EMI licence in CyprusOverview
In Cyprus, electronic money institutions are authorised and supervised by the Central Bank of Cyprus under the Electronic Money Laws of 2012 to 2018, which transpose EMD2. Payment services offered alongside e-money fall under the Cypriot laws implementing PSD2. CySEC, which licenses investment firms and crypto-asset service providers, does not license EMIs. The CBC also applies its own directives on governance, safeguarding and reporting, and the Cypriot AML/CFT law applies in full.
In December 2024 the CBC adopted a comprehensive strategy for the sector, developed with international consultants, and created a dedicated Directorate for the Supervision of EMIs and PIs. At the time, it supervised 26 EMIs and 11 payment institutions. The strategy aims at sustainable growth, better licensing processes and more risk-based supervision, and it has translated into concrete changes to how applications are handled.
From 3 August 2026, every prospective EMI or PI must pass through a pre-application exploratory stage before filing a formal application. The applicant submits specified information on the business, ownership and management, pays a non-refundable EUR 5,000 fee, and the CBC uses this stage to flag issues early, particularly on good repute. The CBC may require an enhanced due diligence report from an independent specialist firm, either at this stage or during the formal assessment. The formal application fee has risen from EUR 5,000 to EUR 10,000, and applications left inactive after unanswered CBC requests are treated as withdrawn.
The CBC expects real substance: management, compliance and AML functions operating from Cyprus, with appropriate premises and staff, rather than a nominal presence. Capital is EUR 350,000 at authorisation, with own funds thereafter of at least 2% of average outstanding e-money and PSD2 methods for other services. Applicants should also factor in PSD3, under which EMIs become payment institutions authorised to issue e-money and existing licences must be re-authorised within the transition window.
Key benefits
- Euro-area home state with EEA passporting from a single licence
- English widely used in business, legal and regulatory communication
- A clearer, staged licensing process that surfaces regulatory concerns before full costs are incurred
- Dedicated CBC directorate focused solely on EMIs and payment institutions
- Established professional services market for audit, legal and compliance support
- Competitive corporate tax framework within EU rules
Requirements
- Cypriot company with registered and head office in Cyprus
- Paid-up initial capital of at least EUR 350,000 from verifiable sources
- Ongoing own funds of at least 2% of average outstanding e-money
- Fit and proper board and key function holders, with local executive management
- Good repute and financial soundness of qualifying shareholders and beneficial owners
- Compliance officer and AML compliance officer based in Cyprus, with an operational AML/CFT function
- Safeguarding through segregated accounts, secure low-risk assets, or insurance or guarantee, with reconciliations
- Governance meeting CBC directives, including the four-eyes principle and internal control functions
- ICT and operational resilience controls aligned with DORA
- Credible business plan and three-year financial projections
Licence options & capital
Pre-application exploratory stage
EUR 5,000 fee
Mandatory since 3 August 2026. The CBC reviews key information on the business and its people and may require an enhanced due diligence report before a formal application proceeds.
Full EMI authorisation
EUR 350,000 initial capital; EUR 10,000 application fee
E-money issuance and PSD2 payment services, passportable across the EEA, assessed within a three-month statutory period from a complete file.
Payment institution alternative
Where the model does not require holding e-money balances, a payment institution licence may be a lighter route under the same CBC process.
Step-by-step process
- 1
Structuring and readiness
We assess the model, ownership and people against CBC expectations and prepare information for the exploratory stage.
- 2
Exploratory stage
The pre-application submission is filed with the EUR 5,000 fee, and the CBC's observations are addressed, including any enhanced due diligence requirement.
- 3
Incorporation and substance
The Cypriot company is formed, capital is paid in, and local management, compliance staff and premises are secured.
- 4
Formal application
The full file, policies and personal questionnaires are submitted with the EUR 10,000 fee.
- 5
Assessment and interviews
The CBC reviews the file, raises questions and may interview management; prompt, complete responses keep the process moving.
- 6
Authorisation and passporting
Following approval, safeguarding accounts and passport notifications are arranged before launch.
Typical documents
- Exploratory-stage information pack and, where required, enhanced due diligence report
- Application form and payment of the application fee
- Memorandum and articles of association
- Business plan, programme of operations and financial projections
- Evidence of initial capital and source of wealth and funds
- Fit and proper questionnaires, CVs and criminal record certificates
- Group and ownership structure to ultimate beneficial owners
- Safeguarding, governance, risk management and internal control policies
- AML/CFT manual and business-wide risk assessment
- ICT security, business continuity and outsourcing documentation
How Legal Wealth helps
Legal Wealth prepares clients for the Central Bank of Cyprus's staged process from the outset, so that ownership, source of wealth and management credentials are clear before the exploratory submission. We coordinate incorporation, local substance, safeguarding banking and AML infrastructure, handle sensitive personal information discreetly, and plan for ongoing supervision and the transition to PSD3. Contact info@legalwealthglobal.com to discuss your project in confidence.
Enquire with Legal WealthFrequently asked questions
What changed in Cyprus in 2026?
From 3 August 2026 a pre-application exploratory stage is mandatory, with a non-refundable EUR 5,000 fee, and the formal application fee increased to EUR 10,000. The CBC may also require an enhanced due diligence report from an independent firm.
Is CySEC or the Central Bank the regulator?
The Central Bank of Cyprus authorises and supervises EMIs and payment institutions. CySEC regulates investment firms and crypto-asset service providers.
How long does the process take?
The formal assessment has a three-month statutory period from a complete file, paused by information requests. With the exploratory stage and preparation, clients should plan for at least six to twelve months.
What substance is required?
The CBC expects senior management, compliance and AML functions to operate from Cyprus with suitable premises and staff. A purely nominal presence will not satisfy the regulator.
Can a Cyprus EMI serve clients across Europe?
Yes. Once authorised, the institution can passport services to other EEA states through notifications made via the CBC.
How much capital is needed?
At least EUR 350,000 paid up at authorisation, with ongoing own funds of at least 2% of average outstanding e-money, plus sufficient working capital for the business plan.
Last reviewed: 2026-10. Requirements, fees and timelines change. Information is general, reviewed on the date shown, and is not legal or tax advice.
