Luxembourg Electronic Money Institution License_Guideline

Luxembourg Electronic Money Institution License

Electronic money institutions and payment institutions are governed by the Law of 10 November 2009 on payment services (“the PSL”). The PSL was amended by the Law of 20 July 2018 which transposed Directive (EU) 2015/2366 of 25 November 2015 on payment services in the internal market (PSD2).

Permitted Activities

An Electronic Money Institution (EMI) is a legal person that has been granted authorization to issue electronic money as per article 24-2 (Luxembourg undertakings) or 24-16 (non-EU undertakings) of the Law. EU EMs duly authorized in their home member state and acting through a branch, an agent or free provision of services, do not need formal authorization from Luxembourg authorities as they benefit from EU rules on freedom of provision of services (article 24-15 of the Law).

In addition to issuing electronic money, electronic money institutions shall be entitled to engage in any of the following activities:

  1. the provision of payment services;
  2. the granting of credit related to payment services;
  3. the provision of operational services and closely related ancillary services in respect of the
  4. issuing of electronic money or of the provision of payment services referred to in point (a);
  5. the management of payment systems;
  6. business activities other than issuance of electronic money, having regard to the applicable
  7. “EU”9 and Luxembourg law.

Legal Requirements



Element Requirement(s)
Entity Requirements
  • Authorisation may only be granted to a legal person incorporated under Luxembourg law, which must be established in the form of a public limited company (société anonyme – SA).
Director’s Requirements The licensee will need at least 2 (two) natural person Fit and Proper Directors of any jurisdiction.
Shareholder requirements
  • An EMI entity will need at least one shareholder
  • Corporate shareholding is also allowed.
  • The Auditor must be a réviseur d’entreprises agréé (approved statutory auditor) approved by CSSF
  • Any change in the réviseurs d’entreprises agréés (approved statutory auditors) shall be authorised in advance by the CSSF
Minimum Capital Requirements
  • The PSL Law requires a minimum capital of EUR 350,000 for an Electronic Money Institution.
  • The Company must at all times respect the own funds as set out by the Law

Ongoing Obligations

  1. EMIs shall draw up their annual accounts and, if appropriate, their consolidated accounts in accordance with the law of 19 December 2002 concerning the trade and companies register, as well as the accounting and annual accounts of companies, as amended, “the law of 10 August 1915 on commercial companies, as amended,”6 and Regulation (EC) No 1606/2002 of the European Parliament and of the Council of 19 July 2002 on the application of international accounting standards.

About Valsen Fiduciaries

Valsen Fiduciaries is a licensed independent global service provider of a broad range of fiduciary, administrative, legal, corporate secretarial and support services.

    1. Company formations and Administration
    2. Assistance with Bank Account opening
    3. Collective Investment Setup and Administration
    4. Intellectual Property Registrations and Maintenance.
    5. Trusts and Foundations setup and administration
    6. Online Payment Gateway Solutions
    7. Banking Licenses and PSP, E-Money, E- Wallet Licenses
    8. Yacht and aircraft registrations.
    9. Cryptocurrency Solutions (ICO, STO, Crypto Exchanges etc)

The Valsen Advantage

  • We will advise you on the optimal legal structure for your requirements, size, expectations and circumstances. We have extensive knowledge of a wide range of securities dealer licenses in all major jurisdictions.
  • Valsen will assist to complete every form for each process in the best way we know how (Based on our many years’ experience with various regulators and service providers across the world)
  • We are very hands on in the post filing period checking with re regulator and service providers and updating you regularly. Any queries raised by the regulators and service providers during processing will be quickly synthesized by us and we shall craft the right responses to move the process forward fast.
  • We have a full in-house compliance support for all compliance requirements with the regulator and service providers

Our Contact Details

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  • Tel: +248 4321018
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