EMI licence in LatviaOverview
Electronic money institutions in Latvia are licensed by Latvijas Banka under the Law on Payment Services and Electronic Money. Latvijas Banka took over the functions of the former Financial and Capital Market Commission at the start of 2023 and now combines central banking with licensing and supervision. The licensing framework is supported by Latvijas Banka regulations on the application format (No 270), information on shareholders and officers (No 241), reporting (No 244) and professional liability insurance for account information and payment initiation services (No 269).
A licensed EMI needs minimum own funds of EUR 350,000, plus ongoing capital calculated under the Law, and must evidence both the capital and its origin. Management must have adequate education and experience, and both management and shareholders holding 10% or more must be of good repute without a criminal record. Applicants submit a three-year business plan, safeguarding measures for user funds, internal control and risk procedures, an IT security policy, and AML/CFT and sanctions rules accompanied by Latvijas Banka's AML/CFT controls checklist.
The process is clearly staged. A free, optional consultation is available before filing, with responses within about 30 days. On submission, Latvijas Banka checks completeness within 15 working days and assigns a project manager; the substantive assessment then runs for three months, extendable if information is insufficient. Once licensed, the institution is published on Latvijas Banka's website and in the EBA register and is assigned a supervisory curator. Published fees are EUR 5,000 for the application, reduced to EUR 450 where only an innovative service is offered, and an annual supervision fee of EUR 7,000 plus up to 1.4% of gross EMI income, capped at EUR 100,000.
For narrow domestic models, Latvia also offers registered EMI status: a closed e-money system limited to Latvia, with average e-money in circulation not exceeding EUR 2 million, no minimum capital requirement and a EUR 2,500 application fee. Firms that outgrow EMI status can also consider Latvia's specialised bank licence. Under PSD3, Latvian EMIs will become payment institutions authorised to issue e-money and will need re-authorisation within the transition period.
Key benefits
- Transparent published fees and a defined review timetable
- Free pre-application consultation and a dedicated project manager during assessment
- Reduced application and supervision fees for innovative-only services
- EEA-wide passporting from a Latvian licence
- Registered EMI route for small, closed, domestic e-money schemes
- Integrated regulator, with central bank and supervisory functions under one roof
Requirements
- Latvian company with management board and head office in Latvia
- Minimum own funds of EUR 350,000 with evidence of origin
- Ongoing capital requirement calculated under the Law on Payment Services and Electronic Money
- Board and council members with adequate education and professional experience
- Good repute and clean criminal record for management and shareholders of 10% or more
- Safeguarding measures for user funds in line with the Law
- AML/CFT and sanctions internal rules, tailored risk assessment and a responsible AML officer
- Internal control, risk management and accounting procedures
- IT security, incident management, sensitive payment data controls and business continuity plans
- Professional liability insurance or bank guarantee where AIS or PIS are provided
Licence options & capital
Licensed EMI
EUR 350,000 own funds; EUR 5,000 application fee
Full e-money issuance and payment services, passportable throughout the EEA, with a three-month substantive review after the completeness check.
Licensed EMI – innovative-only service
EUR 450 application fee
Where the applicant offers only an innovative electronic payment or e-money service, the application fee is reduced and the supervision fee is EUR 1,000 a year for three years after licensing.
Registered EMI
No minimum capital; average e-money up to EUR 2 million
Closed-system, Latvia-only status for issuers offering only payment instrument issuance or money remittance, with a EUR 2,500 application fee.
Step-by-step process
- 1
Consultation
An optional, free consultation with Latvijas Banka clarifies licensing questions before filing; responses usually take up to 30 days.
- 2
Company, people and capital
The Latvian company is incorporated, own funds are paid in and evidenced, and management, AML officer and key staff are appointed.
- 3
Submission
The application is filed in the format of Regulation No 270 with the application fee; completeness is checked within 15 working days.
- 4
Substantive assessment
A project manager is assigned and the three-month review begins, with information requests answered promptly to avoid extension.
- 5
Licence decision
Latvijas Banka grants or refuses the licence and publishes it on its website and in the EBA register.
- 6
Supervision and passporting
A supervisory curator is assigned, reporting begins and EEA passport notifications can be made.
Typical documents
- Application in the format of Latvijas Banka Regulation No 270
- Shareholder structure and origin of funds information
- Programme of operations and three-year business plan with forecasts
- Evidence of initial capital
- Safeguarding measures for user funds
- Internal control, risk management and accounting procedures
- AML/CFT and sanctions rules, risk assessment and completed AML/CFT controls checklist
- Organisational structure, outsourcing, agents and branches description
- CVs, education evidence and criminal record statements for board, council, AML officer and key staff
- IT security, incident management, business continuity and sensitive payment data policies
How Legal Wealth helps
Legal Wealth helps clients use Latvia's transparent process to best effect: preparing focused questions for the free consultation, structuring ownership and capital evidence, and assembling management and AML functions that meet Latvijas Banka's expectations. We coordinate the Regulation No 270 file, manage correspondence discreetly, and help clients choose between licensed and registered status or, later, a specialised bank licence. Contact info@legalwealthglobal.com to discuss your project in confidence.
Enquire with Legal WealthFrequently asked questions
How long does a Latvian EMI licence take?
Latvijas Banka checks completeness within 15 working days and then conducts a three-month substantive review, which can be extended if information is insufficient. Preparation time comes on top.
What are the official fees?
EUR 5,000 to examine a licensed EMI application, or EUR 450 for innovative-only services. Annual supervision costs EUR 7,000 plus up to 1.4% of gross EMI income, capped at EUR 100,000, or EUR 1,000 a year for three years for innovative-only institutions.
What is a registered EMI?
A Latvia-only status for closed e-money systems with average e-money in circulation up to EUR 2 million. There is no minimum capital requirement, but management and legal address must be in Latvia and services cannot be offered abroad.
Is the pre-application consultation free?
Yes. Latvijas Banka offers free consultation before submission, with responses usually within 30 days depending on the questions.
What AML documentation is expected?
Internal AML/CFT and sanctions rules, a business-specific risk assessment, a named responsible person, and Latvijas Banka's completed AML/CFT controls checklist, in line with Annex 13 of Regulation No 270.
Can a Latvian EMI later become a bank?
Latvia offers a specialised bank licence for firms that want to take deposits or lend, which some EMIs consider as they scale. It involves a separate, more demanding authorisation.
Last reviewed: 2026-10. Requirements, fees and timelines change. Information is general, reviewed on the date shown, and is not legal or tax advice.
