Updated
GL-E-05
Glossary · Banks and finance
EMI - a service with an account and a card that is not a bank
01 / In 30 seconds
The short answer
- What it is
- A licensed electronic money institution — not a bank
- What it gives
- An account with an IBAN, cards, fast transfers, multiple currencies
- What it does not do
- It does not take deposits or make loans
- Protection of money
- Client funds are held separately, but the deposit guarantee does not apply
- The main nuance
- Some state programmes and notaries do not accept payments from EMIs
02 / In plain words
What EMI means
An EMI (electronic money institution) is a licensed electronic money organisation. Put simply: a service that looks like a bank — an account with an IBAN, a card, an app, transfers — but is not a bank. Its licence is different, and so are its rights and obligations.
What an EMI can do: open an account quickly and remotely, provide multiple currencies, inexpensive transfers and a convenient app. What an EMI does not do: it does not take deposits in the traditional sense and does not lend. It is obliged to keep clients’ money separate from its own — in safeguarded accounts at banks — but the state deposit guarantee does not extend to it.
For investment migration clients there is a practical nuance here. An EMI covers everyday settlements and business payments very well, but for large transactions — paying a programme contribution, buying property, settling with a notary — the receiving party often requires the payment to come from a bank. That is why we recommend an EMI as a convenient additional tool, not as a replacement for a bank account.
A case from practice
A client planned to pay a state fee from a payment service. The programme’s conditions allowed payment only from the applicant’s bank account. We confirmed this in advance, the payment was made from the bank, and the EMI remained for current expenses — the application went in without delay.
Where an EMI is genuinely convenient
- Everyday settlements and cards
- Multi-currency transactions
- Opening an account quickly and remotely
- Settlements for a freelancer or online business
- Transfers within Europe
- A back-up payment channel
03 / What it covers
EMI and bank: the difference
What an EMI gives
- An account with an IBAN
- Cards and an app
- Multiple currencies
What it does not give
- Interest-bearing deposits
- Loans and mortgages
- Deposit insurance
How it holds money
- Separately from its own funds
- In accounts at banks
- Under the regulator’s supervision
Where it may not be accepted
- State programmes
- Notaries and developers
- Large transactions
04 / How it works
How to choose and open an EMI account
Check the licence and jurisdiction
We look the EMI up in the regulator's register and check the licensing country.
Confirm the limits and prohibited transactions
Which amounts, currencies and countries are allowed.
Pass remote KYC
Passport, address, selfie and questions on the source of funds online.
Receive an IBAN and a card
The account is open; details and the card are in the app.
Use it for your purposes
Day-to-day payments through the EMI, large payments through a bank.
05 / Key facts
What you need to know
01What it gives
IBAN, card, transfers
Quick remote onboarding, several currencies, low-cost transfers and a convenient app.
02What it does not do
Deposits and loans
An EMI takes no deposits in the traditional sense and does not lend. Its licence differs from a bank's.
03Protecting your money
No deposit guarantee
Client funds are kept apart from the EMI's own money, usually in banks, but state deposit insurance does not cover them.
04Large payments
Often expected from a bank
Many government programmes, notaries and developers accept payment only from the applicant's bank account.
Common mistakes
Keeping all your capital in an EMI
Use the EMI for day-to-day payments and keep the bulk of the money in a bank.
Planning to pay a programme from an EMI account
Ask the programme in advance whether it accepts a payment that is not from a bank.
Not checking the licence
Find the EMI in the regulator's register and see who supervises it.
Not knowing the limits and restrictions
Read the limits and the list of prohibited transactions before the first large payment.
06 / Expert advice

How to prepare in advance
Before opening an account, check the institution’s licence and the supervisory authority of its jurisdiction, as well as the limits and the list of transactions the service does not carry out. It is sensible to keep large sums and capital in a bank and to use an EMI for everyday settlements and as a back-up channel. Before paying for a programme, always confirm with the receiving party whether it will accept a payment that does not come from a bank.
What we do for you. We help allocate money across channels: a bank for capital and large programme payments, an EMI for everyday settlements and multiple currencies. And we always check in advance which payment the receiving party will accept, so that payment does not derail the timeline.
Dmitry NagyTax consultant, international taxation and compliance (ex-Big4)
07 / Questions
Frequently asked questions
No. It is a licensed electronic money institution. It can issue an IBAN and a card, but it does not take deposits, does not lend and does not participate in the deposit insurance scheme.
Client funds are held separately from the institution’s own money, usually in accounts at banks. But the state deposit guarantee does not extend to them.
Not always. Many state programmes, notaries and developers accept payment only from the applicant’s bank account. This is confirmed in advance.
An EMI may issue electronic money and hold its balance in the client’s account; a payment institution mainly carries out payments. The licences are different.
For convenience: quick remote opening, multiple currencies, inexpensive transfers, a good app. As an additional channel it is very useful.
Look at its licence and jurisdiction, supervisory authority, time in operation, the conditions for holding client funds and its reputation. Regulators’ registers are public.
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