Applying for a permission

Electronic Money Issuer 


The purpose of this page is to make sure that the application process is fully understood.

This section sets out:

  • What an Electronic Money Issuer is and what this regulated activity would allow you to do
  • Authorisation process
  • Agents and Distributors Notifications 
  • Programme Manager Notifications
  • Capital Requirements
  • Additional Information

What is an Electronic Money Issuer and what would this regulated activity allow you to do?

Electronic Money (E–money) is electronically, including magnetically, stored monetary value, represented by an issuer, accepted by a person other than the electronic money issuer. Types of E-money include pre-paid cards and electronic pre-paid accounts for use online.

The authorisation of E-money Issuers falls within the scope of the Financial Services Act 2019. E-money Issuers should ensure that they comply with all subsidiary legislation to the Act. An E-money Issuer can issue and redeem E-money through a proper establishment or through an Agent or Distributor.

There are two types of E-money Issuers:

  • Authorised E-money Issuer; and
  • Registered E-money Issuer.

Both types of E-money Issuers must meet certain standards and provide the necessary information so that the GFSC can monitor and supervise them effectively. Applicants should note that Registered E-money Issuers cannot passport their services.

An E-Money Issuer can provide the following services:

Distribution/Redemption of electronic money

  • Services enabling cash to be placed on a payment account as well as all the operations required for operating a payment account.
  • Two 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 user’s payment service provider 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;
    • 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;
    • execution of credit transfers, including standing orders.
  • Issuing of payment instruments and/or acquiring of payment transactions.
  • Money remittance.
  • Payment initiation services.
  • Account information services.

Application process

Applicants should submit an application pack with all relevant documents. We will not consider an application complete if there are any outstanding documents.

The application pack must consist of: 

  • Application Fee;
  • Application_Form.xlsm;
  • Financial Projections for the next 3 years
    • Stress Test on Financial Projections;
    • Profit and Loss account;
    • Balance Sheet;
  • Regulated Individual Form (for each Regulated Individual);
  • Non-Executive Director Form (for each non-executive director);
  • Controller Form (for each Controller);
  • Business Plan;
  • Risk methodology and framework
  • Supporting Policies and Procedures
  • Details of Source of Wealth/Source of Funds (including final ownership structure, details of capital within the group, how the funding will be provided, access to further funds and 3-year financial statements for companies providing the funding. If an individual will provide more than 10% of the funding, we will require an independently verified statement of wealth); 
  • Busines Continuity Plan; and
  • Any other document the applicant considers the GFSC should take into consideration as part of the application.

Please request cloud access from the Authorisation team in order to submit the application pack. Requests should be sent via E-mail to with the following information in the subject field: ‘Name of Regulated Firm/Applicant – Application’. Paper copies are not required unless indicated by the Authorisation team. 

Please note that we accept signed signature copies sent via e-mail and electronic signatures, which must originate from the Regulated Firm’s/Applicant’s domain.  

Additional Services

Regulated Firms that are already authorised by the GFSC may apply to extend their permission to provide additional financial or professional services. If you are seeking authorisation for additional services, please contact the Authorisation team in order for us to determine what documents are required for submission.

The below sets out an overview of the expected information requested:

  • Application Fee (if applicable);
  • Revised Business Plan;
  • Financial Projections for the next 3 years, clearly identifying the impact of the additional business:
    • Profit and Loss account
    • Balance Sheet
    • Stress Test on Financial Projections
  • Regulated Individual Form (for any new individual carrying out a Regulated Individual function);
  • Controller Form (for any new Controllers within the structure); and
  • Any other document the applicant considers the GFSC should take into consideration as part of the application. 

The Regulated Firm should consider the following:

  • What new services/permissions it requires;
  • The type of new business/activity;
  • Where the business will be sourced;
  • Resources to deal with the additional business;
  • The impact of the additional business on its capital requirements; and
  • What changes are being effected to its systems and controls.

Capital Requirements

An authorised E-money Issuer is required to hold an initial and ongoing capital of:

  • €350,000; or
  • 2.2%* of the average outstanding electronic money (as projected at application), whichever the highest.

A small or registered E-money Issuer is required to hold an initial and ongoing capital of 2.2% of the average outstanding electronic money.

Regulated Firms holding multiple licences may be required to hold the aggregate of the capital required for each licence prior to conducting the proposed activity, and on an ongoing basis. The GFSC will consider the level of capital in these cases. We advise that you discuss this with the GFSC ahead of your application.


Additional information

Safeguarding Requirements

In accordance with the Regulations, every E-money Issuer must satisfy the GFSC that it has adequate arrangements in place to safeguard the funds of customers received in exchange for E-money issued, and prevent the use of these funds for the E-money Issuer’s own account.

An E-money Issuer shall safeguard customer funds by:

  • Ensuring such funds are segregated and are not, at any time, joined with the funds of any other person or firm; or
  • Ensuring such funds are covered by an insurance policy or similar guarantee which does not belong to the same group as the e-money Institution itself for an amount equivalent to that which would have been segregated in the absence of the insurance policy or such. This should be payable in the event that the e-money Institution is unable to meet its financial obligations.

Additionally, an E-money Issuer that holds customer funds must keep such records and accounts as are necessary to enable them at any time and immediately distinguish funds held for one customer from another and from the funds of the e-money Institution.

The business plan should comprehensively set out:

  • The firm’s proposed activity and how it will be conducted;
  • The resources that will be made available and the systems that the applicant intends to employ;
  • How clients will be attracted and sourced;
  • What arrangements will be put in place to safeguard customer monies and/or assets;
  • How records will be maintained;
  • How, and by whom, any significant decisions will be made;
  • How the firm intends to identify, manage, monitor and mitigate any risks posed to the firm;
  • Details of Agents and/or Distributors to be appointed and countries/jurisdictions in which it will provide its services including whether these services will be passive or active;
  • How the firm complies with the Anti-Money Laundering requirements;
  • The level and nature of fees to be charged to the firm’s clients; and
  • If the applicant forms part of a larger group, applicants should provide details of the activities of the group and a description of their structure.

The GFSC will also be seeking evidence that the firm has considered, documented and implemented the risk, compliance and operational issues associated with the proposed E-money activities.

Applicants should ensure that the business plan is coherent with the firm’s risk appetite and capacity.


GFSC Policy

In order to allow the GFSC to carry out its supervisory and regulatory functions, the GFSC has established a policy for the supervision of E-money Issuers. The following conditions are applied to all approvals issued to E-money Issuers. 

They must be complied with money Institutions on an ongoing basis: 

  • E-money Issuers must ensure that the issue of electronic money or other business carried out in reliance upon its licence is legal in the country in which any electronic money is issued or other business carried out. Additionally, the E-money Institution must not provide any services that are out of the scope of the issued licence to any person where the provision of such services would be illegal under the applicable law.
  • Confirmation is required that any arrangements with Relevant Parties, Programme Managers and Processors satisfy the Commission's requirements and that such arrangements enable the firm to directly exercise appropriate controls and step-in rights as required for regulatory purposes at any given time.
  • The E-money Issuer is required to notify the GFSC of any programme, Programme Manager or relevant party it enters into a new business relationship with.
  • The E-money Issuer must, at all times, be able to demonstrate that it is able to safeguard relevant funds and that any risks associated with relevant funds are being proactively managed, do not compromise its financial position nor disadvantage its customers. Regardless of where funds are paid, the firm must ensure that it always complies with the safeguarding of funds requirements.