Regulations for EMI license in Cyprus

The Central Bank of Cyprus (CBC), under the Electronic Money Laws of 2012, acts as the regulatory and supervisory authority for Electronic Money Institutions (EMIs) in Cyprus. Its objectives include:

  • Strengthening Cyprus’s reputation as a key financial center within the European Union, promoting it as a safe and reliable hub for financial transactions.
  • Regulating and overseeing electronic money services, ensuring compliance, transparency, and fairness among participants.
  • Enforcing strict adherence to the Electronic Money Laws and other relevant regulations, setting and implementing high regulatory standards to maintain the integrity of the financial market.
  • Issuing licenses to EMIs and ensuring their operations align with the regulatory framework, as well as revoking licenses when necessary to safeguard market compliance.
  • Protecting consumers and investors through diligent regulatory practices, enhancing the security and trustworthiness of the EMI sector in Cyprus.

Taxation of EMI companies in Cyprus

  • Corporate income tax is set at a competitive rate of 12.5% (one of the lowest in Europe)
  • Dividends are not subject to withholding tax
  • VAT – 19%

Types of EMI licensing in Cyprus

License typeDescription of license
EMI License
  • Comprehensive financial services including issuance of electronic money, execution of payment transactions, management of electronic payment systems, and provision of operational risk management solutions.
Money Remittance License
  • Offers basic payment services such as executing payment transactions, issuing and/or acquiring payment instruments, and executing credit transfers, with a primary focus on direct dealings with customers’ payment accounts.
Payment Processing License
  • Includes all services of the limited range license plus money remittance, and the execution of payment transactions initiated via telecommunication devices, digital or IT device, suitable for businesses that engage in broader payment services.
Full Payment Institution License
  • Covers all services of the standard PI license and extends to operating payment systems, providing foreign exchange services, safekeeping activities, and the storage and processing of payment transaction data, catering to large-scale payment service providers requiring comprehensive operational capabilities.

With EMI license in Cyprus you can provide following services:

  • services enabling cash to be placed on a payment account as well as all the operations required for operating a payment account
  • services enabling cash withdrawals from a payment account as well as all the operations required for operating a payment account
  • execution of payment transactions, including transfers of funds on a payment account with the payment service provider of the payment service user or with another payment service provider: execution of direct debits, including one-off direct debits, execution of payment transactions through a payment card or a similar device and/or execution of credit transfers, including standing orders
  • execution of payment transactions where the funds are covered by a credit line for a payment service user: execution of direct debits, including one-off direct debits, execution of payment transactions through a payment card or a similar device and/or execution of credit transfers, including standing orders
  • issuing and/or acquiring of payment instruments
  • money remittance
  • execution of payment transactions where the consent of the payer to execute a payment transaction is given by means of any telecommunications terminal equipment, digital or IT device and the payment is made to the telecommunications network or IT system operator, acting only as an intermediary between the supplier of the goods or services and the payment service user
  • Account information services
  • Issuance of e-money

Overview of requirements to obtain EMI license in Cyprus

  • Ensure legal operation by incorporating under the Cyprus Companies Act
  • Appoint two executive directors (Cyprus residents), two non-executive directors, a compliance officer, back office staff, and an IT specialist
  • Contribute required share capital for licensing
  • Maintain sufficient capital to cover business operations (salaries, marketing, operational expenses) for at least one year
  • Maintain high standards of integrity and professional conduct across all team members, including directors, compliance staff, and IT personnel
  • Establish a physical office in Cyprus to reinforce the firm’s commitment to local compliance
  • Set up a corporate bank account and a safeguarding account to manage financial transactions and protect customer funds

Estimated time frames to obtain EMI license in Cyprus

Business name verification

1-3 days

Company formation

up to 2 weeks

Documents preparation

1 month

PI / EMI license obtainment from CBC*

3-6 months

*The timeline also depends on the workload of CBC and any clarifications and queries that CBC may request in relation to the application.

Legal services for obtaining EMI license in Cyprus

Basic Package

25,000 EUR initial set up

  • Turnkey company formation
  • Legal address for 1 year
  • Corporate documents
  • Due diligence for shareholders and key directors
  • Overview of the business plan
  • Overview of financial forecasts
  • Overview of an organizational structure
  • Analysis of the internal documents
  • Applying for the license

Registration of the EMI / PI licensed company under the minimum regulatory requirements

Additional services on request

  • Preparation of individual business plan
  • Preparation of required documents for the licensing
  • Accounting services
  • Assistance in opening bank account, including segregated and safeguard accounts
  • Connection with SEPA system
  • Connection with SWIFT
  • Connection with card issuance programme
  • Apostilled corporate documents
  • Introduction to confirmed software provider
  • Legal support

Ready-Made solution

available on request

  • Registered company
  • Legal address for 1 year
  • No debts, no liabilities – clean company
  • Active license
  • Corporate documents
  • Assistance with transfer of ownership

Edgar Mironov

Head of FinTech Projects

Requirements for EMI licensing in Cyprus

List of required documents

  • CVs and Qualifications: Submission of CVs for shareholders and team members to demonstrate their expertise and suitability for the payment and electronic money industry.
  • Source of Funds/Source of Wealth (SoF/SoW): Documentation for shareholders holding more than 10% of shares, verifying the origins of their funds and wealth.
  • Business Plan: A comprehensive document detailing the company’s strategic objectives, service offerings, market analysis, and financial forecasts.
  • License Application: Completion and filing of the official application form for the PI or EMI license in Cyprus.
  • Internal Policies and Manuals: Development of internal operational, compliance, and client management manuals.
  • IT Infrastructure: Documentation of IT structure, including agreements with software providers or details of proprietary software.
  • KYC/AML Agreements: Agreements with providers for Know Your Customer (KYC) and Anti-Money Laundering (AML) services.
  • Organizational Structure: An outline of the company’s structural hierarchy.
  • Articles of Association/Memorandum: Submission of foundational corporate documents.
  • Programme of Operations Scheme: A detailed plan describing operational processes.
  • Draft Service Agreements: Preparation of preliminary service agreements for clients.
  • ICT and Security Management: Documentation of information and communications technology and security management protocols.
  • Cloud Computing Services: Details of cloud service providers and agreements.
  • Methods of Safeguarding: Strategies to protect client funds and data.
  • Civil Liability Insurance: Evidence of sufficient insurance coverage to manage risks.
  • Business Address Approval: Confirmation of a physical office in Cyprus, validating the operational base and compliance with local regulations.
  • Non-criminal Record: Submission of a clean criminal record certificate for significant shareholders and team members.

Business premises requirements

  • To obtain a EMI license in Cyprus it is necessary to establish a physical office in Cyprus to house staff, support data management, and solidify the operational foundation, as mandated by the regulatory authority.

Share Capital and Government Fees

  • Minimum Share Capital: For obtaining PI license in Cyprus the minimum share capital is 20 000 EUR and for obtaining full EMI license 350 000 EUR.
  • Government Fees: The application fees for PI or EMI license in Cyprus equals to 5000 EUR and additional 1000 EUR in accordance to Directive 473 (2020).

Bank account requirements

  • Safeguarding Account: Detailed arrangements for the establishment of a safeguarding account with an EU credit institution to manage funds separately from those of non-electronic money holders. This may include reliance on the CENTROlink system for account setup, pending final licensing approval.
  • Operational Bank Accounts: Necessary for managing daily operational expenses and transactional purposes, facilitating the processing of customer transactions through current accounts.
  • Current Account: For transactional purposes, allowing for the receipt and sending of payments related to the services offered.

Personnel Requirements

  • Executive Directors: At least two executive directors who are Cyprus residents must be appointed. Responsible for the day-to-day management and operational decisions of the company, ensuring the implementation of strategic plans and achieving organizational goals.
  • Non-executive Directors: Appointment of two non-executive directors. Providing independent oversight and strategic guidance, without involvement in the daily operations of the company.
  • Compliance Officer: Designation of a compliance officer to oversee regulatory compliance.
  • Back Office: Sufficient back office support to handle administrative and operational tasks.
  • IT Specialist: Employment of an IT specialist to manage and secure the IT infrastructure.

Not sure about the number of staff you need to employ for your PI/EMI project? Contact Legalaes experts to define the right personnel structure for your business model.

Roadmap of obtainment Payment license in Cyprus

For more detailed road map of the project and commercial offer – get in touch with our Fintech professional.

Edgar Mironov

Head of FinTech Projects

1

Documentation Preparation

Beginning by collecting and preparing necessary documentation from shareholders and team members, including passports, non-criminal records, Source of Funds/Wealth (SoF/SoW), and relevant educational certifications. Assisting throughout, we ensure all participants meet the stringent standards required for operating within the Cyprus financial system.

2

Company Incorporation

Assisting in incorporating the company under the Cyprus Companies Act, clearly defining the shareholding structure and detailing the percentage of shares held by each shareholder. This establishes the legal foundation for the business.

3

Application Pack Preparation

Preparing and organizing a comprehensive application pack, including all necessary documents and fulfilling regulatory requirements to streamline the submission process to the Central Bank of Cyprus (CBC).

4

Local Team HR Services

Managing the HR processes for establishing the local team, including executive directors and compliance officers, ensuring they are equipped and knowledgeable about Cyprus’s regulatory environment.

5

Application Submission

Assisting in submitting the completed application along with the documentation pack to the CBC, officially initiating the licensing process.

6

Bank Account and Safeguarding Setup

Beginning to set up a bank account and a safeguarding account, ensuring compliance with regulatory mandates to protect customer funds.

7

Regulatory Follow-Up

Providing continuous support in addressing any inquiries or requests for additional information from the CBC, typically involving multiple rounds of communication to ensure compliance with all regulatory concerns.

8

License Approval

Supporting the process of receiving approval from the CBC, facilitate the initial board meeting to formalize operational procedures, and help secure premises for the company’s operations to establish a strong business presence in Cyprus.

9

Finalizing Bank and Safeguarding Accounts

Finalizing the establishment of bank and safeguarding accounts with payment institutions, ensuring all financial infrastructure is in place prior to license operation.

10

Operational Launch and Additional Services

Supporting the start of operations under the new license, including the integration of additional services such as SWIFT applications and card issuing through partnerships with major networks like Mastercard and Visa.

Advantages of the EMI license in Cyprus

Links for legislation related to EMI business in Cyprus

Establishes the legal framework for the issuance and operation of electronic money institutions within the EU, defining the core principles and operational standards for EMIs.

Sets out the regulatory requirements for payment services across the EU, focusing on making payments safer, more accessible, and enhancing consumer protection.

Governs the formation, registration, and operation of companies in Cyprus, ensuring that businesses comply with local corporate governance standards.

Cyprus’s primary legislation for anti-money laundering and combating the financing of terrorism, aligning local laws with international standards.

Includes provisions for the operation of credit institutions within Cyprus, covering aspects relevant to EMIs concerning credit transfers and related financial services.

Supplements Directive (EU) 2015/2366 regarding regulatory technical standards for the cooperation and exchange of information between competent authorities.

Cyprus EMI license regulatory body - Central Bank of Cyprus

These descriptions provide a quick overview of each act’s main purpose and its role in the regulatory landscape for obtaining EMI license in Cyprus.

FAQ about EMI license in Cyprus

1. Why choose Cyprus for setting up your PI/EMI project?

Cyprus offers several advantages for setting up a Payment Institution (PI) or Electronic Money Institution (EMI). As jurisdictions like Lithuania and the UK become more saturated with licensees, Cyprus remains less crowded, increasing the likelihood of license approval. Coupled with one of the lowest tax rates in the EU, passporting rights, and a straightforward licensing process, Cyprus is an excellent destination for launching your E-money venture.

2. Who can apply for a Cyprus PI/EMI License?

The ideal candidate for the Central Bank of Cyprus (CBC) would be companies with prior licensing and experience in other countries and those that use their own proprietary software. However, Cyprus is open to newcomers in the field as long as they hold the necessary certifications/education and maintain an impeccable reputation.

3. How long does it take to get licensed by the CBC?

Preparing the necessary documentation and incorporating a company can take up to 4 weeks. Upon submission, the assessment period by the CBC ranges from 12 weeks (assuming a complete application) to 26 weeks for an EMI, particularly if the CBC requests additional documentation.

4. I have a license in another country; would it be useful?

Yes, holding a license in other markets is seen as a sign of compliance with high standards. Such credentials make applicants appear more reliable, potentially reducing the time it takes to process a new application in Cyprus.

5. Should I establish an office in Cyprus?

Yes, establishing a local office in Cyprus is essential. It serves as a secure location for storing documentation and provides a workspace for your staff, which is a requirement for regulatory compliance.

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