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Digital Payments & Fintech · Austria

EMI license in Austria: e-money institution (EMI) requirements (2026)

Licensing regimeCountry index 90 · A+

Austria shaded by its digital payments & fintech status

Fintech and digital payments in Austria: licensing regime.

FrameworkPayment Services Act 2018 (Zahlungsdienstegesetz 2018 / ZaDiG 2018) transposing PSD2, E-Money Act 2010 (E-Geldgesetz 2010) transposing EMD2, and the Banking Act (BWG); supervised by the Financial Market Authority (FMA) with the Oesterreichische Nationalbank (OeNB) overseeing payment infrastructure.

Austria operates a clear, in-force licensing regime for payments and e-money as an EU member state, with PSD2 transposed via ZaDiG 2018 and e-money issuance regulated under the E-Geldgesetz 2010. The FMA is the sole competent authority for granting Payment Institution (PI) and Electronic Money Institution (EMI) licences, with EU passporting available and open banking obligations enforced through PSD2 RTS. The SEPA Instant Payments Regulation obligation to send/receive instant payments applied from October 2025, and the new Consumer Credit Act (VKrG 2026 / VerKrAG 2026) implementing EU Directive 2023/2225 brings BNPL within scope from 20 November 2026.

How to get an EMI license in Austria

To provide electronic-money or payment services in Austria you need authorisation as an Electronic Money Institution (EMI), supervised by the Austrian Financial Market Authority (FMA), under the EU E-Money Directive (2009/110/EC) and the Second Payment Services Directive (PSD2).

Authority
the Austrian Financial Market Authority (FMA)
License required
authorisation as an Electronic Money Institution (EMI)
Framework / law
the EU E-Money Directive (2009/110/EC) and the Second Payment Services Directive (PSD2)
Minimum capital
€350,000 initial capital for a full (Authorised) EMI; a lighter Small EMI regime exists below an average €5m of outstanding e-money
Timeline
roughly 3–12 months; the regulator has up to 3 months to decide once the application is complete
Cost
application and supervisory fees that vary by country (often €5,000–€25,000), plus safeguarding and audit costs
Passporting
Yes — an EMI authorisation passports across the whole EEA (all 27 EU states plus Norway, Iceland and Liechtenstein).

What an EMI license in Austria covers

  • Issuing electronic money and maintaining payment accounts
  • Executing payment transactions: credit transfers, direct debits and card payments
  • Issuing and/or acquiring payment instruments
  • Money remittance
  • Payment initiation services (PIS)
  • Account information services (AIS)

How to get an EMI license in Austria: step by step

  1. 1Incorporate in the member state and establish real local substance (registered office and part of the business conducted there).
  2. 2Build the application file: programme of operations, three-year business plan, governance, AML/CFT, safeguarding and security policies.
  3. 3Deposit and evidence the €350,000 initial capital.
  4. 4Submit the application to the national competent authority.
  5. 5The authority has three months from a complete application to grant or refuse.
  6. 6On authorisation you are entered in the national and EBA registers, then passport into other EEA states before serving them.

Documents required in Austria

  • Programme of operations listing each payment service you will provide
  • Business plan with a three-year budget forecast
  • Evidence of the €350,000 initial capital
  • Governance arrangements and internal-control mechanisms
  • AML/CFT policy and appointment of a compliance officer
  • Safeguarding arrangements for client funds (segregated account or insurance)
  • Security policy, incident management and ICT resilience procedures
  • Fit-and-proper documentation for directors and qualifying shareholders
  • Description of any outsourcing, agents or distributors
  • Professional indemnity insurance where you provide PIS or AIS

After authorisation: ongoing obligations in Austria

  • Maintain own funds under the applicable calculation method (A, B or C)
  • Safeguard client funds at all times, segregated or insured
  • Apply strong customer authentication (SCA) under PSD2
  • Run continuous AML/CFT monitoring and reporting
  • Report major operational and security incidents to the regulator
  • Submit annual audited accounts and periodic regulatory reporting

EMI license in Austria: FAQ

Do you need a license to run an e-money business in Austria?

Yes. To provide electronic-money or payment services in Austria you need authorisation as an Electronic Money Institution (EMI), supervised by the Austrian Financial Market Authority (FMA), under the EU E-Money Directive (2009/110/EC) and the Second Payment Services Directive (PSD2).

Which authority issues EMI licenses in Austria?

The Austrian Financial Market Authority (FMA).

How much does an EMI license cost in Austria?

Application and supervisory fees that vary by country (often €5,000–€25,000), plus safeguarding and audit costs.

How long does it take to get an EMI license in Austria?

Typically roughly 3–12 months; the regulator has up to 3 months to decide once the application is complete.

What documents do you need for an EMI license in Austria?

The application file centres on programme of operations listing each payment service you will provide; business plan with a three-year budget forecast; evidence of the €350,000 initial capital; governance arrangements and internal-control mechanisms; plus fit-and-proper evidence for directors and qualifying shareholders.

What is the application process for an EMI license in Austria?

Incorporate in the member state and establish real local substance (registered office and part of the business conducted there). Build the application file: programme of operations, three-year business plan, governance, AML/CFT, safeguarding and security policies. The authority then assesses the file and, once authorised, you can begin operating.

Does an Austria EMI license work in other EU/EEA countries?

Yes — an EMI authorisation passports across the whole EEA (all 27 EU states plus Norway, Iceland and Liechtenstein).

Key points

Payment institution licensing (ZaDiG 2018)

The FMA grants licences to Payment Institutions under Section 1 of Chapter 2 of ZaDiG 2018, covering all eight PSD2 Annex I service categories (credit transfers, direct debits, card acquiring/issuing, money remittance, account information, payment initiation, account operation). Authorised Austrian PIs passport into the EU 27 plus EEA under Articles 28-29 PSD2 via FMA notification.

E-money institution regime

Commercial issuance of electronic money in Austria requires a dedicated licence as an Electronic Money Institution (E-Geld-Institut) from the FMA under the E-Geldgesetz 2010, subject to limited Article 2(2) exemptions. EMIs are supervised separately from PIs pending the PSD3/PSR merger.

Open banking (PSD2 AISP/PISP)

AISPs and PISPs are registered/licensed by the FMA under ZaDiG 2018, with strong customer authentication and secure communication requirements set by Delegated Regulation (EU) 2018/389. Austrian banks implement the Berlin Group NextGenPSD2 API standard; major institutions (Erste, Raiffeisen, UniCredit Bank Austria, BAWAG) expose compliant APIs.

Instant payments rail

Austria participates in SEPA Instant Credit Transfer (SCT Inst) since 2017 and TARGET Instant Payment Settlement (TIPS) since November 2018, with OeNB providing national payment infrastructure. Under the EU Instant Payments Regulation (Regulation (EU) 2024/886), PSPs in Austria have been required to send and receive euro instant credit transfers 24/7 since 9 October 2025, alongside the mandatory verification-of-payee (VoP) service.

BNPL brought into consumer credit scope

The Austrian Consumer Credit Act 2026 (VerKrAG 2026 / VKrG 2026), transposing EU Directive 2023/2225 (CCD II), enters into force on 20 November 2026 and abolishes the previous EUR 200 de minimis threshold. All forms of payment deferrals, interest-free loans, and small loans - explicitly including BNPL and instalment models such as Klarna and PayPal Pay Later - are captured, with limited carve-outs for standard merchant payment deferrals and deferred-payment debit cards.

FMA FinTech Navigator and regulatory sandbox

The FMA operates a FinTech Point of Contact and a regulatory sandbox (introduced in 2020) to guide firms through the ZaDiG 2018, E-Geldgesetz 2010 and BWG licensing analysis. The FinTech Navigator publishes a domain-specific decision aid for digital payments licensing.

Timeline - major decisions & events

Dec 31, 2025guidanceofficial
Deadline for existing Austrian crypto firms to obtain MiCAR authorisation

Under the Austrian MiCA-VVG transitional regime, crypto-asset service providers previously registered as VASPs had to be authorised by the FMA as CASPs by 31 December 2025 or cease activities. It marks the end of the grandfathering window that closed the old AML-only registration era.

FMA
Apr 1, 2025decisionofficial
FMA grants first MiCAR CASP authorisation in Austria (Bitpanda)

The FMA authorised Bitpanda GmbH as a crypto-asset service provider under Article 63 MiCAR, the first full MiCA licence issued in Austria; its prior FM-GwG VASP registration lapsed automatically. It signalled the FMA operationalising the new EU crypto licensing regime.

FMA
Jan 17, 2025lawofficial
DORA and Austrian DORA Enforcement Act enter into application

The EU Digital Operational Resilience Act became applicable with no transition period, backed by Austria's DORA-Vollzugsgesetz, imposing ICT-risk-management, incident-reporting and third-party-oversight duties on FMA-supervised payment and fintech firms. It made operational resilience a licensing-relevant compliance obligation.

FMA
Jul 20, 2024lawofficial
Austrian MiCAR Enforcement Act (MiCA-VVG) enters into force

Passed by the National Council on 3 July 2024 and published in Federal Law Gazette I No. 111/2024, the MiCA-Verordnung-Vollzugsgesetz designated the FMA as supervisor and set transitional rules for existing providers. Austria was among the first EU states to put a MiCAR-compliant national framework in place.

FMA
Sep 1, 2020lawofficial
FMA regulatory sandbox established (FMABG §23a)

An amendment to the Financial Market Authority Act created a formal regulatory sandbox letting fintech, DLT and AI firms test innovative business models under FMA supervision for up to two years. It gave emerging payment and crypto startups a structured path toward licensing.

FMA
Jan 10, 2020lawofficial
Virtual asset service providers brought under FMA registration (FM-GwG)

Implementing the EU's 5th Anti-Money-Laundering Directive, the Financial Markets Anti-Money Laundering Act required crypto exchanges, custodial wallet providers and similar firms to register with the FMA for AML/CTF purposes. It was Austria's first dedicated regulatory touchpoint for crypto businesses.

FMA
Jun 1, 2018lawofficial
Payment Services Act 2018 (ZaDiG 2018) transposes PSD2

ZaDiG 2018 implemented the second Payment Services Directive, introducing licensing/supervision for payment initiation and account information service providers and strong customer authentication. It established the modern licensing framework for Austrian payment institutions and fintechs.

FMA
Apr 30, 2011lawofficial
E-Money Act 2010 (E-Geldgesetz 2010) enters into force

Adopted 23 December 2010 and effective 30 April 2011, the E-Geldgesetz transposed Directive 2009/110/EC, creating a dedicated FMA licensing regime for e-money institutions issuing prepaid electronic payment instruments. It remains the legal basis for e-money licensing in Austria.

European Commission

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