Apply for a licence

Electronic Money Institutions


The purpose of this page is to make sure that the application process is fully understood.

This section sets out:

  • What is an Electronic Money Institution ("e-money")?
  • What would this Licence allow you to do?
  • GFSC Policy
  • Guidance/Safeguarding Requirements
  • Capital Requirements
  • What do you need to submit?


Electronic Money Institutions

e–money is electronically, including magnetically, stored monetary value, represented by an issuer which is accepted by a person other than the electronic money issuer. Types of e-money include pre-paid cards and electronic pre-paid accounts for use online.

The regulation of e-money Institutions falls within the scope of the Financial Services (Banking) Act 1992 and, specifically, the Financial Services (Electronic Money) Regulations 2011 (“the Regulations”). e-money Institutions should ensure that they comply with all subsidiary legislation to the Act.

What would this Licence allow you to do?

An e-money Institution is authorised to issue and redeem e-money and this can be done either via a proper establishment, or through an Agent or Distributor.

There are two types of e-money Institutions

  • Authorised e-money Institution; and
  • Registered e-money Institution.

Both these types of e-money Institutions must meet certain standards and provide the necessary information so that the GFSC can monitor and supervise them effectively.

You should note that registered e-money Institutions cannot passport their services.

Agents and Distributors

An e-money Institution may appoint agents and distributors. Agents distribute and redeem e-money, and provide payment services. These must be registered with the GFSC.

Distributors distribute and redeem e-money without providing payment services. The FSC must be notified of these.

Neither an agent nor a distributor can issue e-money, this activity may only be carried out by the e-money Institution.

GFSC Policy

In order to allow the GFSC to carry out its supervisory and regulatory functions the GFSC has established a policy for the supervision of e-money Institutions.

The following conditions are applied to all licences issued to e-money Institutions. They must be complied with money Institutions on an ongoing basis:


  • The e-money Institution has to ensure that the issue of electronic money or other business carried out in reliance upon its licence is not illegal in the country in which any electronic money is issued or other business carried out. Additionally, the e-money Institution must not provide any services which are out of the scope of the issued licence to any person where the provision of such services would be illegal under the applicable law.
  • Confirmation is required that any arrangements with Relevant Parties, Programme Managers and Processors satisfy the Commission's requirements and that such arrangements enable the firm to directly exercise appropriate controls and step-in rights as required for regulatory purposes at any given time.
  • The e-money Institution is required to notify the GFSC of any programme, Programme Manager or relevant party it enters into a new business relationship with.
  • The e-money Institution must, at all times, be able to demonstrate that it is able to safeguard relevant funds and that any risks associated with relevant funds are being proactively managed, do not compromise its financial position nor disadvantage its customers. The firm must ensure that, regardless of where the funds are received, it is always in compliance with the safeguarding of funds requirements.

Guidance - Safeguarding Requirements

  • In accordance with Section 20 of the Regulations, every e-money Institution must satisfy the GFSC that it has adequate arrangements in place to safeguard the funds of customers that have been received in exchange for e-money that has been issued and prevent the use of these funds for the e-money Institution’s own account.

An e-money Institution shall safeguard customer funds by:

  • Ensuring such funds are segregated and are not, at any time, joined with the funds of any other person or firm; or
  • Ensuring such funds are covered by an insurance policy or similar guarantee which does not belong to the same group as the e-money Institution itself for an amount equivalent to that which would have been segregated in the absence of the insurance policy or such. This should be payable in the event that the e-money Institution is unable to meet its financial obligations.


Additionally an e-money Institution that holds customer funds must keep such records and accounts as are necessary to enable them at any time and without delay to distinguish funds held for one customer from another and from the funds of the e-money Institution.

Capital Requirements

An authorised e-money Institution is required to hold an initial and ongoing capital of:

  • €350,000; or
  • 2.2%* of the average outstanding electronic money (as projected at application), whichever the highest.

A small or registered e-money Institution is required to hold an initial and ongoing capital of 2.2%* of the average outstanding electronic money.

Firms holding multiple licences may be required to hold the aggregate of the capital required for each licence prior to being permitted to conduct the proposed activity, and on an ongoing basis. The level of capital in these cases will be considered by the GFSC. It is advised that you discuss this with the GFSC ahead of your application.

*Under Schedule 2, paragraphs 15 and 16 of the Financial Services (Electronic Money) Regulations, the GFSC directs that the minimum requirements imposed by the second Electronic Money Directive (2009/110/EC) be increased by 20%.

What do you need to submit?

An application pack is required to be submitted with all the relevant documents.

An application will not be considered complete if there are any outstanding documents.

The application pack must consist of:

Any other document the applicant considers the GFSC should take into consideration as part of the application.

Business Plan

The business plan should clearly and comprehensively set out:

  • The firm’s proposed activity and how it will be conducted
  • The resources that will be made available and the systems that the applicant intends to employ
  • How clients will be attracted and sourced
  • What arrangements will be put in place to safeguard customer monies and/or assets
  • How records will be maintained
  • How, and by whom, any significant decisions will be made
  • How the firm intend to identify, manage, monitor and mitigate any risks posed to the firm
  • Details of Agents and/or Distributors to be appointed and countries/jurisdictions in which it will provide its services including whether these services will be passive or active
  • How the firm complies with the Anti-Money Laundering requirements
  • The level and nature of fees to be charged to the firm’s clients
  • If the applicant forms part of a larger group, details should also be provided of the activities of the group and a description of their structure

The GFSC will also be seeking evidence that the firm has considered the risk, compliance and operational issues associated with the proposed e-money activities, as well as evidence that these have been documented and implemented.

Applicants should ensure that the business plan is coherent with the firm’s risk appetite and capacity.

Application Forms

Should you get an error when opening any of the forms, please check the FAQ tab for guidance on how to override this.

  Application Form

Royal Gibraltar Police Vetting Form

Please note that an 'Individual Questionnaire' or a 'Notifiable Document' MUST be accompanied by a Royal Gibraltar Police vetting application form.  

  Individual Questionnaire
  Body Corporate Questionnaire
  Trust Questionnaire

Where a trust is proposed as part of the shareholding structure of an applicant, the GFSC will need sight of a comprehensive explanation setting out the rationale for the use of such a vehicle within the structure.


Furthermore, the following is required to be submitted together with the Questionnaire


  1. Copy of the trust deed
  2. A written undertaking from the respective trustees to the effect that:
    • the provisions of the trust(s) in respect of beneficiaries, trustee(s) and terms of settlement are as contained in the relevant deed(s) dated [xxx],
    • the resignation of any trustee and, where appropriate, protector will be notified to the Commission forthwith,
    • no other trustee(s) or any additional or different protector(s) will be appointed, without the prior approval in writing of the Commission,
    • any proposed changes to the beneficiaries must be notified in writing to the Commission,
    • any proposed distribution or transfer for value or otherwise of any of the trust assets related to the applicant firm must receive the prior approval in writing of the Commission.
  3. Confirmation from the trustee(s) that they understand that failure to adhere to their undertaking may result in regulatory action against the applicant/regulated firm.

In addition to the Trust Questionnaire and the above listed information, the Applicant is also required to submit Individual Questionnaires for the settlor(s) and any named beneficiaries. This will not apply in cases where the beneficiary is a minor. In these cases, details of the individual will suffice i.e. name, DOB, address, nationality & passport number. When the trust is for example a discretionary family trust where not all beneficiaries are named (i.e. refers to spouse and children/issue of Mr X but does not actually name these individuals) a copy of the ‘letter of wishes’ of the Settlor, if any, will also be required.

In principle, the GFSC does not favour the use of nominee shareholdings for the purposes of holding shares, directly or indirectly, in a regulated firm. The Commission will therefore require that the applicant submit a paper setting out the rationale for the use of these structures in each instance where this is being proposed. This should include comprehensive details as to why it is necessary to hold the shares in this way.


  Electronic Money Quarterly Supervisory Return

Application Fees

The application fee must accompany your application. Please note, if you are applying for more than one licence, aggregate fees will apply.

Type Nature of Application Application Fee
Electronic Money Institution Application to be Licensed £27,500
Electronic Money Institution Notification of intention to appoint an agent £250
Electronic Money Institution Notification of intention to engage a distributor £150
Electronic Money Institution Application to extend permitted activities £3,500

Annual Fee

The annual fee is not payable until your application is approved. For details of these please refer to the current Fee Regulations.

Under the GFSC’s annual fee methodology you pay a minimum base fee which is dependent on the set fee block assigned to your regulated sector. In addition to the base fee, you are also required to pay an additional amount that will be calculated based upon a range of factors including activity and income. To calculate the additional part of your annual fee the GFSC will need to review audited financial data and/or supervisory returns. At licensing stage, you will not yet have the requisite audited financial data or supervisory returns available for the GFSC to calculate the additional part of your annual fee. On this basis, the GFSC will only require you to pay the base fee at this stage and, towards the end of the GFSC’s financial year end (31 March), you will then be invoiced for the remainder of the annual fee which will be calculated based upon the financial data and/or supervisory returns provided by you up until that date.

Details on the payment methods can be requested from the Accounts team.

Service Level Standards

The current service level standards are:

  • To provide initial feedback to an application within 5 weeks of a complete application being received.
  • Once all of the information has been received from an applicant and the application is therefore considered to be complete, we aim to provide an in principle decision within 4 weeks.

Please be advised that the above service level standards refer to the period of time in which the GFSC holds applications for consideration. Where we require further information or documents from an applicant the service level standards will be suspended until we receive the requested information. The period of time an application is pending because of factors outside the control of the GFSC will not be accounted for under the service level standards.

Please note that should we be unlikely to meet our SLS’s, we will advise you as soon as possible.

The purpose of this page is to set out:

  • What is an extension?
  • What do you need to submit?
  • Guidance

What is an extension?

Firms or individuals that are already licensed by the FSC may apply to extend their authorisation/licence to provide additional financial or professional services.

If you are seeking a licence, authorisation or registration under a separate Act, please contact the Authorisation team so that we can determine what documents you are required to submit.

What do you need to submit?

An application pack is required to be submitted with all the relevant documents.

An application will not be considered complete if there are any outstanding documents.

The application pack must consist of:

  • Application Fee (if applicable)
  • Revised Business Plan
  • Financial projections for the the next 3 years, clearly identifying the impact of the additional business
    • Profit and loss account
    • Balance sheet
    • Returns (these need to be on a quarterly basis for the first year and then annually for the following 2 years)
  • Individual Questionnaire (for any new individual holding a notifiable position)
  • Body Corporate Questionnaire (for any new entity within the structure)
  • Trust Questionnaire (if applicable)

Any other document the applicant considers the FSC should take into consideration as part of the application.


The licensee should consider and provide information on the following:

  • What new licence/authorisation it requires
  • The type of new business/activity
  • Where the business will be sourced
  • Resources to deal with the additional business
  • The impact of the additional business on its capital requirements
  • What changes are being effected to its systems and controls.