Licence route · AEMI
Authorised Electronic Money Institution
Full e-money authorisation with the most demanding capital, safeguarding and governance expectations. Genesis support for this route is in active development.
In DevelopmentApplication depth: Extensive
Who this route is generally for
E-money issuers above the small-EMI threshold or scaling beyond it.
Typical activity
Issuing electronic money and providing payment services under full authorisation.
Key indicators
Regulatory status
AuthorisedSource: EMRs 2011, reg. 6 · Position at 2026-07-30
Initial capital
€350,000 initial capitalSource: EMRs 2011, Sch. 1 · Position at 2026-07-30
Ongoing own funds
Method D on outstanding e-money, plus payment-service requirementsSource: EMRs 2011, Sch. 2 · Position at 2026-07-30
Safeguarding
Mandatory for e-money float and relevant fundsSource: EMRs 2011, reg. 20 · Position at 2026-07-30
Route indicators are informational and require confirmation against the full business model and applicable law.
How Genesis supports the route
Building an AEMI the regulator expects.
- Determines route eligibility from actual activities and funds flow
- Builds the regulatory business plan and programme of operations
- Constructs the route-specific financial model
- Designs safeguarding where applicable and reconciles it
- Assembles the evidence schedule and challenges the application before submission
Common weaknesses
What delays applications.
- Financial model that contradicts the business narrative
- Safeguarding design that does not reconcile with funds flow
- Governance that exists on paper but not in operating reality
- Evidence gaps against stated regulatory claims
- Permissions that do not match the actual activities
Current Genesis route status: In Development
This route is not yet certified. Support status is shown honestly and updated as it graduates.