class of service (art. 67 and Annex IV) | 40 working days from the complete file (art. 63) |
A PI licence goes only to a legal person established in an EU member state. Its head office must be in the same state as its registered office, and part of its business must take place there (PSD2, art. 11). A CASP needs a registered office in a member state where it provides part of its services, its place of effective management in the EU and at least one director resident in the EU (MiCA, art. 59).
From application to the whole EU market
The MiCA clock for a CASP, counted in working days, then the passport.
Receipt
The authority acknowledges the application.
Completeness
It checks whether the file is complete.
Decision
It decides on the complete file, then notifies you within 5 working days.
Passport
It forwards your notification, and you can start by the 15th calendar day after notifying.
Source: MiCA, arts. 63 and 65. For a PI, the authority decides within 3 months of receiving the application, or the last missing information. To passport, it sends your notification to the host country within 1 month of a complete file, and the host authority then has 1 month to assess it (PSD2, arts. 12 and 28).
Real waits run longer than the legal clock, which starts once the file is complete. The Central Bank of Ireland took 763 days on average for a PI or EMI in 2025 (CBI report). Plan capital and staff for that wait.
Small national licences stay at home
A country may exempt payment institutions up to €3 million of average monthly transactions (PSD2, art. 32) and e-money institutions up to €5 million of average outstanding e-money (EMD2, art. 9). Neither can be passported to another country.
Reverse solicitation is narrow
A crypto firm outside the EU may serve an EU client without a licence only when that client takes the exclusive initiative. Any solicitation in the EU, by any means, including through a related entity, ends the exemption whatever the contract says (MiCA, art. 61).
What each country still decides
Fees, language, penalties and rules still moving.
EU law fixes the capital, the legal deadlines, the passport and the set-up conditions. Each country keeps the rest, as the table above shows: one authority or two, the application fees, the real processing times, the language of the file and the light national regimes. Fees can stop a file on their own: Sweden rejects an application whose fee has not arrived within 30 days (FI).
Penalties are national: Italy punishes unlicensed crypto services with 6 months to 4 years in prison and a fine of €2,066 to €10,329 (Consob).
The MiCA transitional periods are over
MiCA let existing crypto firms keep working until 1 July 2026 at the latest, and each country could cut that short: 6 months in Latvia, the Netherlands and Poland, 18 months in Estonia, France and Spain (ESMA list). All had ended by November 2026: serving EU clients now takes a MiCA licence, outside reverse solicitation.
Crypto firms that move e-money tokens may need a payment licence too. Since 2 March 2026, the Banca d'Italia requires a CASP that transfers or holds them to be authorised under PSD2 or to work with a payment provider (Banca d'Italia), and 5 Irish CASPs applied for a PI licence before the 1 March 2026 deadline (CBI report). Both rest on an EBA no-action letter we have not read at the source: confirm the position with your authority.
PSD3 and the Payment Services Regulation are not law yet. After a provisional agreement on 27 November 2025 (Council) and a committee vote on 5 May 2026, there was still no plenary vote or publication in the Official Journal on 25 October 2026 (European Parliament). PSD2 and EMD2 still apply.
Do you need an EU company?
To hold the licence, yes. The real choice is the country.
Enough in narrow cases
Your home company cannot hold a PI or CASP licence. It can serve EU crypto clients who come to it on their exclusive initiative, and any solicitation in the EU ends that. In the UK, an EMI can be a foreign company with a UK branch (EMRs 2011, reg. 6).
Formed where you apply
A PI has its head office in the member state of its registered office, with part of its business there. A CASP is run from the EU with at least one EU-resident director. Ireland also expects a board mixing executive, non-executive and independent non-executive directors, with key (PCF) roles approved by the Central Bank (CBI, April 2024).
Pick the country first, then form the company there. A Latvian SIA fits a licence from Latvijas Banka. For a PI licensed elsewhere, the company and its head office sit in that other country. If an EU company is part of the plan, see our pages on forming an EU company as a non-resident and on a Latvian subsidiary for a foreign group.
What Balt Partners coordinates
One contact in Riga for the plan and the calendar. Each filing goes through a licensed local adviser.
Licence route map
Which licence your services need (PI, EMI or CASP), which countries fit, and the capital, fees and legal deadlines in each, in one plan.
Filing with the authority
We list what the authority asks for and bring in a licensed adviser in the country you choose, who handles the filing and the exchanges with the supervisor.
Calendar and passport
Legal clocks, passport notifications and open points to confirm with each authority, in one calendar.
A Latvian company when it fits
A Latvian SIA with its bank account and accounting set-up, when the licence is sought in Latvia or your group needs an EU company there.
Three countries have a full guide so far: Finantsinspektsioon fees and filing in Estonia, Central Bank of Ireland timelines and substance and DNB and AFM licences in the Netherlands.
Questions from non-EU founders about fintech licences
Not directly. PSD2 reserves the payment institution licence to a legal person established in an EU member state, with its head office in the same state as its registered office and part of its business there. A founder from outside the EU forms a company in the chosen country and applies through it. In Ireland, most PI and EMI applicants are groups setting up a local subsidiary.
The legal deadline is 3 months from a complete file. Real times run longer: the Central Bank of Ireland took 763 days on average in 2025 for a PI or EMI, DNB warns that its 3 months are often exceeded, and Germany refuses an application that is still incomplete 12 months after filing.
An e-money institution needs at least €350,000 of initial capital. A payment institution needs €20,000 for money remittance only, €50,000 for payment initiation and €125,000 for the services in points 1 to 5 of PSD2 Annex I. A crypto-asset service provider needs €50,000, €125,000 or €150,000, by class of services.
Yes, through the passport. The home authority sends your notification to the other countries within 10 working days, and you can start there by the 15th calendar day after notifying at the latest. This is how a CASP serves Poland, where no authority has been designated to grant MiCA licences. It does not cover the UK.
Only on reverse solicitation, when the client in the EU takes the exclusive initiative. Any solicitation in the EU, by any means, including through a related entity, ends the exemption whatever the contract says, and it does not let you offer that client new products. The MiCA transitional periods all ended by 1 July 2026.
No. In the UK a payment institution must be a UK company with its head office and registered office there, and an e-money institution must be a UK company or a foreign company with a UK branch. The FCA crypto application window runs from 30 September 2026 to 28 February 2027, before the regime starts on 25 October 2027.