Fintech Licensing
EMI, PSP, VASP, MSB and crypto licences in the right regulator's hands.
Building a fintech is the easy part. Getting authorised to handle other people's money, or other people's crypto, is where most ambitious projects stall, burn capital or quietly relocate. A payments app, a wallet, an exchange or a remittance service almost always requires a licence from a financial regulator, and the choice of which licence, in which jurisdiction, shapes everything that follows: your banking, your card schemes, your investor appetite and your ability to passport into new markets.
Fintech licensing is the work of selecting the right regulatory permission for a specific business model and the markets it serves, then preparing and shepherding the application to approval. The main permissions are the Electronic Money Institution (EMI) licence for issuing e-money and wallets, the Payment Service Provider (PSP) or Payment Institution authorisation for processing payments, the Money Services Business (MSB) registration for remittance and currency exchange, and the Virtual Asset Service Provider (VASP) licence for crypto exchange and custody.
It matters now because regulators have caught up with the sector. The era of operating first and asking forgiveness is over. Banks will not service an unlicensed money business, card schemes will not sponsor one, and serious investors will not fund one. Equally, regulators have become more demanding: capital, governance, AML systems and fit-and-proper directors are scrutinised in detail. Choosing badly, or rushing, is expensive.
The jurisdictions, compared honestly
The right regulator depends on your business model, your target markets, your capital and how much credibility you need to raise money.
The United Kingdom (FCA) offers global credibility and a mature payments and EMI regime. The bar is high: real substance, capable compliance leadership and serious capital are expected, and timelines run long. Best for ambitious payments and e-money businesses wanting reputational weight; tough and slow for a thinly resourced startup.
Lithuania and the wider EU became the practical home of European EMI and PI licensing, offering passporting across the EEA from one authorisation. Lithuania moved fast historically but has tightened considerably; Ireland, Luxembourg and the Netherlands are credible, more demanding alternatives. Best for anyone needing EU-wide reach; the trade-off is genuine substance requirements and post-MiCA scrutiny for crypto.
Malta offers EU access with a long fintech and crypto history and a regulator (the MFSA) experienced in the sector. It carries some reputational baggage and demands real local presence. Best for crypto-adjacent and gaming-linked payments players comfortable with substance.
The UAE has built credible regimes through ADGM and DIFC, plus VARA in Dubai for virtual assets. Strong for crypto and for GCC and emerging-market payments, with a pro-business posture, though costs and substance expectations are rising. Best for crypto exchanges and MENA-facing payments; less suited to those needing EU passporting.
Singapore (MAS, under the Payment Services Act) is the gold standard for Asia, covering payments and digital-token services in one framework. Highly respected, highly selective, and not fast. Best for well-capitalised, serious APAC players; unforgiving of weak governance.
The United States is not one regime but fifty-plus: federal MSB registration with FinCEN plus state-by-state money-transmitter licensing, an expensive multi-year undertaking, with the New York BitLicense its own challenge for crypto. Best only for those committed to the US market with capital to match.
Lighter-touch jurisdictions exist, but a cheap licence that banks and partners do not respect is a false economy. The licence has to actually open the doors you need.
How it actually works
- Model and market mapping. We define precisely what your business does, where it serves customers and which regulated activities it triggers, then identify the licence and jurisdiction that fit.
- Gap analysis. We assess capital, governance, key personnel and systems against the regulator's requirements, and surface what is missing before you apply.
- Substance build-out. Most regimes require local presence, qualified directors, an MLRO and operational systems. We help assemble these so the application is credible rather than aspirational.
- Documentation. We prepare the business plan, financial projections, AML and risk policies, safeguarding arrangements and the regulatory business case the authority expects.
- Submission and dialogue. We coordinate the filing and manage the regulator's questions, which are detailed and iterative. Expect months, not weeks.
- Operational readiness. Authorisation is the start, not the finish: banking, safeguarding accounts and scheme sponsorship must follow.
What goes wrong
- Jurisdiction shopping for price. The cheapest licence often cannot be banked or passported, stranding the business after approval.
- Underestimating capital. EMI and payment regimes carry minimum own-funds and safeguarding rules; running short triggers regulatory intervention.
- Weak AML systems. Policies copied from a template, with no real transaction monitoring or trained MLRO, fail at inspection and at the bank.
- The wrong people. Regulators apply fit-and-proper tests to directors and shareholders. A founder with an awkward history can sink an otherwise strong file.
- No substance. A brass-plate presence with directors who cannot speak to the business is now a quick path to refusal.
- Forgetting banking. A licence with no banking or card-scheme relationship is a permission to do nothing. Sequencing these together is essential.
How HPT helps
We work director-led and we coordinate with licensed law firms, regulated corporate-services providers and the regulators themselves; we do not hold client funds or operate the licence on your behalf. Our role is to get the strategy and the file right.
You receive a written licensing roadmap: the recommended permission and jurisdiction, the capital and substance you will need, a realistic timeline as at 2026, and the banking and scheme relationships to line up in parallel. We help build the governance and AML framework that regulators and banks actually accept, prepare the application pack, and manage the regulator dialogue through to authorisation.
We are honest about fit. If your model does not yet justify a full EMI, if your capital is short of what the regime demands, or if your target jurisdiction will not respect the licence you are tempted by, we will say so. A licence you cannot use is worse than no licence, and steering you away from that is part of the job.
Who this is for
Fintech licensing through us suits founders and companies with a genuine, scalable financial-services business and the capital and intent to build it properly. It is not for those seeking a regulatory veneer to reassure customers without meeting the obligations, nor for anyone unwilling to fund the substance these regimes now require. Done right, the licence becomes the foundation that unlocks banking, partnerships and investment. Done as a box-tick, it becomes an expensive liability, and we would rather tell you that before you start.
Fintech Licensing — structured to hold.
EMI, PSP, VASP, MSB and crypto licences. Drafted, prepared and supported through the application process via the client's licensed local counsel. We have walked clients through the FCA, MFSA, CySEC, FSA Mauritius, ADGM and DFSA, and we know what each regulator actually reads.
The director named on your engagement letter is the same director who signs the memorandum. One name on the page, one name on the invoice, one name on the file.
The right fit
- Founders building payment, neobank, crypto-on-ramp or FX products
- Operating fintechs expanding into new jurisdictions
- Investors acquiring an existing licensed entity
Deliverables
- Regulator-tested business plan and financial projections
- Capital, governance, IT and operational policies (including MLRO role design for the licensed entity)
- Application drafting and submission support via local counsel
- Regulator-meeting preparation
- Post-authorisation operating-model design
Where we deliver fintech licensing.
We hold direct relationships across 39 active jurisdictions for this service.
United Kingdom (FCA — EMI / PSP / SPI)
Ireland (CBI)
Lithuania (Bank of Lithuania)
Estonia (FIU)
Latvia (FCMC)
Malta (MFSA)
Cyprus (CySEC)
Luxembourg (CSSF)
Netherlands (DNB)
Germany (BaFin)
France (ACPR)
Spain (Bank of Spain)
Sweden (FI)
Denmark (DFSA)
Czech Republic (CNB)
Poland (KNF)
Gibraltar (GFSC)
Isle of Man (IOM FSA)
Jersey (JFSC)
Guernsey (GFSC)
Switzerland (FINMA)
United Arab Emirates (ADGM FSRA, DIFC DFSA, VARA)
Saudi Arabia (SAMA)
Bahrain (CBB)
Qatar (QFC)
Hong Kong (SFC / HKMA)
Singapore (MAS)
Japan (FSA)
Australia (ASIC)
New Zealand (FMA)
Mauritius (FSC)
Seychelles (FSA)
Cayman Islands (CIMA)
BVI (FSC)
Bahamas (SCB)
Bermuda (BMA)
Curaçao (CBCS)
Canada (FINTRAC / OSFI)
USA (state MTL / FinCEN)From engagement letter to signed structure.
Typical timeline: 6–14 months. Director-led throughout.
A short, confidential intake form. We decide within 48 hours whether we are the right fit for your matter.
Working sessions with the principal director. We probe assumptions, model scenarios and surface the real question.
A written memorandum that any banker, auditor or counsel can read and defend. No surprises at implementation.
We manage formations, bank openings, licensing and documentation, and stay on as a long-term retained counsel.
Practical questions from real client files.
What clients usually pair with this.
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Corporate Payment Cards
Multi-currency corporate cards and prepaid cards for global operations.
Ready to discuss your matter?
Forty-eight hours to know if we're the right fit for your fintech licensing work. Five days to put the answer in writing.