An EU payment licence passports only as a full authorisation: PSD2 Article 11(9) makes it valid in every Member State. So the country you file in does not decide your market, it decides your supervisor and where your company physically has to sit. The cheap route is the one that shrinks. Article 32(3) strips the passport out of a small-payment-institution registration, so that permission stops at the granting country's border.
Four initial-capital floors, written into the Directives
Most people arrive with the wrong vocabulary. API and SPI are British words, MPI is a Singaporean one, and none is EU law. Which licence type a stablecoin or card product triggers is answered on the EMI, API and MPI page; undecided readers start at licence selection. If what you provide is a crypto-asset service, the regime is MiCA rather than PSD2 — the MiCA scope test — and regions compare on jurisdictions. This page answers one thing: what the country determines.
Key takeaways
- A full authorisation is valid in every Member State, so the country is not a market-access decision.
- It is a supervision decision: the State you file in supervises you from then on.
- The company has to be genuinely there: head office with the registered office, part of the business local.
- A small-PI registration is cheaper and carries no passport: it works only where granted.
Does an EU payment licence really work in every Member State?
Yes, if it is a full authorisation. PSD2 Article 11(9) is unambiguous: an authorisation is valid in all Member States and lets the institution provide the services it covers throughout the Union, under freedom of establishment or freedom to provide services.
It is not automatic, though. Article 28(1) makes an institution entering another Member State notify its home authority first, naming the States and the services; Article 28(2) gives the home authority one month to pass that on and the host authority one month to respond. Every step runs through the regulator you picked at the start.
API, SPI, MPI: which of those words is EU law?
None. Authorised and small payment institution are FCA terms; standard and major payment institution are Singapore's. EU law has three things instead: a payment institution authorised under Article 11, an electronic money institution authorised under EMD2, and a person merely registered under the Article 32 exemption. Only the first two passport. Terms are in the glossary.
Why does the country still decide everything?
Because the Directive does not allow a company that is only an address. Article 11(3) requires a payment institution whose home Member State demands a registered office to have its head office in that same Member State, and to carry out at least part of its payment service business there. Article 4(1) fixes the home Member State as wherever the registered office sits.
So registered in Lithuania, team entirely in Asia is not a filing you can make — the point made at length on local substance requirements. Choosing a Member State is three questions: whose supervision for the next decade, which functions can you move, and can you hire there.
What does the small-PI route cost you?
Article 32(1)(a) lets a Member State exempt a small provider where the monthly average of the preceding 12 months of payment transactions stays under a national ceiling capped at EUR 3 million. Article 32(2) puts its head office or residence in the Member State where the business actually happens.
Then comes Article 32(3), which says exempt persons "shall be treated as payment institutions, save that Article 11(9) and Articles 28, 29 and 30 shall not apply to them". Article 11(9) is the passport. Remove it and what is left is a national permission, not a cheap European licence.
The e-money side is symmetrical: EMD2 Article 9 allows registration instead of authorisation while average outstanding electronic money stays under a ceiling capped at EUR 5 000 000, and Article 9(3) disapplies Article 10(9) of Directive 2007/64/EC — which PSD2's Annex II correlation table lines up against its Article 11(9). The provision switched off is, again, the passport.
Full authorisation and the Article 32 registration, side by side
| Full authorisation | Article 32 registration | |
|---|---|---|
| EU passport | Yes, Article 11(9) | No, Article 11(9) disapplied |
| Volume ceiling | None | Monthly average up to EUR 3 million |
| Where the company sits | Head office with the registered office, part of the business local | Head office or residence where the business actually happens |
| If you outgrow it | — | Apply for full authorisation within 30 days |
Article 32(5) writes the exit: once the conditions stop being met, the person has 30 calendar days to seek authorisation. The ceiling is a monthly average, so the EUR 3 million cap tolerates roughly EUR 36 million of volume across a year.
How much capital do you actually need?
PSD2 Article 7 sets initial capital at EUR 20 000 for money remittance alone, EUR 50 000 for payment initiation and EUR 125 000 for the other services in points (1) to (5) of Annex I; e-money is EUR 350 000 under EMD2 Article 4.
Those are floors, not budgets: Article 8(1) requires own funds never to fall below the higher of that initial capital and the Article 9 calculation. And in Ireland the Minded to Authorise letter itself sets the proposed level of capital to be held, so the final number reaches you near the end.
What does authorisation in Ireland actually involve?
The Central Bank of Ireland publishes its own process, and it runs in three stages: an exploratory stage around an initial meeting and a key information check, an assessment stage on the file itself, and a decision stage ending in a Minded to Authorise or Minded to Refuse letter.
Exploratory stage
Before the initial meeting you file a Pre-Application Key Facts Document, which the Bank expects to run to about 15 to 20 pages and to arrive at least 5 working days ahead.
Assessment stage
The Bank assesses the file, may request more information, and may interview people proposed for Pre-Approval Controlled Function roles. Its published standard is to notify the outcome in 90% of cases within 90 business days of the stage commencing.
Decision stage
A Minded to Authorise letter with its conditions and capital level, or a Minded to Refuse letter stating reasons.
The 90-day standard comes with a suspension rule. The Bank says plainly that "the 90 day Service Standard clock for the Assessment Stage will be paused where an information request has been issued to the applicant until such time as a satisfactory response has been provided". It can also stop entirely: where another regulator must be contacted, where people are interviewed, where the business model is complex or novel, or where the Bank is minded to refuse.
This is why nobody should promise you a timeline. PSD2 Article 12 gives the authority 3 months, but from a complete application. How fast your file gets complete is partly in your hands; when the decision comes, and what it is, are not.
The Irish small-PI route: on the statute book, not in operation
- The statute: Regulation 41(1) of S.I. No. 6/2018 lets the Central Bank exempt a person whose monthly average over the preceding 12 months stays under €3,000,000.
- The practice: the Bank's own authorisation page says there is no small payment institution regime in place in Ireland, and that firms must apply for authorisation as a payment institution.
- It would not have helped anyway: Regulation 41(3) disapplies Regulation 18(6), the clause making an Irish authorisation valid in all Member States.
Frequently asked questions
Can a small payment institution operate in other Member States?
No. PSD2 Article 32(3) disapplies Article 11(9) to exempt persons, and Article 11(9) is what makes an authorisation valid in all Member States.
Can you register as a small payment institution in Ireland?
Not in practice. Regulation 41(1) of S.I. No. 6/2018 lets the Central Bank exempt a person under a €3,000,000 monthly average, but the Bank's own authorisation page says there is no small payment institution regime in place in Ireland, and that firms must apply for authorisation as a payment institution.
How long does the regulator take to decide?
PSD2 Article 12 gives the competent authority 3 months from a complete application to say whether authorisation is granted or refused. That is a deadline on the authority, not a forecast for your file.
Before you file
This describes published law and regulators' own documents; it is not legal advice. CryptoLicense is the licensing advisory brand of CL GLOBAL SDN BHD (1421939-T), in business since 2020, with 100+ companies served across 10+ jurisdictions; the entities behind it are on entity proof. No application can be guaranteed: whether an authorisation is granted rests entirely with the regulator. Bring your model and where your paying clients are, and we will settle the tier first.
Part of a series: the full guide is at licence selection.