Updated

GL-E-05

Glossary · Banks and finance

EMI - a service with an account and a card that is not a bank

Full glossary
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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

01

What an EMI gives

  • An account with an IBAN
  • Cards and an app
  • Multiple currencies
02

What it does not give

  • Interest-bearing deposits
  • Loans and mortgages
  • Deposit insurance
03

How it holds money

  • Separately from its own funds
  • In accounts at banks
  • Under the regulator’s supervision
04

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

Step 1

Check the licence and jurisdiction

We look the EMI up in the regulator's register and check the licensing country.

Step 2

Confirm the limits and prohibited transactions

Which amounts, currencies and countries are allowed.

Step 3

Pass remote KYC

Passport, address, selfie and questions on the source of funds online.

Step 4

Receive an IBAN and a card

The account is open; details and the card are in the app.

Step 5

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

Dmitry Nagy

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.

Author: Dmitry Nagy

Reviewed by: Sergej Evdokimov

Sources: European Banking Authority

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Anna Kovalevskaya, lead lawyer at BRIDGES GLOBAL
Anna KovalevskayaLead lawyer, citizenship and residency, 12 years of practice