EMI Licence in Latvia: Requirements, Fees, and Why Stablecoin Issuers Need One

Electronic money hides in plain sight: take customer funds, hold a balance, let the customer spend it elsewhere, and you are issuing e-money – whatever the product calls itself. That is how payments apps, wallets and euro stablecoins all arrive at the same licence. In Latvia it is issued by Latvijas Banka, and the requirements, fees and timelines are published rather than negotiated.

This guide sets out what an EMI licence in Latvia actually involves: the two tiers and the trap in the cheaper one, the capital, the fees, the clock, and the reason the licence has become interesting again – MiCA made an authorised EMI one of only two entities permitted to issue a euro stablecoin.

General information as of 3 September 2026, not individual legal advice. Fee schedules and thresholds change – confirm the current position with Latvijas Banka before you budget. For how we work with founders, see crypto lawyer in Latvia.

In short

• Two tiers. A licensed (authorised) EMI – sometimes written AEMI – passports across the EU/EEA. A registered (small) EMI is cheaper and lighter but cannot operate outside Latvia.
• Capital: own funds of at least €350,000 for a licensed EMI. A registered EMI has no set capital requirement.
• Fees: €5,000 to examine a licence application (€450 for innovative-services-only providers); ongoing supervision €7,000 a year plus up to 1.4% of gross income, capped at €100,000. Registration as a small EMI costs €2,500, with €1,000 a year in supervision.
• Timeline: decision within three months of a confirmed-complete application, after a completeness check of roughly 15 working days.
• The MiCA link: under MiCA, an e-money token may only be issued by a credit institution or an authorised EMI – which is why anyone planning a euro stablecoin ends up reading this page.

What an EMI licence actually authorises

Electronic money is stored monetary value, issued on receipt of funds, that represents a claim on the issuer and is accepted by parties other than the issuer. The definition matters more than it looks: if your product takes customer money, holds a balance, and lets the customer spend it elsewhere, you are probably issuing electronic money whatever you call the balance in your interface.

An EMI licence authorises that issuance, and it carries payment services alongside it – accounts, transfers, card issuing, acquiring, and the rest of the payment-services list, to the extent your authorisation covers them. For an authorised EMI, the licence passports across the EU and EEA: one authorisation from Latvijas Banka, then notification to operate in other member states.

The two tiers, and the trap in the cheap one

Latvia operates the two-tier structure the EU e-money regime permits, and the gap between them is larger than the fee difference suggests.

	Licensed (authorised) EMI	Registered (small) EMI
Capital	own funds ≥ €350,000	no set requirement (balance-sheet items must not be negative)
Application fee	€5,000 (€450 innovative-only)	€2,500 (€450 innovative-only)
Annual supervision	€7,000 + up to 1.4% of gross income (cap €100,000)	€1,000 + up to 1.4% of gross income (cap €100,000)
Scale limit	none	average e-money in circulation ≤ €2 million
EU passport	yes	no
Can issue MiCA e-money tokens	yes	no
Decision	within 3 months of completeness	examination begins within 1 month of completeness

The trap is the passport row. A registered institution may not offer or provide payment and e-money services outside Latvia, or through international payment systems. For a domestic product serving Latvian customers, that can be a sensible and inexpensive start. For anything with EU ambitions – or any stablecoin – it is a dead end that has to be re-licensed later, from scratch, at the higher tier.

The €2 million ceiling compounds the problem: it is a limit on average electronic money in circulation, so success itself pushes you out of the regime. Growing into the licensed tier is a planned migration if you anticipate it, and an emergency if you do not.

What the application has to contain

The published requirements track the EU regime, and the file is substantial. Expect to prepare:

• a programme of operations and a business plan covering at least three years, with a forecast that shows the institution can meet its obligations;
• evidence of the initial capital;
• safeguarding arrangements for funds received in exchange for electronic money – segregation from the institution’s own funds, or an equivalent insurance or guarantee mechanism. This is the requirement most often underestimated: safeguarding is a structural design decision, not a policy document;
• internal control, risk management and governance arrangements;
• AML/CFT procedures, including customer due diligence, monitoring and reporting;
• the structure of the institution, ownership and group relationships;
• fitness and propriety evidence for board members and qualifying shareholders;
• security incident procedures, business continuity arrangements, and outsourcing policies where functions are outsourced.

Own funds do not stop at the €350,000 floor. Ongoing own funds are calculated under the statutory methods and scale with the volume of electronic money in issue, so a business that grows will need capital above the entry figure. Model the trajectory, not the threshold.

Fees and timeline, in numbers

• Application: €5,000 for a licence; €450 where the applicant provides only innovative electronic payment services. Registration as a small EMI: €2,500, or €450 for innovative-services-only.
• Ongoing supervision: €7,000 a year plus up to 1.4% of gross income for a licensed EMI, capped at €100,000 a year. Innovative-service providers pay €1,000 a year for three years. A registered EMI pays €1,000 a year plus the same percentage component.
• Completeness check: roughly 15 working days.
• Decision: within three months of the confirmation that the application is complete, extendable where the information submitted is insufficient.

The innovative-services discount deserves a note of its own. Reducing an application fee from €5,000 to €450, and annual supervision to €1,000 for three years, is a deliberate signal to new entrants. Whether a given product qualifies is a question to settle with the regulator early – which is exactly the kind of question Latvijas Banka’s pre-application engagement exists to answer.

Why stablecoin issuers end up here

This is where MiCA changed who the licence is for.

Under MiCA, a token that references a single official currency – a euro stablecoin – is an e-money token, and MiCA is explicit about who may issue one: a credit institution or an authorised electronic money institution. Nobody else. A registered small EMI does not qualify, and neither does a CASP authorisation.

So the structure behind every compliant euro stablecoin in the EU is a bank or an EMI. That is why brands launching tokens partner with licensed issuers rather than issuing themselves – the licence, not the technology, is the constraint. We wrote about that division of labour when Revolut’s euro stablecoin launched through a licensed issuer.

Issuing an e-money token also brings MiCA’s own obligations on top of the EMI regime: a crypto-asset white paper notified to the competent authority, redemption at par at any time, and the marketing and disclosure rules that go with it. The EMI licence is the entry ticket, not the whole compliance picture.

EMI or CASP – which licence do you need?

These are different authorisations for different activities, and they are easy to conflate.

• CASP (MiCA): providing crypto-asset services – custody, exchange, transfer, operating a trading platform, execution, advice. Covered in our guide to the MiCA/CASP licence in Latvia.
• EMI: issuing electronic money, including e-money tokens, and providing payment services.

A crypto exchange needs a CASP authorisation. A euro stablecoin issuer needs to be a bank or an EMI. A business that both issues a token and runs a trading venue for it needs both, and the sequencing matters – as does the question of whether one legal entity should hold both, or whether the group is better structured with separate entities. That is a design decision worth making before either application is filed, not after.

What to settle before you file

• Which tier, honestly assessed against where the business will be in three years – not where it is at launch.
• The safeguarding model, because it shapes your banking relationships and your operational design.
• The own-funds trajectory, not just the entry figure.
• Whether the innovative-services fee reduction applies, settled with the regulator rather than assumed.
• Whether you also need a CASP authorisation, and how the entities should be arranged if you need both.
• Substance in Latvia – as with any licensed institution, the regulator expects genuine local management and control, not a registered address.

Frequently asked questions

What is an EMI licence and what does it allow? An electronic money institution (EMI) licence authorises a company to issue electronic money – stored monetary value representing a claim on the issuer – and to provide payment services alongside it. In Latvia the competent authority is Latvijas Banka. An authorised EMI passports across the EU and EEA on a single licence.

How much capital does an EMI licence require in Latvia? Own funds of at least €350,000 under Section 12 of the Payment Services and Electronic Money Law. That is the floor; ongoing own funds are calculated under the statutory methods and rise with the volume of electronic money in issue, so a scaling business should model above the floor rather than at it.

What does an EMI licence cost in Latvia? Latvijas Banka charges €5,000 to examine a licence application, reduced to €450 for providers offering only innovative electronic payment services. Ongoing supervision is €7,000 per year plus up to 1.4% of gross income, capped at €100,000 a year; innovative-service providers pay €1,000 a year for three years.

What is the difference between a licensed EMI and a registered EMI? A registered (small) EMI is a lighter regime for institutions whose average electronic money in circulation does not exceed €2 million. It has no set capital requirement and costs €2,500 to register. The catch is decisive: a registered institution may not provide services outside Latvia or through international payment systems – there is no EU passport, and it cannot issue e-money tokens under MiCA.

Do I need an EMI licence to issue a euro stablecoin? Effectively yes, unless you are a bank. Under MiCA, an e-money token may only be issued by a credit institution or an authorised electronic money institution. A registered or small EMI does not qualify. That makes the EMI licence the gateway to issuing a euro-denominated stablecoin in the EU.

How long does an EMI licence take in Latvia? Latvijas Banka decides within three months of confirming that the application is complete, with a separate completeness check of about 15 working days beforehand. The deadline can be extended where the information submitted is insufficient, so the realistic timeline depends mostly on the quality of the file at first submission.

When to talk to a lawyer

The decisions that determine an EMI application’s outcome – which tier, how funds are safeguarded, how the group is structured, whether a CASP authorisation is needed alongside – are made before anything is filed. If you are weighing an e-money licence in Latvia, or working out whether your product is issuing electronic money at all, get in touch. Related reading: the MiCA/CASP licence in Latvia, choosing a MiCA jurisdiction and asset tokenization in the EU.

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Updated: 3 September 2026. General information only, not individual legal advice. Fees and thresholds are those published by Latvijas Banka at the time of writing; verify the current schedule before relying on them.