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Payment institution licensing and launch

We help payment businesses choose the right regime, obtain authorisation or registration and build the compliance, finance and technology needed to operate. Lawyers, finance specialists, anti-money laundering (AML) and compliance specialists and engineers work on one project plan, from the first assessment to the first live transactions.

EU · UK · UAE · SGKazakhstan · NBKAIFC · AFSA
The regime

What a payment institution is

A payment institution (PI) is a non-bank company permitted to provide payment services: execution of payment transactions, money remittance, issuing payment instruments, acquiring card and online payments, payment initiation and account information services. The permission covers only the listed services and does not turn the company into a bank.

Each jurisdiction defines the services, the form of permission and the capital in its own way. In the EU the basis is the Payment Services Directive (PSD2), transposed into national law; the UK applies the Payment Services Regulations 2017; the Central Bank of the UAE (CBUAE) licenses retail payment services in four categories; Singapore regulates payments under the Payment Services Act 2019. In Kazakhstan a payment organisation is registered by the National Bank (NBK), while the Astana International Financial Centre (AIFC) has a separate authorisation for Providing Money Services.

The EU is reforming its payments framework: a new directive (PSD3) and a Payment Services Regulation (PSR) are intended to replace PSD2. Final texts and transition periods must be checked at the date of application, so we confirm the applicable requirements at the assessment stage.

Who needs it

  • Payment gateways and merchant acquiring for e-commerce
  • Money remittance and cross-border transfer services
  • Payment accounts and card issuing for consumers or businesses
  • Payment initiation (PIS) and account information (AIS) services built on open banking
  • Marketplaces and platforms that collect and pay out funds between users
  • Crypto and fintech projects that need fiat payment rails alongside a digital asset licence
  • Payment organisations in Kazakhstan: cash acceptance, e-money distribution and payment processing
Scope

Scope of the permission

What it permits

  • Execution of payment transactions and transfers
  • Issuing payment instruments and acquiring payment transactions
  • Money remittance without opening a payment account
  • Payment initiation and account information services, where included in the permission
  • Holding client funds solely to execute payments, under safeguarding rules
  • In Kazakhstan: the four types of payment services defined for payment organisations

Restrictions

  • Only the services named in the authorisation or registration; adding a service requires a new approval and may increase the capital requirement
  • No deposit-taking and no banking business
  • Issuing electronic money requires a separate e-money permission (in the EU and UK — authorisation as an electronic money institution, EMI)
  • Client funds must be safeguarded and kept apart from the company's own funds
  • Lighter regimes cap payment volume; in the UK a small PI cannot provide PIS or AIS
  • A permission in one country does not by itself allow serving clients in another; cross-border activity is assessed separately
Jurisdictions

Jurisdictions and regimes

The table shows the regimes we work with and the requirements confirmed against official sources. Where a figure could not be verified, we confirm it at the assessment stage.

JurisdictionRegulatorRegimeKey points
European Union (PSD2)National competent authorityAuthorisationInitial capital: €20,000 for money remittance only, €50,000 for payment initiation, €125,000 for other payment services. Ongoing own funds are calculated under one of three methods chosen by the regulator. Member states may exempt small PIs with an average monthly volume of up to €3 million.
LithuaniaBank of LithuaniaAuthorisationPSD2 capital tiers apply. National options, including the small PI regime, and procedure details are confirmed at assessment.
Czech RepublicCzech National Bank (CNB)AuthorisationPSD2 capital tiers apply. National options and the application procedure are confirmed at assessment.
United KingdomFinancial Conduct Authority (FCA)Authorisation (authorised PI) or registration (small PI)Authorised PI: €20,000 / €50,000 / €125,000 depending on services; no capital for account information only. Small PI: average monthly volume up to €3 million, no PIS or AIS, head office in the UK. The new safeguarding chapter, CASS 15, applies from 7 May 2026.
UAE — mainland and non-financial free zonesCentral Bank of the UAE (CBUAE)Licence, Category I–IVInitial capital depends on category and on average monthly volume below or above AED 10 million: Cat. I AED 1.5m / 3m, Cat. II AED 1m / 2m, Cat. III AED 0.5m / 1m; Cat. IV (payment initiation and account information only) AED 100,000. Capital must be maintained at all times.
UAE — ADGMFinancial Services Regulatory Authority (FSRA)Financial Services Permission — Providing Money ServicesSince 9 Nov 2020 the permission has covered payment accounts, stored value, currency exchange and money transmission. Capital follows the prudential category and is confirmed at assessment.
UAE — DIFCDubai Financial Services Authority (DFSA)Licence — Money ServicesCapital depends on the DFSA prudential category; the rules were amended in 2025–2026, so amounts are confirmed at assessment.
SingaporeMonetary Authority of Singapore (MAS)Licence: Standard (SPI) or Major (MPI) Payment InstitutionSPI base capital S$100,000. An MPI licence is needed above S$3 million a month for one service, S$6 million for two or more services, or S$5 million average daily e-money float.
KazakhstanNational Bank of Kazakhstan (NBK)Registration with the NBKFour types of payment services. Applications are filed via the e-government portal; payment services cannot be provided without a registration number. Minimum charter capital is set by the NBK and confirmed at assessment.
AIFC (Astana)Astana Financial Services Authority (AFSA)Authorisation — Providing Money ServicesCovers currency exchange, issuing payment instruments and stored value, executing payments and money transmission. AIFC law applies only to AIFC participants; capital is confirmed at assessment.
KyrgyzstanNational Bank of the Kyrgyz Republic (NBKR)Licence (payment organisation; payment system operator)Minimum charter capital for new entrants: KGS 30 million for a payment organisation, KGS 20 million for a payment system operator and KGS 50 million for both; higher amounts, up to KGS 110 million, apply to cross-border payments to non-resident providers, tax collection and acquiring. Existing licensees reach the new levels in stages by 1 October 2027. Issuing e-money requires a separate right shown in the NBKR register.
GeorgiaNational Bank of Georgia (NBG)RegistrationNon-bank payment service providers register under NBG rules approved by Order No. 77/04 of 1 May 2023, since updated to cover account information and payment initiation services, significant provider status and notification of changes in ownership. Capital adequacy requirements, in force since 1 January 2024, apply only to significant providers and payment initiation service providers; the amounts are confirmed at assessment. The applicant must be a Georgian legal entity with its head office in Georgia.

How the regimes differ

  • Form of permission: authorisation in the EU and UK, a licence by category in the UAE mainland and Singapore, a Financial Services Permission in ADGM, registration with the NBK in Kazakhstan, authorisation by AFSA in the AIFC.
  • Capital: the EU and UK link initial capital to the set of services (€20,000–€125,000); the CBUAE adds a volume threshold of AED 10 million a month; Singapore links the licence class to transaction volume.
  • Lighter regimes: optional small PI exemption in EU member states (up to €3 million a month), small PI registration in the UK, the SPI licence in Singapore — each with volume limits.
  • Safeguarding: the UK introduced a dedicated chapter, CASS 15, for authorised PIs and EMIs from 7 May 2026; small PIs apply it only by choice. Other regimes set their own rules for protecting client funds.
  • Kazakhstan and the AIFC are separate legal regimes: NBK registration does not cover AIFC activity, and AFSA authorisation does not replace NBK registration for the national market.
  • Kyrgyzstan and Georgia: the NBKR issues licences with charter capital tied to the services provided (KGS 30 million for a new payment organisation), while Georgia uses registration with the NBG and applies capital adequacy requirements only to significant providers and payment initiation service providers.
Requirements

Key requirements

Company and owners

  • A company incorporated in the jurisdiction with a business model matching the requested services
  • Disclosure of qualifying shareholders and ultimate beneficial owners, with source of funds and wealth
  • Fit-and-proper assessment of owners: reputation, financial soundness, sanctions checks
  • A transparent group structure and documented outsourcing arrangements

Capital and finances

  • Initial capital at the level required for the service set, paid in before or as a condition of authorisation
  • Ongoing own funds and capital monitoring under the method set by the regulator
  • Business plan with financial projections, usually for three years
  • Safeguarding arrangements with a bank or other permitted institution

Management, team and local presence

  • Directors and senior managers with relevant experience and good repute
  • Key functions: compliance, AML, risk management, internal audit and IT
  • Real management and decision-making in the jurisdiction, as required by the regulator
  • In Kazakhstan: appointment of a head of IT and a compliance controller, or a person combining these functions

Compliance and IT

  • AML and counter-terrorist financing (AML/CFT) framework: risk assessment, customer and business due diligence (KYC/KYB), sanctions and politically exposed persons (PEP) screening, transaction monitoring
  • Safeguarding, reconciliation and incident management procedures
  • Information security, business continuity and outsourcing controls
  • Payment infrastructure: processing, bank and scheme connections, regulatory reporting

Regulatory capital is separate from state and application fees, operating costs and our fees. Our fees are agreed after the project assessment.

Documents

Main application documents

  • Application form and regulator questionnaires
  • Programme of operations describing each payment service
  • Business plan and three-year financial model
  • Constitutional documents and group structure chart
  • Information on shareholders, beneficial owners, directors and key function holders
  • Evidence of initial capital
  • Safeguarding arrangements and agreements with banks
  • AML/CFT policy, business risk assessment and internal control rules
  • Governance, risk management and internal control framework
  • IT and security description, business continuity and outsourcing policy
  • In Kazakhstan: rules of activity and a document on cooperation with a bank or a money transfer organisation
Process

How the project runs

  1. 01

    Assessment

    We analyse the business model, payment flows and target markets, define the regulatory perimeter and compare regimes. Result: recommended jurisdiction, type of permission and a list of requirements.

  2. 02

    Structure and company

    Incorporation or adaptation of the company, shareholding, governance and outsourcing model. Result: a structure the regulator can assess without gaps.

  3. 03

    Documents and financial model

    Business plan, financial model, policies, AML/CFT framework and safeguarding model. Result: a complete application package.

  4. 04

    Application and regulator dialogue

    Filing, answers to the regulator's questions, interview preparation for managers. Result: a decision on the application.

  5. 05

    Capital, banking and infrastructure

    Paying in capital, opening safeguarding accounts, setting up processing, KYC and monitoring systems. Result: readiness to operate.

  6. 06

    Launch and ongoing support

    Operational launch, first regulatory reports, internal control and changes to the business. Result: a working payment institution that meets its obligations.

Timing

Timing

Review periods are set by national law or regulator practice and differ between jurisdictions; we confirm them for the chosen regime. In practice, the timeline depends mostly on the quality of the application and how quickly the regulator's questions are answered. We do not promise a fixed decision date.

  • Completeness and consistency of the application package
  • Number and type of payment services requested
  • Complexity of the ownership structure and source-of-funds evidence
  • Readiness of management, key function holders and local presence
  • Availability of a safeguarding account and banking partners
  • Regulator workload and regulatory changes, including the EU payments reform
Our work

What our team does

Lawyers

  • Regulatory perimeter analysis and choice of regime and jurisdiction
  • Company incorporation, corporate documents and group structuring
  • Preparation of the application and programme of operations
  • Correspondence with the regulator and interview preparation
  • Client terms, agent, distribution and outsourcing agreements
  • Foreign-law opinions, together with local counsel where required

Finance specialists

  • Business plan and three-year financial model
  • Calculation of initial capital and own funds requirements
  • Budget that separates regulatory capital, state fees and operating costs
  • Safeguarding model and reconciliation logic
  • Set-up of regulatory and management reporting

AML/compliance specialists

  • Business-wide money laundering and terrorist financing risk assessment
  • AML/CFT policy, KYC/KYB, sanctions and PEP screening procedures
  • Transaction monitoring scenarios and handling of suspicious activity
  • Internal control, staff training and inspection readiness
  • Support for the person the company appoints as MLRO or compliance officer

Engineers

  • Mapping payment flows and system architecture against regulatory requirements
  • Development and integration of KYC, screening and monitoring tools
  • Automation of safeguarding reconciliations and regulatory reporting
  • Information security, access control and audit logging
  • Integration with banks, processors and payment providers
After authorisation

After authorisation

  • Maintaining initial capital and own funds at all times
  • Safeguarding client funds and regular reconciliations
  • Regulatory reporting in the form and within the deadlines set by the regulator
  • Notifying the regulator of, or obtaining approval for, changes in owners, managers and services
  • Periodic AML/CFT risk reassessment, staff training and internal control reviews
  • Annual audit and payment of supervisory fees where applicable
  • Preparing for regulatory changes, including the EU payments reform
FAQ

Frequently asked questions

Describe your project in a few sentences. We will give you a substantive reply: which questions need answering and where to start.

Discuss your project
Do we need a licence, or is registration enough?

It depends on the services and volumes. The UK small PI and the EU small PI exemption are lighter regimes with volume limits of up to €3 million a month; in Kazakhstan payment organisations are registered by the NBK rather than licensed. Higher volumes or services excluded from lighter regimes require full authorisation.

How much capital is required?

Initial capital depends on the services: from €20,000 to €125,000 under PSD2 and UK rules, from AED 100,000 to AED 3 million in the UAE mainland depending on category and volume, S$100,000 for an SPI in Singapore. This is regulatory capital only; state fees, operating costs and our fees are separate. Our fees are agreed after the assessment.

Can a payment institution issue electronic money?

Under PSD2 and UK rules, no: issuing e-money requires an EMI authorisation. The EU reform under way may change the structure of these regimes, so we confirm the position at assessment. In Kazakhstan, payment organisations may distribute e-money and process e-money payments; issuing it is reserved for the issuers named in the Law on payments.

What changes with the new UK safeguarding rules?

From 7 May 2026 authorised PIs and EMIs apply CASS 15 of the FCA Handbook; small PIs apply it only if they opt into safeguarding. A subsequent regime depends on legislative changes and does not yet have a fixed date.

Can a Kazakhstan payment organisation operate in the AIFC, or the reverse?

No, these are separate regimes. NBK registration covers the national market; activity in the AIFC requires AFSA authorisation as an AIFC participant. We help choose the regime that matches the client base and the payment flows.

Do you guarantee a licence or a bank account?

No. The decision belongs to the regulator, and banks and payment providers make their own onboarding decisions. We prepare the project so that the application and the operating model meet the requirements and the questions are answered fully.

Can you act as the MLRO or compliance officer?

We do not perform regulated functions. We help prepare and support the person appointed by the company and can discuss outsourced support models where the law allows; this is determined for each project.

Sources checked on 15 October 2026
  • Directive (EU) 2015/2366 (PSD2), Art. 7, 9, 32 — EU-derived text on legislation.gov.uk — https://www.legislation.gov.uk/eudr/2015/2366/article/7/data.html (checked 15 Oct 2026)
  • UK Payment Services Regulations 2017, Schedule 3 — https://www.legislation.gov.uk/uksi/2017/752/schedule/3 (checked 15 Oct 2026)
  • UK Payment Services Regulations 2017, reg. 14 (small payment institutions) — https://www.legislation.gov.uk/uksi/2017/752/regulation/14 (checked 15 Oct 2026)
  • FCA PS25/12 Changes to the safeguarding regime for payments and e-money firms — https://www.fca.org.uk/publications/policy-statements/ps25-12-changes-safeguarding-regime-payments-and-e-money-firms (checked 15 Oct 2026)
  • FCA Handbook CASS 15 — https://handbook.fca.org.uk/handbook/cass15/cass15s1 (checked 15 Oct 2026)
  • CBUAE Retail Payment Services and Card Schemes Regulation (Circular 15/2021) — https://rulebook.centralbank.ae/node/1580 (checked 15 Oct 2026)
  • ADGM FSRA announcement on Providing Money Services framework — https://adgm.com/media/announcements/fsra-introduces-enhancements-to-the-regulatory-framework-for-providing-money-services (checked 15 Oct 2026)
  • MAS Standard Payment Institution licence — https://www.mas.gov.sg/regulation/payments/standard-payment-institution-licence (checked 15 Oct 2026)
  • National Bank of Kazakhstan — registration of payment organisations — https://nationalbank.kz/ru/news/uchetnaya-registraciya-platezhnoy-organizacii (checked 15 Oct 2026)
  • AFSA — regulated activities (Providing Money Services) — https://afsa.aifc.kz (checked 15 Oct 2026)
  • National Bank of the Kyrgyz Republic (NBKR) — register of payment system operators and payment organisations — https://nbkr.kg/index1.jsp?item=2785&lang=RUS (checked 15 Oct 2026)
  • NBKR Board resolution No. 2025-П-14/20-1-(ПС) of 30 Apr 2025 (minimum charter capital of payment organisations and payment system operators) — https://nbkr.kg/contout.jsp?item=2145&lang=RUS&material=125178 (checked 15 Oct 2026)
  • NBG — Payment service providers — https://nbg.gov.ge/en/page/payment-service-providers-2 (checked 15 Oct 2026)
  • NBG news: updated regulation on registration and regulation of payment service providers — https://nbg.gov.ge/en/media/news/nbg-approves-updated-regulation-on-registration-and-regulation-of-payment-service-provider (checked 15 Oct 2026)
  • NBG news: capital adequacy requirements for payment service providers — https://nbg.gov.ge/en/media/news/nbg-approves-regulation-on-capital-adequacy-requirements-for-payment-service-providers (checked 15 Oct 2026)
  • NBG rules on registration and regulation of payment service providers (legal entity and head office in Georgia) — https://regalert.today/document/7d18592d-d9db-4438-bc62-6f4db216f034 — official text on a third-party database; used qualitatively (checked 15 Oct 2026)

Discuss your payment project

Tell us about your services, target markets and expected volumes. We will assess the regulatory perimeter, compare the regimes and propose a project plan; fees are agreed after the assessment.

Discuss your project
Contact

Tell us about your project

We will review the description and give you a substantive reply: which regime may apply and where to start.

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