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Averium ConsultingAverium

EMI and payment institution licences in Estonia and the EU

Launching a regulated payments business takes more than a strong product: it takes the right licence, in the right jurisdiction, supported by a clean and well-prepared application that a supervisor will actually approve. We prepare payment, e-money and crypto-asset businesses in Estonia and across the EEA for that test: an EMI licence or a payment institution authorisation under PSD2 and the E-Money Directive, a CASP authorisation under MiCA, the compliance gap analysis that comes before them, and the AML and KYC framework the application has to describe.

Most of the work is regulatory readiness rather than forms. We map the business model to the licence it actually needs, from e-money institution (EMI) to payment institution (PI / API / SPI) and crypto-asset service provider (CASP), run a gap analysis against what the supervisor will test, build the compliance framework, the safeguarding arrangements and the governance the file describes, help you find and hire the qualified personnel, prepare all the necessary documentation, and support the entire process through to authorisation. Licences outside that core, such as gambling or investment-firm licences, and applications in jurisdictions outside Estonia, are delivered with partner law firms in the jurisdiction concerned, under one engagement.

List of jurisdictions

You can view the full list of jurisdictions where this service is provided.

How a licensing project works:

01

Scoping and jurisdiction selection

We map your business model to the right licence type and to the jurisdictions where it can realistically be obtained and passported across the EEA.

02

Company and substance setup

Incorporation, governance, local substance and the qualified personnel a regulator expects – directors, an MLRO and other key function holders.

03

Documentation and compliance framework

Business plan, financial projections, AML/KYC policies, safeguarding arrangements and the full application file, prepared to the regulator's standard.

04

Submission, regulator dialogue and authorisation

We file the application, manage the back-and-forth with the supervisory authority, and steer the project through to the licence being granted.

Services we provide in EMI, payment and crypto-asset licensing:

  • EMI (e-money institution) licence applications
  • PI / API / SPI (payment institution) licence applications
  • Crypto-asset service provider (CASP) licensing under MiCA
  • Regulatory readiness assessments under PSD2, the E-Money Directive and MiCA
  • Compliance gap analysis against what the supervisor will test
  • Preparation of the full application file and supporting documentation
  • AML/KYC policies, safeguarding and the compliance framework
  • Assistance with finding and hiring qualified personnel (directors, MLRO, key staff)
  • Liaison with regulators and support throughout the authorisation process
  • Gambling, investment-firm and other licences, and applications outside Estonia, delivered with partner law firms in the jurisdiction concerned

Frequently asked questions

That is the first question we answer, in writing, before any application starts. It turns on what the product does – whether you hold client funds, execute orders, issue instruments, or only introduce customers to someone who does – and not on how the company describes itself. Where an activity sits outside the regulated perimeter we say so; it is the cheapest advice we give.

The one whose supervisor understands the model, whose local substance requirement you can genuinely meet, and whose banking market will service the result. Comparing application fees is the least useful way to choose. We map the activity against the perimeter in each candidate jurisdiction before recommending one.

A business plan the regulator can test, a governance and compliance framework with named people behind it, fit-and-proper files for those people, evidence of capital, and answers to the supervisor’s follow-up questions. We draft and assemble the file and handle the correspondence; what we need from you is the commercial reality of the business, honestly described.

Most refusals are decided long before the decision letter, in the quality of the file and the substance behind it. Where a refusal has already happened the work is remediation: establishing what the supervisor actually objected to, fixing it, and deciding whether to re-apply here or elsewhere. We take those cases, including files we did not submit.

A test of the business against the authorisation before the authorisation is applied for: whether the activity needs a licence at all and which one, whether the governance, the people, the AML and KYC framework, the safeguarding and the capital exist or are only planned, and what has to change before a supervisor sees the file. You receive it in writing, with the gaps ranked, and the application work is then scoped against it.

Describe your task. We reply within one business day.

Averium prepares payment, e-money and crypto-asset businesses for licensing in Estonia and across the EEA, with partner law firms where another jurisdiction's law applies, and will be glad to guide you from the first scoping call to the licence in hand.

Alina Grigorjeva

Alina Grigorjeva

Founder and Head of Legal Practice

Aleksejs Pravotorovs

Aleksejs Pravotorovs

Head of Operations

Andres Aarelo

Andres Aarelo

Head of Business Development

Dmitri Grigorjev

Dmitri Grigorjev

Head of Finance and Tax

Alongside the heads of practice areas, three senior lawyers handle corporate, regulatory and dispute matters.

Describe
your task

Tell us what needs to be done and by when. We reply within one business day to arrange a scoping call.