Electronic Money Institution vs Payment Institution - PSP Lab (2022)

Electronic Money Institution vs Payment Institution - PSP Lab (1)

If you are thinking about entering PayTech market in the EU or UK as a non-bank service provider you have a choice of becoming an Electronic Money Institution vs Payment Institution. If you are a new player, the difference between EMIs and PIs may not be so obvious to you. Fortunately for you, we got you covered. In this article, we will explain the practical and legal differences between these two types of licenses.

Electronic Money Institution vs Payment Institution (Services)

To understand what is the difference between these two types of financial service providers we will need to outline what is their respective rationale of creation and what specific services they can provide. It is a core aspect which differentiates between them, so pay close attention.

What is an Electronic Money Institution or a so-called E-money Institution?

Many people are still trying to understand what are Electronic Money Institutions a.k.a. E-money Institutions or EMIs. These terms refer to a legal person that has been authorised to issue electronic money under one of the Member State’s national implementation of Title II of the Directive 2009/110/EC, known as the Electronic Money Directive 2 (EMD2). While many types of financial institution are allowed to issue e-money (these institutions are called E-money Issuers), an Electronic Money Institution (EMI) is a type of financial institutions that was created specifically for the purpose of e-money issuance and there is a specific authorisation regime for EMIs.

Unlike banks, which can also issue e-money, EMIs are not subject to such strict prudential requirements (to understand better the difference between EMIs and banks read our article). Why would somebody want to create a specific regulatory regime for entities focused on the issuance of e-money? The answer is easy. Such a regime exists to spur innovation in the payments sector.

If you need you can read our more detailed explanations of EMIs in the UK and EMIs in Lithuania.

What is a Payment Institution?

A Payment Institution or PI, on the other hand, refers to a category of payment service providers that was created as a result of the adoption of Directive 2007/64/EC known as the Payment Services Directive 1. The activities of PIs are now broadly regulated under Directive (EU) 2015/2366, known as the Payment Services Directive 2 (PSD2) and its national implementation.

To read more about PIs you can read about PI license in the UK, PI license in Lithuania, and so-called Payment Initiation Service Provider license (PISP license) and money transmitter license in the UK.

What services can EMIs provide?

As it was explained EMIs can issue e-money. To understand this service you should know what is e-money and how it is different from scriptural money, fiduciary money and other types of monetary value. We advise you to read our article explaining what is e-money.

Besides issuing e-money, according to Article 6 of the EMD2 and its national implementation in each EU MS and UK, EMIs can also provide all payment services that can be provided by Payment Institutions as provided in Annex 1 to Directive (EU) 2015/2366, known as the Payment Services Directive 2 (PSD2), credit services as explained in Article 18 (4) of the PSD2, operational and closely related ancillary services such as ensuring the execution of payment transactions, currency exchange services, safekeeping activities, the storage and processing of data, and the operation of payment systems as explained in Article 18(1)(b) of the PSD2. Thus, conduct rules of the PSD2 and its national implementation are applicable to EMIs as well as PIs.

When we speak about payment services provided by EMIs you should understand two things. Firstly, when we say EMIs can provide all payment services provided in Annex 1 to PSD2 it does not mean that all EMIs provide such services or that EMIs are automatically allowed to provide such services. An applicant applying to be authorised as an EMI to one of the national regulators must indicate for what kind of payment services it wants to get the authorisation.

Secondly, it is important to understand what payment services are linked (related) to e-money issuance and what payment services are unrelated to e-money issuance. Such distinction is important as prudential requirements are different for related and unrelated payment services provided by EMIs. For instance, in the UK the FCA further clarifies that when e-money account holders use their e-money to make a payment or to simply transfer funds from their account, this would not constitute an unrelated payment service as it relates to the activity of issuing e-money.

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What services can PIs provide?

PIs can offer payment services explained above, but they cannot issue e-money. The possibility to issue e-money is the difference between an Electronic Money Institution vs Payment Institution (EMI vs PI). Because of this one difference, PIs and EMIs have different business models due to the different legal treatment of payments accounts provided by PIs and EMIs as explained below.

Electronic Money Institution vs Payment Institution (E-money vs Payment account)

Under Article 4(12) of the PSD2, a payment account is defined as an account held in the name of one or more users of the payment service that is used for making payment transactions. Similarly, Article 2(3) of the Directive 2014/92/EU on the comparability of fees related to payment accounts, payment account switching and access to payment accounts with basic features, a payment account entails an account held in the name of one or more customers used for the execution of payment transactions.

Based on these definitions, so long as the account allows for payment transactions to be conducted by authorised users, it is considered a payment account.

Before delving into how a payment account is different from an e-money account, and thus, considering one of the most crucial differences between Electronic Money Institution vs Payment Institution, it is important to understand that EMIs, PIs, and banks are all able to provide payment accounts. Electronic money accounts (i.e. e-wallets), bank accounts, and accounts opened by PIs are all payment accounts as they are used for the execution of payment transactions.

Nevertheless, as the Bank of Lithuania has stated, the functionality of these payment accounts is different. This difference is important to distinguish as, although both accounts can be used to send money and make transfers, the nature of the transaction differs. To read more about the difference between a payment account and an e-wallet, read our article on the matter.

For instance, the user of an e-wallet is free to use his/her account as he/she wishes, meaning that he/she can withdraw money from it, make transfers to bank accounts, make purchases, pay for utility bills, and many other uses. It is worth clarifying however that as per Recital 13 of the EMD, e-money is not a deposit-taking activity. As such, although an e-money account can be used for a variety of activities, what distinguishes it from a deposit is the fact that e-money stored in an e-money account cannot be used by non-electronic means, i.e. it is generally the case that if cheques can be drawn from an account, chances are that that is a deposit rather than an e-money account.

Payment accounts provided by Payment Institutions are on the other hand more limited. The reason for that is the fact that in order to make use of your account, there must be an identifiable transaction for which the funds are sent to the entity processing the payment. Meaning that payment account requires a standing order based on which the funds will arrive to and leave from the account.

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Electronic Money Institution vs Payment Institution (Business Models)

The EBA in its report on the risks and opportunities from fintech and their impact on business models stated that the business models of EMIs and PIs are shaped based on (a) customer expectations/behaviour, (b) competitive pressure, (c) technological advancements as well as (d) changes in regulation. These considerations play a core role in firms choosing which services they will offer.

A good example of the difference in terms of the business model and services offered between Electronic Money Institution vs Payment Institution is Transferwise. Transferwise started out as a PI but because with this license it was not able to issue its own cards to customers and hold customer money in payment accounts without an identifiable payment order, it switched from PI to EMI. Now, the business model of the company revolves around card issuance and the provision of borderless multicurrency accounts.

As you can see PIs can legally choose business models where they do not need to hold customer money in payment accounts without an identifiable payment order. Services that PIs usually provide are payment processing and money remittance. There are also PISPs which only provide payment initiation service.

Of course, there are more complicated business models. For example, even PIs can participate in a co-branding card issuance program or indirectly offer e-money accounts for its merchants. You should contact a professional consultancy like PSP Lab to be aware of all available options and decide between Electronic Money Institution vs Payment Institution.

Electronic Money Institution vs Payment Institution (Safeguarding Requirements)

Both EMIs and PIs are subject to specific safeguarding requirements set out in Article 7 of the EMD2 and Article 10 of the PSD2. Nevertheless, PIs that only offer payment initiation or account information services are not subject to safeguarding requirements.

Funds received by an EMI for both services related to e-money issuance and unrelated payment services, should not be held in the same safeguarding account.

Electronic Money Institution vs Payment Institution (Initial Capital requirements)

The difference between Electronic Money Institution vs Payment Institution (EMI vs PI) in terms of the differences between the payment account and the e-money account is important for highlighting regulatory requirements. Due to the risk, a payment user is subject to, the initial capital requirements for PIs are considerably lower than those for EMIs.

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Under Article 7 of the PSD2, PIs have to hold at the time of authorisation an initial capital of:

  • EUR 20,000 when a PI provides only money remittance
  • EUR 50,000 when a PI provides only payment initiation services;
  • EUR 125,000 a PI provides only services listed in points 1-5 of Annex I of the PSD2.

At all times, authorised PIs are also required to hold own funds equal to or in excess of the required initial capital required for the chosen services to be offered, or the amount of the own funds required as per method A, B, or C as explained in PSD2

Article 4 of the EMD2 on the other hand states that EMIs must have an initial capital requirement of EUR 350,000. Authorised EMIs are at all times required to hold own funds equal to or in excess of the greater of the amount of initial capital and the amount of own funds calculated as per method D which consists of the 2% of the average outstanding e-money issued by the EMI. However, for unrelated payment services, an EMI must use method A, B, or C.

Electronic Money Institution vs Payment Institution (EMI vs PI Licensing costs)

In the table below you will find information on the licensing fees for both authorisations in all the countries in which PSP Lab offers its services.

Electronic Money Institution vs Payment Institution - PSP Lab (2)

How can PSP Lab help?

Electronic Money Institution vs Payment Institution what will you choose? If you don’t know you can contact PSP Lab, which is a fintech consultancy that offers authorisation services not only for EMIs and PIs but also for small EMIS, for small PIs, Account Information Service Providers (AISP) and Payment Initiation Service Providers (PISP). Our experience will guide you through the process of selecting the right authorisation as well as through the application process in a swift manner.

Should you have any questions relating to the difference between Electronic Money Institution vs Payment Institution do not hesitate to contact us. We are happy to help!

FAQs

What is an electronic payment institution? ›

Simply put, an authorised e-money institution is a limited version of a bank that can only provide payment services and hold funds of its clients.

Is an EMI a PSP? ›

A payment service provider (PSP) is a third-party financial institution that carries out payment services. APIs and EMIs are simply two different kinds of PSP.

Is an EMI a financial institution? ›

An electronic money institution (EMI) is not a bank. Although people often use these words interchangeably, they refer to different things. Banking regulations and operations differ from those of an… An electronic money institution (EMI) is not a bank.

What is payment institution? ›

What is a Payment Institution? The term “Payment Institution” refers to a category of payment service providers which came into being as a result of the enactment of the Payment Services Directive (PSD).

Is PayPal an electronic money institution? ›

What is e-money? E-money (including prepaid cards and accounts) is money that's stored in electronic form which can be used to make payments - a well-known example is PayPal.

How do I become an electronic money institution? ›

If you want to issue electronic money (e-money), you must be registered or authorised by us as an EMI, in accordance with the Electronic Money Regulations 2011 (EMRs). EMIs need to comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.

Is an MSB a PSP? ›

First of all, you should understand that PSPs and EMIs are both European terms. In other countries they are referred to by other terminology: for example, MSB (Money Service Business). MSBs are more equivalent to PSPs than EMIs. The terms EMI and PSP refer to different kinds of licenses granted under European law.

What does PSP stand for in payments? ›

What are Payment Service Providers (PSPs)? PSPs (also called Merchant Service Providers) are third-party companies that help business owners accept a wide range of online payment methods, like online banking, credit cards, debit cards, e-wallets, cash cards, and more.

What's the difference between EMI and a bank? ›

EMIs adopt the widest possible spread of options and provide their customers with choices. When it comes to the movement of money, whereas banks work with limited services for card payments and wire transfers, EMIs can have many different payment options that may be better for their clients.

What is an electronic money institution UK? ›

Electronic Money Institution (EMI) in the UK is allowed to issue and redeem electronic money. Electronic money is a digital equivalent of cash stored on an electronic device or remotely at a server. Additionally, EMIs can be authorised to provide all of the services of a Payment Institution.

Can a payment institution issue cards? ›

Any authorised payment service provider, be it a bank or a payment institution, can issue payment instruments. Payment instruments do not only cover payment cards, such as debit cards and credit cards, but any personalised device or set of rules agreed between the issuer and the user used to initiate a payment.

Who is an electronic money issuer? ›

Electronic Money Institutions (EMIs) are the digital alternative of banks, operating through an online platform and licensed to manage transactions and issue debit cards. EMI clients can use either the platform or their issued debit card to carry out payment transactions.

Is Visa a payment institution? ›

Key Takeaways. Visa is a digital payments company providing transactions between consumers, merchants, and banks and other financial institutions.

What can an EMD agent do? ›

These 'Payment Services Directive (PSD) Agents' or 'Electronic Money Directive (EMD) Agents', collectively 'Agents', are able to conduct business, seemingly on behalf of one or more 'Principal' firms, to the extent of the permission held by the Principal firm.

What is an e-money license? ›

An e-money licence allows you to offer payment services and some other financial services products, but not operate as a bank or use 'bank' in your name or marketing materials. Broadly speaking, e-money institutions can: Accept customer funds and change them into e-money, but not manage them.

What are the types of electronic money? ›

Electronic money can be classified into two broad categories:
  • Hard. Hard electronic money is when e-money is used for irreversible transactions, ones that are highly securitized, and are more or less procedural in nature. ...
  • Soft. Soft electronic money is when e-money is used for reversible or flexible transactions.
3 Feb 2021

Are electronic money institutions safe? ›

Electronic Money Institutions are safe. Even though they are commercial bodies, they follow lots of governmental regulations and have all necessary functions for ensuring the customers' financial security.

Why is PayPal shutting down accounts? ›

(Bloomberg) — PayPal Holdings Inc. said it closed 4.5 million accounts and lowered its forecast for new customers after finding “bad actors” were taking advantage of its incentives and rewards programs. Shares of the company fell by the most on record.

Do I need an EMI Licence? ›

In establishing or setting up an electronic money institution (EMI), intending EMIs owners must obtain licensing from the FCA. Although a separate approval to provide payment services is not required, the EMIs must notify FCA of the payment services they intend to provide.

What is Railsbank? ›

Railsr is a banking and compliance platform that connects together a global network of partner banks with companies who want API access to banking. The company was formerly known as Railsbank and rebranded to Railsr in June 2022. Railsr was founded in 2015 and is based in London, England.

What is an EMI BSP? ›

Under Section 702 of the Manual of Regulations for Banks (MORB) issued by the BSP, e-money is defined as the monetary value, as represented by a claim on its issuer, that is: a. electronically stored in an instrument or device; b.

Is an MSB a financial institution? ›

Note: Each money services business (MSB) is a financial institution. For the regulatory definition of "financial institution," see 31 CFR 1010.100(t) (formerly 31 CFR 103.11(n)).

Do all MSBs have to register with FinCEN? ›

Every MSB must register with FinCEN by electronically filing FinCEN Form 107, Registration of Money Services Business, unless a person or business is only an MSB because they serve as an agent of another MSB.

What is MSB in AML? ›

A money service business is a non-bank financial institution that lets customers trade exchanges, store value, and transfer money. Like banks, money service businesses are also subject to the Bank Secrecy Act (BSA) and AML regulations. MSB is used as an umbrella term for financial services.

What is PSP and PSO? ›

Payment System Operator and Payment Service Provider (PSO and PSP) means such Authorized Party that is a company registered under Companies Ordinance 1984 and is engaged in operating and/or providing Payment Systems related services like electronic payment gateway, payment scheme, clearing house, ATM Switch, POS ...

Is Shopify a PSP? ›

PayPal, Square, Shopify Payments, and Stripe are all PSPs. Also called third-party processors or aggregators, PSPs accept merchants before officially reviewing them for eligibility.

What is the difference between a payment service provider and a payment gateway? ›

The main difference is that the PSP hold the contracts with the banks and acquirers, whereas a payment gateway provider agrees contracts directly with you, the merchant. Unlike payment gateways, PSP service providers offer a full service, not only processing payments but collecting funds as well.

What's the difference between PSP APM and payment gateway? ›

A PSP provides a merchant account and payment gateway for the collection and management of payments. Whereas, a payment gateway is a software behind credit card transactions between a merchant and their customers.

What is an EMI Fintech? ›

Electronic money, or e-money, has simplified our lives as the fintech industry develops new technologies to make purchasing goods and services more accessible. Suppose you want to offer payment services as an Electronic Money Institution (EMI) in Europe.

What currency is EMI? ›

The EMI was the key monetary institution of the second phase of the Economic and Monetary Union of the European Union. The EMU encouraged cooperation between the national banks of the member states of the European Union (EU) and laid the foundation for the euro.

What is an EMI Licence UK? ›

An Electronic Money License acts as authorization provided by the FCA (which acts as sole regulator) for an Electronic Money Institution to conduct its business. This generally has fewer requirements for approval from the FCA but also comes with fewer protections than a conventional banking license would.

What are PSR regulations? ›

The PSR's regulatory tools include legislation, rules issued by the PSR (called general directions and requirements), written guidance, and decisions (sometimes called specific directions and requirements).

Who regulates payment services in the UK? ›

PSR works with HM Treasury.

What is the difference between PSD1 and PSD2? ›

The difference between PSD1 and PSD2 is that the latter is an updated version that broadens the scope of its predecessor. PSD2 recognises third-party players, acknowledges a wider range of payment transactions and addresses some of the shortcomings of PSD1 as technology developed.

Are payment service providers regulated? ›

All non-bank payment service providers (ie APIs, EMIs and SPIs) must be authorised or registered with us. You can contact us for more information about regulated firms. Some of these non-bank providers may trade under different names than the one authorised or registered with us.

What is PSD2 compliance? ›

What is PSD2? The revised Payment Services Directive 2 (PSD2) aims to better align payment regulation with the market and technology's current state. It introduces security requirements for the initiation and processing of electronic payments and the protection of consumers' financial data.

Which of the following is an example of electronic money? ›

E-Money can be held on cards, devices, or on a server. Examples include pre-paid cards, electronic purses, such as M-PESA in Kenya, or web-based services, such as PayPal. As such, e-money can serve an umbrella term for a number of more specific electronic value products and services.

How is electronic money issued? ›

Electronic money is stored monetary value in the form of a claim against the electronic money issuer by the electronic money holder, which: is in electronic form, including magnetic form, is issued by the electronic money issuer on the basis of receipt of cash for the purpose of executing payment transactions, and.

Is Bitcoin electronic money? ›

As such, bitcoin is a digital currency but also a type of virtual currency. Bitcoin and its alternatives are based on cryptographic algorithms, so these kinds of virtual currencies are also called cryptocurrencies.

What is PSP in banking? ›

PSP is banking company that is a member of UPI and connects to the UPI platform for providing UPI payment facility to the PSP and TPAP which in turn enables the Users and merchants to complete payment transactions over UPI.

Are worldpay a PSP? ›

Government Banking's contracted payment service provider (PSP) is currently Worldpay.

Is Paytm a PSP? ›

Paytm is the largest payment enabler in India which ensures high success rates of digital payments. Also, it is the acquiring PSP, issuing PSP, and owns its payment gateway. Some impressive numbers about the Paytm Payment Gateway that you can rely on are: 400 million transactions per month.

Who can be a PSD agent? ›

Under the Payment Services Directive 2 (PSD2), a PSD Agent UK is a legal or natural person acting on behalf of a UK Payment Institution (PI) or Electronic Money Institution UK (an entity with EMI license UK), Small Payment Institution UK (Small PI), Small Electronic Money Institution (Small EMI) or Registered Account ...

What is a PSD firm? ›

The firm is the applicant for the purposes of the PSD Individual form. The person whom the form is about is the PSD Individual. This should be the name that is recorded on the front cover of the PSD Individual Form ('Name of individual'). Terms in these notes.

What is a payment services agent? ›

A payment services agent is one that acts for account of a payment institution in the performance of payment services (definition in section 1 of the Financial Supervision Act (Wet op het financieel toezicht)) As a payment services agent is a separate legal entity or natural person, notification is subject to extensive ...

Does Google have a banking license? ›

Google Payment Corp. (GPC) is licensed and regulated as a Money Transmitter by the Banking Department of the State of New York.

What are the types of electronic payment system? ›

The different types of e-commerce payments in use today are:
  • Credit Card. The most popular form of payment for e-commerce transactions is through credit cards. ...
  • Debit Card. Debit cards are the second largest e-commerce payment medium in India. ...
  • Smart Card. ...
  • E-Wallet. ...
  • Netbanking. ...
  • Mobile Payment. ...
  • Amazon Pay.
21 Jun 2021

Is an example of electronic payment system? ›

The most common electronic payment methods include ACH, debit and credit cards, wire and bank transfers, digital wallets, and mobile pay.

What is an electronic payment system why is it important? ›

E-payments allow users to make payments online at any time, from anywhere in the world, and also remove the need to go to banks. Faster electronic payments, like virtual cards, empower businesses to improve security, visibility, and efficiency all while lowering costs and saving time on manual processes.

What is the process of electronic payment? ›

They are also known as online payment systems. Normally e-payment is done via debit, credit cards, direct bank deposits, and e-checks, other alternative e-payment methods like e-wallets, bitcoin, cryptocurrencies, bank transfers are also gaining popularity.

What are the 3 methods of payment? ›

Payment Options
  • Cash.
  • Checks.
  • Debit cards.
  • Credit cards.
  • Mobile payments.
  • Electronic bank transfers.

Why are there different types of payment systems? ›

Banks have developed various payment methods to facilitate the exchange of money that stimulates the growth of commerce, helps economic development and facilitates flexibility with lower transaction costs with security. Various payment systems exist today, ranging from cheque, wire transfer, cards to online transfer.

What is electronic payment system explain its advantages and disadvantages? ›

Electronic payment allows your customers to make cashless payments for goods and services through cards, mobile phones or the internet. It presents a number of advantages, including cost and time savings, increased sales and reduced transaction costs.

How is e payment system better than traditional payment system? ›

E-payment enjoys advantages for it is appropriate, fast, well organised and economic. As long as the user has a computer which is connected to the internet, he will be able to stay inside and complete the whole payment within a very less time. The cost is even less than one percent of that of the traditional way.

What are the features of electronic payment system? ›

Here are some features that are a must consider while evaluating a payment gateway for your needs:
  • Security. One of the most important features to consider in a payment gateway is security. ...
  • Easy integration. ...
  • Detailed reporting. ...
  • Invoicing options. ...
  • Multiple payment options. ...
  • Fast processing speed.
26 Jun 2020

What is the risk in electronic payment system? ›

These risks include everything from chargebacks and fraud to data breaches and payment declines. With more consumers choosing digital payments, it's essential to understand the risks of accepting debit, credit, and prepaid cards.

What are the main concerns about electronic payment? ›

The main drawbacks to electronic payments are concerns over privacy and the possibility of identity theft. Fortunately, there are many safeguards available to protect your sensitive personal information from falling into the wrong hands.

What are the issues in electronic payment system? ›

Electronic payment system are highly expensive because it includes set up cost, machine cost, management cost etc and this mode of payment will take more time than the physical mode of payment. Online shopping are very sensitive to notion that e-commerce is insecure, particularly when it comes to online payments.

Which three steps are involved in making an electronic payment transaction? ›

Online transaction is a payment method in which the transfer of fund or money happens online over electronic fund transfer. Online transaction process (OLTP) is secure and password protected. Three steps involved in the online transaction are Registration, Placing an order, and, Payment.

What is the magic triangle of electronic payment methods? ›

In financial jargon, a magic triangle refers to the three cornerstones of a financial investment: profitability, security and liquidity. Good financial investments offer varying degrees of profitability, security (meaning freedom from major risks) and liquidity (meaning accessibility of assets).

What is e-payment How is it safer than cash payment? ›

E-payments are quick and efficient, and the fund transfer typically takes place instantly. It is a secure mode of making payments. E-payments eliminate the need for cash payments, and funds are transferred directly into mobile wallets or bank accounts linked to the mobile number.

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