Payment companies and investors turn to Národná banka Slovenska (NBS) when they intend to issue e-money and to run regulated settlement operations. Authorization opens the passporting mechanism, and its holder may then pursue business across the other European Economic Area (EEA) states, acting under an EMI license in Slovakia.
NBS requires the applicant to evidence its ownership structure; adequacy of capital; the qualifications of management; client-money safeguarding; controls against the laundering of money and against the funding of unlawful activity (AML/CFT); and the resilient operation of information and communication technology (ICT).
This memorandum sets out how a company obtains the authorization and what the licensing dossier must contain. It names the rules that bind an applicant: those of Act No 492/2009 Coll., those under the Digital Operational Resilience Act (DORA) and those in European Banking Authority (EBA) guidelines.
EMI license Slovakia: applicable law and NBS powers
Once the National Bank of Slovakia approves an application, the company may put electronic money into circulation. Slovak legislation calls such an undertaking an Electronic Money Institution. Its authorization covers creation of electronic monetary value plus the payment operations that the supervisor's decision lists.
In law, electronic money means value recorded on an electronic or magnetic carrier, which the issuer owes back to the holder and creates when it receives funds. Acceptance in settlement by parties outside the issuing undertaking is the second mandatory feature. Bonus points of a single retailer, loyalty balances and value usable only inside a closed platform therefore do not always come under Slovak electronic money rules.
Legal nature separates electronic money from a bank deposit. A deposit funds the bank's own financial business, while an EMI records the sum it receives as its liability to the holder and must return it at face value. The Slovak EMI license carries no right to accept deposits or to carry on banking business.
Regulation rests on these instruments:
- payment services: Act No 492/2009 Coll., which fixes EMI status, permitted operations, capital thresholds and how authorization is obtained;
- financial market supervision: Act No 747/2004 Coll., which governs proceedings before NBS, supervisory control and the measures that follow;
- protection against the legalisation of proceeds of crime and the financing of terrorism: Act No 297/2008 Coll.;
- European framework: Directive EMD2 on electronic money institutions and Directive PSD2 on payment services;
- strong customer authentication and secure data communication: Delegated Regulation (EU) 2018/389.
That first act gives NBS its powers of examination and vetting over the application itself and over the owners and managers behind it. The authority also writes permitted services into the license, keeps the registers and supervises the institution afterwards. Its later oversight takes in reporting, the protection given to client money, own-funds adequacy and payment security. An operation absent from the decision falls outside the authorization.
Since January 17, 2025 the license has also carried the duties of Regulation (EU) 2022/2554, the instrument that governs digital operational resilience throughout the sector. Guideline EBA/GL/2017/09 details what an application must contain; EBA/GL/2019/02 covers outsourcing of functions to contractors; EBA/GL/2019/04 addresses information and security risks. The analysis below rests on the consolidated wording of national legislation as at July 2026. Amendment No 248/2024 Coll. was not the last change, and later rules, among them provisions in force from May 1, 2026, belong within the applicable body of law.
Categories of the Slovak e-money license and available payment operations
Slovak law separates a standard institution from an undertaking of limited scope. Turnover ceilings, permitted territory and access to clients in other EEA states divide the two regimes. The choice follows from the planned product, from how many clients are expected and from where settlements will run.
Articles 81 and 82 of the Payment Services Act govern the authorization of a full institution. Such an institution faces no specific quantitative limit on the electronic money it issues, and may apply for any payment service the act provides. The notification procedure then opens the remaining EEA markets.
Article 87 sets up a regime for a local model. A limited institution must observe two quantitative ceilings and a territorial restriction:
- outstanding electronic money averages no more than EUR 5 million;
- additional payment operations average no more than EUR 3 million a month across the preceding 12 months;
- business stays inside Slovakia, with no European passporting.
Transactions executed through agents count towards the second limit. Breach of either value requires full authorization; failing that, operations beyond the permitted range must stop. Preparation for a Slovak e-money license therefore starts with a financial forecast that identifies the regime appropriate to the planned scale of business and its costs.
The NBS decision lists the specific operations permitted to the institution. An application may extend to the placing of money on payment accounts and its withdrawal, to credit transfers and to direct debits. It may also include card payments, acquiring, the issue of payment instruments and remittance of money without an account. Payment initiation and account information services need a separate application.
Law draws a line between issuing e-money and carrying out a payment transfer. In the first the institution creates electronic monetary value against ordinary funds and undertakes to redeem it to the holder. Under the second, a payment service provider moves money between payer and payee. The license extends to both categories only where the decision expressly confers the corresponding powers.
A payment agent acts for the institution and supplies the services its contract provides. Distributors circulate electronic money or accept it for redemption, but never become its issuer in law. The license holder alone may create electronic value and cannot devolve that power on a third party, because responsibility for issuance is inseparable from the authorization. Licensing weighs that boundary, particularly where a wide partner network is planned.
Conditions an applicant must satisfy
Only a company whose registered office lies in Slovakia may apply. The requirements run to corporate structure and funding sources, to managerial competence and to working control mechanisms. Registering an ordinary company confers no right to put electronic value into circulation.
Slovak law and financial-industry standards determine the corporate model. An entity's structure provides for bodies that may direct the business and control licensed operations. Examining an application, NBS establishes which country hosts the management center, who the responsible officers are and how direct its access to documents and digital infrastructure will be.
A nominal registered office without staff or management resources does not evidence substance. The functions needed for genuine control over operations, over risks and over contractors must be performed in Slovakia. This is not to be read as an unconditional requirement to place every unit inside the country. NBS judges conditions for a Slovak EMI license against the declared model's scale and complexity.
Examination of finances and corporate structure includes:
- fully paid share capital, not below EUR 350,000;
- disclosure of direct and indirect participants;
- the ultimate beneficial owners named;
- vetting of anyone holding 10% and above, or otherwise able to exert significant influence;
- proof of lawful origin for the money invested;
- analysis of close links and group companies.
Bank documents, financial statements, tax returns and the owners' sources of wealth evidence the capital required. NBS asks whether an owner could support the institution after launch. A complex foreign chain of participation raises no bar where it is transparent and leaves supervision unobstructed.
Persons who actually direct the undertaking must be professionally fit and enjoy good repute. An applicant supplies their education, employment history and previous positions. The file also discloses participation in other companies, criminal records and regulatory proceedings. NBS tests professional knowledge of payments and finance. That review extends to the prevention of unlawful transactions, digital technology and the management of risk.
NBS rules also require internal control, compliance and AML/CFT roles, alongside cyber-protection and an assessment of possible threats. This creates no automatic duty to establish five separate posts. An institution may combine compatible tasks or entrust them to a contractor, so long as independence, contact with the governing bodies and its own responsibility survive intact. Amendments made in 2024 recast the prior approval of the supervisory board's composition, yet left the general governance assessment at licensing in place.
Capital, own funds and client-money protection
Share capital from EUR 350,000 is one licensing condition. An applicant contributes it in monetary form and confirms it before the document check ends. NBS traces the money from its first source through to the corporate bank account.
Minimum capital forms the opening financial base. After launch a separate own-funds indicator applies and tracks operations at their current scale. The two figures cannot be merged, because the first is a condition of market entry and the second a continuing obligation.
Own funds held against electronic money in issue may not drop below 2% of average sums in circulation over the preceding six calendar months. Daily closing liabilities form the basis for that calculation. A new institution uses its business-plan forecast until its own record spans a full calculation period. The Slovak EMI license further calls for extra coverage where payment services lie outside electronic value issue.
Financial indicators of the full regime
|
Parameter |
Requirement |
|
Initial capital, paid up |
EUR 350,000 |
|
Own funds against electronic money |
2% of average volume or higher |
|
Calculation period |
Preceding 6 months |
|
Basis for a newly formed institution |
Figures from the approved business plan |
|
Time limit for deciding a full application |
3 months maximum |
|
Administrative fee |
EUR 3,400 or EUR 1,700, by scope of powers |
Every applicant must draw up and submit a separate procedure for protecting client money. Article 77 of the Payment Services Act keeps such sums outside the assets of the license holder, in dedicated accounts and beyond creditors' claims. Permitted forms are a special bank account, an insurance policy or equivalent security that meets the statutory criteria.
The safeguarding mechanism comprises:
- identification of receipts from clients;
- separate accounting for the liabilities;
- regular reconciliation of the actual balance;
- a prohibition on any use of those sums to serve the institution itself;
- a documented course of action on insolvency;
- an agreement made with a bank or with a guarantor.
The draft agreement belongs in the submission to NBS. Licensing requires proof that the account is legally separate and a statement of the conditions attached to its use. The proposition that such an account is in every case opened only with an EU or EEA bank calls for a check of the applicable model and of the standing of the particular credit institution.
A licensed company must issue electronic value at par as soon as funds arrive. It redeems that value in the same amount whenever the holder demands. Interest, or any other reward tied to how long a balance remains, contradicts the nature of the instrument.
Documents for Slovak EMI licensing
An applicant assembles a file evidencing that the business is ready to operate. NBS reads the documents against one another. The financial forecast must match headcount, the product scheme, the information architecture, and client money the model chosen to protect it. A formal set without reconciled calculations does not suffice.
The corporate block comprises the constitutive act plus the application. Draft articles, a current extract from the register and address details complete it. The applicant attaches a scheme of the governing bodies and the group structure. A Slovak EMI license likewise calls for disclosure of every direct and indirect owner, together with the participation held. Companies under common control and the ultimate beneficiary fall under the same disclosure.
Owners provide financial statements, tax materials and evidence showing where the invested money came from. Managers submit a curriculum vitae with educational documents and a record of service. They also file certificates of no criminal conviction and a list of other posts held. Each file must disclose the division of powers and the actual employment of every manager.
The commercial block holds:
- a description of the e-money and payment products planned;
- a business plan covering three financial years or longer;
- a forecast of client numbers and turnover;
- a calculation of the average electronic money in issue;
- a baseline scenario and a stress scenario;
- a budget for staff, information technology, compliance and outsourcing;
- a calculation covering own funds together with initial capital.
Before filing, the company describes the full life cycle of electronic value from incoming funds through issue and storage to execution of an operation and redemption. Cash flows appear separately, with integrations to banks, payment schemes and outside suppliers. The architecture must disclose databases and access levels, along with backup and recovery after failure.
Licensing requires internal acts covering AML/CFT and client identification; compliance, risk control and audit; and money protection, outsourcing and information security. Documents drawn up under DORA set out mechanisms for business continuity, recovery after a breach, the recording of ICT incidents and control over the risks of third-party technology suppliers. Documentation for clients deals with contractual terms and fees, and with the rules on issue and redemption. It also states the grounds for suspending a transaction, the parties' obligations and the complaints mechanism.
During authorization NBS weighs whether the declared model can work in practice. A forecast of rapid turnover growth must match headcount and the transaction control system's readiness. Similar risk arises where the safeguarding policy describes a dedicated account, but the draft bank agreement does not confirm its separate legal regime.
Procedure and time limits for licensing
The procedure for a Slovak EMI license opens with the product's legal qualification. A company decides whether a claim by the holder against the issuer arises. It also establishes whether third parties accept the electronic value and which payment operations will accompany its use. The answer fixes how wide the future authorization must be.
The company measures its project against the full regime's requirements and those of the limited one. It settles in the same step its territory of operation, the services sought and the forecast volume of outstanding electronic money.
The applicant incorporates in Slovakia and discloses its owners and ultimate beneficiaries. It then appoints those answerable for management and for AML/CFT, alongside the officers in charge of risk, of control and of information security.
The company contributes share capital, confirms where the money came from and draws up a three-year model. Choice of a mechanism to protect client receipts and negotiations with a bank belong to the same stage.
The applicant drafts internal regulations, its information technology architecture, a continuity plan and a recovery procedure. At this point it agrees contracts with suppliers and processing organizations, and with agents and other counterparties.
Under NBS Decree No 5/2021 Coll. as amended by No 8/2024 the charge is EUR 3,400 for the full regime and EUR 1,700 where the scope is limited. Foreign documents are translated into Slovak and, where the relevant international requirements apply, apostilled or legalized.
NBS studies the file and puts further questions where evidence is absent or the materials do not agree. The time limit starts on the day the application becomes complete.
A special time limit, up to three months, applies once the file arrives complete. Any range of six to twelve months therefore is not a period fixed by law. The calendar lengthens whenever NBS calls for new information and the applicant reworks calculations or procedures.
Once NBS issues the authorization, the institution enters the register for its regulated activity. The company meets the conditions set by the decision, activates the safeguarding account and puts its reporting in place. A readiness check on internal systems closes the stage.
The license costs more than the administrative fee alone. Share capital enters the same total, and so does the build of technological infrastructure. Banking services and audit add to it, as do staff and control functions. These outlays follow the model and have no single official rate.
NBS does not treat an application as complete where the ownership chain is opaque, funding unconfirmed, the business plan self-contradictory or design documentation on information systems absent. Delay also arises where internal policies copy general rules without describing the actual products, the contractors or the flows of money.
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Conclusion
A legal entity qualifies for an EMI license in Slovakia once it holds capital of EUR 350,000 or more and a transparent ownership scheme. Qualified management completes the conditions, together with working control over payment, AML/CFT and ICT risks. NBS authorization reaches only the operations named in it; other EEA markets open through notification. The most demanding stage is the assembly of the commercial model, financial forecasts, protection of client money and of the technological infrastructure into a single consistent file.
