A Gibraltar e-money licence is Part 7 permission from the Gibraltar Financial Services Commission (GFSC) under the Financial Services (Electronic Money) Regulations 2020. As of October 2026, you need at least €350,000 of initial capital, a safeguarding arrangement for client funds and a £45,000 application fee. Payment institutions are authorised under the Payment Services Regulations 2020, with lower capital that depends on the services they offer.
At a glance
| Item | Position as of October 2026 |
|---|---|
| Regulator | Gibraltar Financial Services Commission (GFSC) |
| Legislation | Financial Services Act 2019; Electronic Money Regulations 2020; Payment Services Regulations 2020 |
| E-money initial capital | At least €350,000 |
| Payment institution capital | About €20,000 to €125,000 depending on class |
| E-money application fee (2026/27) | £45,000 |
| Typical timeline | 12 to 18 months from project start, by one adviser’s estimate |
| Passport | UK access under transitional arrangements to 31 December 2026; no EU passport |
Which licence do you need: e-money or payment institution?
The choice turns on whether you hold customer value.
- E-money institution (EMI). You issue electronic money: stored value, issued at par against funds received, that customers can spend or redeem later. Prepaid cards, stored-value wallets and multi-currency accounts usually fall here. An EMI can also provide payment services linked to its e-money.
- Payment institution (PI). You execute payments but do not issue stored value. Money remittance, merchant acquiring, payment accounts, payment initiation and account information services are examples.
Banks already holding Part 7 permission do not need a separate payment licence, but they must extend their permission to cover payment services. If your model also involves crypto custody or exchange, you may need DLT or VAA provider permission instead or as well; see our guide to DLT and fintech licensing in Gibraltar.
Both regimes were drawn from the EU’s E-Money Directive and second Payment Services Directive (PSD2) and stayed in Gibraltar law after Brexit. The UK continues to be the main reference point, because Gibraltar’s market access to the UK depends on keeping its rules aligned.
What capital does an e-money institution need?
The Electronic Money Regulations set two tests.
- Initial capital of at least €350,000, in qualifying capital items, held before the GFSC grants permission.
- Ongoing own funds that never fall below the higher of €350,000 and the requirement calculated under Schedule 3. For e-money issuance this uses “Method D”, which is based on average outstanding e-money. The GFSC can adjust the result by up to 20% either way.
Tier 2 capital cannot exceed one third of Tier 1, and at least 75% of Tier 1 must be common equity.
Small e-money institutions
A smaller firm can register as a small EMI if its average outstanding e-money stays at or below €5 million and its monthly payment transactions average no more than €3 million over 12 months. It must be a company with its head office in Gibraltar. Capital is lighter: 2% of average outstanding e-money once that figure reaches €500,000. The GFSC must decide a complete small EMI application within three months. If you breach the limits, you have 30 days to apply for full permission.
What capital does a payment institution need?
The Payment Services Regulations set initial capital through regulations 80 to 83. Gibraltar law firms describe three classes, which the GFSC fee schedule also uses:
| Class | Typical services | Initial capital |
|---|---|---|
| Class A | Money remittance | €20,000 |
| Class B | Payment initiation and account information services | €50,000 |
| Class C | Payment accounts, execution of payments, card issuing and acquiring | €125,000 |
These figures come from a Gibraltar law firm’s published summary and match the PSD2 minimums. A firm can hold only one class, so if your services span two classes you apply for the higher one. Payment initiation firms must also hold professional indemnity insurance or a comparable guarantee.
Smaller firms can sometimes register rather than seek full authorisation. The GFSC fee schedule has a separate registration route for Class A, B and C firms. Ask the GFSC at pre-application stage whether your volumes qualify.
How does safeguarding work?
Safeguarding protects customer money if the firm fails. It is the area the GFSC and auditors examine most closely.
Under the E-Money Regulations you must choose one of two methods:
- Segregation. Keep customer funds apart from your own. Any funds still held at the end of the business day after receipt must go into a designated account at an authorised credit institution, or into secure, liquid, low-risk assets held with an authorised custodian.
- Insurance or guarantee. Cover the funds with an insurance policy or guarantee from an authorised insurer or bank, paying out into a separate account if you become insolvent.
If you fail, e-money holders are paid from the safeguarded pool before other creditors. You must issue e-money at par, redeem it at par on request and state any redemption fee in the contract. You cannot pay interest on e-money balances, take deposits or lend from safeguarded funds.
Payment institutions have an equivalent duty under regulation 84 of the Payment Services Regulations, which was amended with effect from 16 July 2026. Firms serving UK customers should also plan for stricter standards. According to Gibraltar adviser Ramparts, the UK’s new safeguarding rules for payment and e-money firms took effect on 7 May 2026, with daily reconciliations, annual safeguarding audits and resolution packs, and the GFSC intends to introduce equivalent standards in Gibraltar.
How do you apply to the GFSC?
Since 2024 the GFSC has used a staged, risk-based authorisation process. For e-money it runs as follows.
1. Pre-application
Meet the GFSC’s authorisations team to explain the business model. This filters out applications unlikely to succeed before you pay the full fee.
2. Stage 1: threshold conditions
The GFSC assesses the core business model, capital, key individuals and the main elements of your operations. You form a Gibraltar company with local management at this point; our guide to setting up a company in Gibraltar covers incorporation.
3. Stage 2: risk and controls
Risk framework, financial crime and anti-money laundering controls, business continuity, governance and IT systems.
4. Stage 3: conduct and resilience
Non-financial resources, compliance structure, conduct of business, Consumer Duty and operational resilience.
5. Stage 4: mobilisation
For e-money, banking, DLT and some investment firms, a mobilisation stage lets you test systems before going live.
Expect detailed questions on safeguarding, outsourcing, agents and distributors, and how customer funds flow. Agents providing payment services must be registered before they start, and the GFSC has two months to confirm registration. You can distribute and redeem e-money through agents and distributors, but you cannot issue it through them.
How long does authorisation take?
When it launched the staged approach, the GFSC set a target of up to six months for stages 1 to 3 combined, with a further three months for mobilisation in e-money cases, according to Sovereign Group’s summary. Those are targets for the GFSC’s own work, not for your whole project.
Ramparts estimates 12 to 18 months from project start to authorisation, if you answer questions promptly. Banking is often the slowest part: an EMI needs safeguarding accounts and operating accounts, and the banks’ due diligence can run in parallel with the licence. See opening a business bank account in Gibraltar.
How much does a Gibraltar e-money licence cost?
The Financial Services (Fees) Regulations 2020, as amended from 1 April 2026, set these GFSC fees for the 2026/27 fee year:
| Fee | E-money institution | Payment institution |
|---|---|---|
| Application | £45,000 | £11,250 (Class A), £22,500 (Class B), £45,000 (Class C) |
| Registration (smaller firms) | Not applicable | £4,331 |
| Annual base fee | £26,262 | £9,192 plus a class fee of £9,192 to £17,070 |
| Volume-based annual fee | Nil to £45,959 by average outstanding e-money | Nil to £32,839 (Classes A and B) or £45,959 (Class C) by turnover |
| AML supervision fee | £4,017 | £798 |
The e-money application fee rose from £28,875 to £45,000 in 2025/26 and was unchanged for 2026/27. There are smaller fees per agent (£262 a year) and distributor (£133), and a passporting fee of £1,030 for services or £5,150 for an establishment in the UK.
On top of regulatory fees, budget for the €350,000 capital, a Gibraltar office and resident senior staff, audit, a safeguarding audit and legal and compliance advice. Gibraltar corporate tax is 15%.
Can a Gibraltar e-money firm serve UK or EU customers?
UK. Gibraltar e-money and payment firms access the UK under transitional arrangements. The FCA says these run until 31 December 2026 and may be extended until the permanent Gibraltar Authorisation Regime (GAR) under the UK Financial Services Act 2021 is ready. As of late October 2026 no further extension had been announced, so check the FCA’s page before relying on access after that date. Firms passporting into the UK apply through the GFSC, which notifies the FCA.
EU. There is no EU passport. The UK–EU treaty, applied provisionally since 15 July 2026, covers goods, customs and the movement of people, not financial services. It does not restore passporting or give Gibraltar firms access to the EU single market. To serve EU customers at scale you need an EU-authorised entity. Our UK–EU treaty explained for business covers the wider changes, and the licensed sectors hub compares Gibraltar’s other regulated regimes.