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

Yes. To provide electronic-money or payment services in Czechia you need authorisation as an Electronic Money Institution (EMI), supervised by the Czech National Bank (ČNB), under the EU E-Money Directive (2009/110/EC) and the Second Payment Services Directive (PSD2).

The Czech National Bank (ČNB).

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).

Full licensing regime exists under Act No. 370/2017 Coll. with distinct categories: full Payment Institutions (PI), Electronic Money Institutions (EMI), and Small-Scale Payment Institutions (SPI) with simplified requirements. Applications are governed by Decree No. 1/2022 Coll., most recently amended by Decree No. 197/2025 Coll. to reduce administrative burden.

The CNB operates the CERTIS interbank payment system, which includes a live instant-payments rail in CZK. By 2024, 50% of all interbank retail transactions were processed instantly. EU Instant Payments Regulation (EU) 2024/886 applies; from July 2027 all domestic banks must offer instant euro transfers. The CNB is also developing bulk instant payments (e.g. payroll) targeted for 2026.

PSD2 open-banking obligations (XS2A, strong customer authentication) are fully in force via Act No. 370/2017 Coll. The CNB published opinion RS2023-02 clarifying access to payment accounts for third-party providers. PSD3 and the Payment Services Regulation (PSR) were agreed by EU co-legislators on 27 November 2025 with a 21-month national transposition window after entry into force.

EU Consumer Credit Directive 2 (CCD2, 2023/2225), which brings BNPL, deferred debit and short-term credit into a regulated framework, required national transposition by 20 November 2025 with full application from 20 November 2026. The Czech Ministry of Finance launched a public consultation in February 2025 and submitted the draft Consumer Credit Act amendment for the government agenda in July 2025; final enactment pending. The CNB already imposed many CCD2-equivalent requirements, so the compliance gap is smaller than in most EU states.

The CNB became the competent authority for crypto-asset service providers under EU MiCA Regulation from 15 February 2025. By 11 February 2026 it had issued the first six CASP authorisations from a total of 248 applications received, signalling a rigorous licensing gate for crypto-payment services.

The CNB announced it will open direct access to the CERTIS payment system to non-bank payment institutions, broadening fintech participation in the national payment infrastructure and aligning with EU open-finance objectives.