Digital Payments & Fintech · Austria
EMI license in Austria: e-money institution (EMI) requirements (2026)
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
- 1Incorporate in the member state and establish real local substance (registered office and part of the business conducted there).
- 2Build the application file: programme of operations, three-year business plan, governance, AML/CFT, safeguarding and security policies.
- 3Deposit and evidence the €350,000 initial capital.
- 4Submit the application to the national competent authority.
- 5The authority has three months from a complete application to grant or refuse.
- 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
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).
The Austrian Financial Market Authority (FMA).
Application and supervisory fees that vary by country (often €5,000–€25,000), plus safeguarding and audit costs.
Typically roughly 3–12 months; the regulator has up to 3 months to decide once the application is complete.
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.
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.
Yes — an EMI authorisation passports across the whole EEA (all 27 EU states plus Norway, Iceland and Liechtenstein).
Key points
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.
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.
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.
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.
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.
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
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 ↗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 ↗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 ↗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 ↗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 ↗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 ↗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 ↗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 ↗Austria - other topics
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