The EMI Licence: Your Gateway to European Payment Services from Germany

For fintech companies seeking to issue electronic money and provide payment services across Europe, the Electronic Money Institution (EMI) licence remains one of the most powerful regulatory instruments available. A BaFin-supervised EMI licence carries weight with banks, enterprise clients, and institutional partners that licences from smaller jurisdictions often do not match — but obtaining one requires a degree of preparation that many international applicants materially underestimate.

Granted under the framework established by the EU's Second Electronic Money Directive (EMD2, Directive 2009/110/EC) and implemented in Germany through the Zahlungsdiensteaufsichtsgesetz (ZAG), the EMI licence authorises firms to issue e-money, operate payment accounts, execute payment transactions across the full range of PSD2-regulated services, and — critically — passport these services into all EU and EEA member states under a single German authorisation. Germany's role as the largest economy in the eurozone, combined with the market credibility of a BaFin licence, makes the German EMI licence the regulatory backbone for many of the most ambitious fintech businesses operating in continental Europe.

A note on the pending reform: on 27 November 2025 Parliament and Council reached a political agreement on a third Payment Services Directive (PSD3) and a Payment Services Regulation (PSR). Under the Commission's proposal, PSD3 repeals the E-Money Directive and treats electronic money institutions as a sub-category of payment institutions. Neither act has been formally adopted yet (as of October 2026); this article describes the law in force.

This article provides a comprehensive walkthrough of the German EMI licence: what electronic money is legally, which business models fit within the EMI perimeter, how the EMI regime interacts with MiCA and other EU frameworks, what capital and governance the licence requires, how the application process works, how passporting unfolds, and what founders must understand about ongoing compliance obligations. The objective is to equip fintech leaders with the substantive understanding they need to plan an EMI application realistically — not just to survive the process, but to emerge with a licence that genuinely supports their commercial ambitions.

What Is Electronic Money? The Legal Definition

Electronic money is defined with surprising precision in German and EU law. Section 1(2) of the ZAG, tracking Article 2(2) of EMD2, characterises e-money as electronically (including magnetically) stored monetary value representing a claim on the issuer, issued upon receipt of funds for the purpose of making payment transactions, and accepted by persons other than the issuer. Every element of this definition matters in practice, and the failure to understand the legal scope is the most common cause of misaligned business plans and rejected applications.

The key features of the definition can be summarised as follows. First, e-money must represent electronically stored value — not a physical instrument such as a banknote. Second, it must represent a claim on the issuer, meaning the holder has a legal right to redeem the value against the issuer. Third, e-money is issued on receipt of funds and always at par value of the funds received (Section 33(1) of the ZAG) — a crucial point that distinguishes e-money from credit-backed instruments. Fourth, the purpose must be making payment transactions. Fifth, it must be accepted by third parties, not only by the issuer itself; closed-loop value (for example, a retailer’s own gift card that can only be redeemed at that retailer) is typically not e-money for regulatory purposes.

This definitional framework carries important consequences. A business model that involves issuing a prepaid card, a digital wallet balance, or a virtual account that can be used to pay merchants generally constitutes e-money issuance and requires an EMI licence (or passporting from another EU member state). A business model that merely provides technology to an underlying licensed issuer is not issuing e-money itself, although it may still fall within other parts of the regulatory perimeter.

Common EMI Business Models

In practice, EMI licences support a wide range of commercial models. The most common categories include the following:

• Prepaid card programmes: Issuance of prepaid debit cards (physical or virtual) that customers load with funds and use for purchases and withdrawals. These programmes have historically been the most common EMI use case.
• Digital wallets: Consumer-facing applications that hold stored monetary value, allow person-to-person transfers, support merchant payments, and in some cases integrate with card networks.
• Multi-currency accounts: Accounts in which customers can hold balances in multiple currencies, make cross-border payments, and access foreign exchange services. Many neobanks operate under an EMI licence rather than a full banking licence.
• Virtual account services: B2B solutions that provide virtual IBAN-style account numbers to business customers, often for reconciliation, collection, or marketplace-related use cases.
• Expense management and corporate card programmes: Solutions for corporate clients that combine stored value, card issuance, and expense tracking.
• Certain stablecoin use cases: Some stablecoin models fall within the e-money definition, particularly those structured as e-money tokens (EMTs) under MiCA. The regulatory analysis is fact-specific and requires careful legal characterisation.

Each of these models has specific operational features that influence the licensing analysis. Prepaid card programmes require integration with a card scheme (typically Visa, Mastercard, or a private-label equivalent), which imposes its own rule-book. Digital wallets require robust IT infrastructure and customer authentication. Multi-currency account providers face foreign exchange regulatory considerations in addition to the e-money framework. Founders should invest the time to understand how their specific model maps to the EMI framework before committing to a licensing strategy.

The EMI Licence and MiCA: A New Interaction

The entry into force of the Markets in Crypto-Assets Regulation (MiCA, Regulation (EU) 2023/1114) has created a new regulatory interaction that EMI applicants and existing licence holders must now navigate. MiCA's stablecoin provisions applied from June 30, 2024, and its CASP provisions applied from December 30, 2024. Within MiCA's framework, e-money tokens (EMTs) — crypto-assets that purport to maintain a stable value by referencing a single fiat currency — must be issued by an EMI authorised under EMD2 (and therefore, in Germany, under the ZAG) or by a credit institution.

This creates a practical channel for regulated stablecoin issuance in the EU: an EMI needs no second authorisation under MiCA to issue e-money tokens. It must notify a crypto-asset white paper to its competent authority and publish it (Articles 48(1) and 51 of MiCA), and it must inform the authority of its intention at least 40 working days before the offer (Article 48(6)). The MiCA rules layer on top of the EMI obligations, adding white paper requirements, rules on the investment of the funds received, redemption obligations specific to EMT holders, and additional transparency and reporting duties.

For asset-referenced tokens (ARTs), which reference another value or right or a combination of them, such as a basket of currencies or crypto-assets, MiCA establishes a separate authorisation regime under Title III of the regulation. As a rule, ARTs may only be issued by an issuer that has obtained an authorisation under Article 21 of MiCA from its competent authority, or by a credit institution that follows the procedure in Article 17 (Article 16(1) of MiCA). An EMI licence is not enough: an EMI that wants to issue ARTs needs the Article 21 authorisation as well.

Founders planning stablecoin or tokenised money products should analyse the MiCA classification carefully alongside the EMI framework. Misclassification — for example, assuming that a token is a utility token when it is in fact an e-money token — can derail an entire product launch. Aegiron Capital Group discusses MiCA and EMI frameworks academically for educational purposes; specific product structuring requires engagement with licensed legal counsel.

A further practical dimension is timing. Because MiCA provides no separate authorisation for e-money tokens but builds on the authorisation as an electronic money institution, there are not two authorisation procedures, but there are two work packages: the licensing procedure under the ZAG, and the preparation of the white paper, the notification to the competent authority and the additional MiCA obligations. Some founders obtain the EMI licence first and prepare the token issuance afterwards, while others plan both together from the outset. Each approach has trade-offs in terms of time to market, documentation burden, and supervisory risk. The right sequencing depends on the specific product strategy and should be planned with licensed counsel from the outset.

Capital Requirements: Initial and Ongoing

The initial capital requirement for an EMI licence under Section 12 no. 3(d) of the ZAG is EUR 350,000. This threshold is fixed regardless of the institution’s projected volume or business model. It represents an absolute floor, not a realistic operating budget.

Beyond the initial capital requirement, EMIs must maintain ongoing own funds calculated in accordance with the ZAG and the underlying EU rules. The calculation reflects the average outstanding electronic money of the institution, meaning that as the business grows, the capital requirement grows with it. Founders should model this ongoing requirement carefully as part of their financial planning: unlike a fixed threshold, the own funds requirement scales, and capital planning that assumes a static figure will fail at the first major growth phase.

BaFin’s practical expectations go beyond the statutory minimum. Applications that arrive at exactly the statutory threshold without a credible capital cushion are frequently asked to demonstrate additional financial backing before the application proceeds. Prudent applicants budget meaningfully above the statutory minimum to absorb the expected growth in ongoing own funds requirements and to demonstrate to BaFin that the institution has the financial resilience to withstand operational setbacks.

Capital planning should also consider the interaction between capital and operating cash flow. An EMI that launches at scale will typically experience a period of negative operating cash flow as customer acquisition costs precede revenue. The regulatory capital base cannot be depleted to fund operating losses without triggering supervisory concern, which means that the working capital needed to sustain early-stage operations must come from additional funding beyond the regulatory minimum. Credible applicants present financial plans that explicitly separate regulatory capital from operating capital and demonstrate that both are adequately funded for the period leading up to break-even.

E-Money Redemption at Par Value

One of the defining substantive protections of the EMI regime is the redemption right. Under the ZAG and EMD2, e-money holders are entitled to redeem their e-money at any time, at par value — that is, at the monetary value stored electronically, without deduction of fees except in strictly defined circumstances. This right is the cornerstone of consumer protection in the e-money framework and has material implications for product design.

The redemption obligation creates a clear operational expectation: institutions must maintain sufficient liquidity to meet redemption requests as they arise. Combined with the safeguarding requirement discussed below, this obligation means that an EMI cannot invest e-money balances in illiquid assets or use them for its own operational purposes. The business model must generate revenue through fees, interchange, or other sources that do not depend on using customer balances.

Redemption at par also implies a conceptual distinction between e-money and more speculative forms of digital asset. E-money, by definition, maintains a stable value against the currency in which it is denominated. This is why certain stablecoin models fit within the e-money framework (because they commit to par-value redemption) while others do not (because they involve algorithmic mechanisms or reference baskets that do not guarantee par-value redemption).

From a product strategy perspective, the redemption obligation has far-reaching implications for pricing and business model design. Because EMIs cannot pay interest on customer balances and cannot use those balances to fund proprietary lending or investment activity, revenue must come from other sources — typically transaction fees, interchange, foreign exchange margins, premium product tiers, or ancillary services. Structuring a viable business model within these constraints is one of the hardest aspects of the EMI business and should be addressed very explicitly in the applicant's financial plan.

Safeguarding Rules Specific to E-Money

EMIs are subject to stringent safeguarding requirements under Sections 17 and 18 of the ZAG. The core principle is that client funds received in exchange for e-money must be protected against the insolvency of the institution itself. Two principal methods are permitted: segregation of funds in accounts at authorised credit institutions (or in equivalent low-risk investments), or coverage through an insurance policy or guarantee from an authorised institution.

In practice, segregation is the dominant approach. The mechanics require that incoming customer funds are channelled into identifiable safeguarded accounts, that those accounts are legally segregated from the institution’s operating accounts, and that reconciliation processes ensure the safeguarded balance matches the outstanding e-money liability at all times. Operational deficiencies in this process — for example, delays in transferring funds into safeguarded accounts, or reconciliation gaps — are treated seriously by BaFin and can generate enforcement action.

The choice of safeguarding bank is itself a regulatory consideration. The bank must be an authorised credit institution, and the institution’s concentration of safeguarding with a single counterparty may itself be a supervisory question. Some EMIs distribute safeguarded funds across multiple banking partners to manage concentration risk, though this approach adds operational complexity.

Safeguarding bank relationships have become materially harder to establish in recent years. Many German banks have tightened their acceptance criteria for EMI customers, reflecting concerns about AML risk, operational complexity, and the perceived profitability of such relationships. Founders should not assume that safeguarding bank capacity is freely available; establishing a committed relationship with a bank willing to act as safeguarding counterparty is itself a meaningful prerequisite to a viable licence application. Some applicants have spent months securing safeguarding bank commitments before being able to progress their BaFin application in earnest.

The Application Process from Start to Authorisation

The EMI application process with BaFin broadly parallels the payment institution application process under the ZAG, with additional substantive elements reflecting the e-money issuance perimeter. A common rule of thumb for a well-prepared EMI application is nine to fifteen months from initial submission to authorisation, plus the substantive preparation beforehand and the operational build-out afterwards; this is an estimate, not an official figure. By statute, BaFin decides within three months of having the complete application (Section 11(2) in conjunction with Section 10(3) of the ZAG).

The application package must include the full range of documentation expected by BaFin: a detailed business plan covering at least a three-year horizon, organisational charts and internal policies, fit-and-proper dossiers for each managing director and significant shareholder, a description of IT systems and security architecture, AML policies and procedures, outsourcing register and contracts, documentation of safeguarding arrangements, and audited or projected financial statements. Each of these elements is examined substantively; incomplete or generic documentation triggers Nachforderungen (supplementary question sets) that extend the timeline.

A distinguishing feature of the German process is BaFin’s rigorous pre-filing engagement culture. Well-prepared applicants typically engage with BaFin informally before submitting their formal application, to clarify the supervisory view of their business model, identify potentially contentious issues, and calibrate their documentation to the authority’s expectations. This preparatory dialogue is not mandatory, but applications that skip it tend to encounter more friction in the formal process.

Governance Requirements: The Three Lines of Defence

BaFin expects EMIs to implement a governance structure built around the three lines of defence model. The first line comprises the operational business units that generate and manage risk in their day-to-day activities. The second line consists of independent risk management and compliance functions that set frameworks, monitor first-line activity, and escalate issues. The third line is internal audit, which provides independent assurance on the effectiveness of the first and second lines.

For an EMI, the practical consequences include the appointment of a dedicated Money Laundering Reporting Officer (Geldwäschebeauftragter), a Compliance Function, a Risk Management Function, and an Internal Audit Function. Depending on the size and complexity of the institution, some of these roles may be combined or outsourced, but the substantive oversight responsibilities cannot be. BaFin examines the design and independence of these governance arrangements closely during licensing.

As a rule at least two managing directors must be appointed; Section 11(2) of the ZAG lets a single one suffice only for undertakings of small size. The division of responsibilities between them must be documented. BaFin has a clear preference for arrangements where responsibilities are clearly delineated and where no single individual holds unchecked authority over material business activities. Founders who expect to centralise decision-making in a single founder-CEO will encounter friction with this expectation.

IT Governance under DORA

IT governance is one of the most scrutinised elements of an EMI application. The supervisory expectations derive from the directly applicable Digital Operational Resilience Act (DORA, Regulation (EU) 2022/2554), which has applied since 17 January 2025 and expressly covers electronic money institutions. The former BaFin circular for payment and e-money institutions (ZAIT, Circular 11/2021 (BA)) was repealed at the end of 16 January 2025, and the banking circular BAIT does not apply to EMIs. EMIs must design and document information security management, access controls, change management procedures, incident management processes, business continuity arrangements, and ICT third-party risk management in a manner that satisfies DORA and the organisational duties in Section 27 of the ZAG.

DORA’s applicability from January 17, 2025 has materially raised the bar for IT governance documentation in EMI applications. Applicants submitting today must demonstrate how they will satisfy DORA’s five pillars: ICT risk management, ICT-related incident reporting, digital operational resilience testing, ICT third-party risk management, and information sharing. The documentation burden is substantial, particularly for applicants that rely heavily on cloud service providers for core infrastructure.

Founders should not underestimate the time required to produce credible IT governance documentation. Template-based documentation is rarely sufficient; BaFin expects documentation that reflects the actual architecture, actual vendors, actual controls, and actual operational processes of the applicant. This requires close collaboration between the applicant’s engineering leadership, compliance function, and external advisors.

EMI as Obliged Entity under the GwG

Like payment institutions, EMIs are obliged entities under the German Anti-Money Laundering Act (GwG). This subjects them to the full range of GwG obligations: risk assessment under Section 5, MLRO appointment under Section 7, customer due diligence under Section 10, enhanced due diligence for higher-risk cases under Section 15, and suspicious activity reporting under Section 43. E-money products present specific AML challenges — in particular, the potential for anonymous or low-friction onboarding flows that can attract illicit use — and BaFin examines AML frameworks for EMI applicants with heightened attention.

The interaction between product design and AML risk is particularly important for consumer-facing EMIs. Simplified due diligence, where permitted under the GwG and subject to transaction limits, can enable streamlined customer onboarding but imposes ongoing monitoring obligations. Full customer due diligence is required for higher-value relationships and for customers that fall outside the permitted simplified regime. Founders should design customer onboarding flows with a clear understanding of which regulatory thresholds they are operating under and how those thresholds translate into product experience.

Transaction monitoring is another area where EMI applicants frequently underinvest. BaFin expects automated transaction monitoring capable of identifying typologies relevant to the institution’s business model, not merely rule-based checks on transaction size. For an e-money institution processing retail payment volume, the monitoring infrastructure is a substantial technology investment that should be planned from the outset.

The interaction with the EU Anti-Money Laundering Authority (AMLA), which commenced operations in Frankfurt am Main on July 1, 2025 and will assume direct supervision of certain obliged entities from 2028, is a development that EMI founders should factor into their long-term planning. AMLA will introduce a second layer of AML supervision for the largest and highest-risk cross-border obliged entities in the EU, while national authorities including BaFin will continue to supervise the broader population. An EMI with significant cross-border activity and growth ambitions may eventually fall within AMLA's direct supervisory remit, and the compliance infrastructure built during the licensing phase should be designed to scale to that eventuality.

Passporting the EMI Licence across the EU

Once authorised, an EMI holding a BaFin licence can exercise EU passporting rights to provide e-money and payment services in other EU and EEA member states. Passporting proceeds under one of two routes: the freedom to provide services (cross-border provision without a physical presence in the host state) or the freedom of establishment (the establishment of a branch in the host state). Each route has its own procedural requirements and operational implications.

Freedom of services passporting is the more common and typically faster route. It requires the EMI to notify BaFin of its intention to provide services in a specific host state, after which BaFin coordinates with the host competent authority. The process is largely administrative, though host states may impose additional conduct or reporting requirements on passported institutions. Some host authorities take a more active supervisory interest than others; founders should investigate the host-state practice for their priority markets before assuming passporting will be friction-free.

Branch establishment is more demanding. It typically requires more extensive documentation, a dedicated branch manager, and compliance with host-state conduct requirements in a more substantive way. Branches are usually chosen where the passporting activity involves a significant local presence — customer-facing offices, local staff, or direct marketing — rather than a purely cross-border operation.

Passporting does not insulate the institution from local AML rules, conduct of business requirements, or consumer protection expectations. Founders should treat passporting as the opening of a regulated channel, not as an automatic pass through host-state supervision.

The choice between the freedom to provide services and establishment also has tax and operational implications. In many jurisdictions a branch creates a permanent establishment for income tax purposes, which can lead to profit attribution and local tax obligations. The freedom to provide services generally avoids these tax consequences but also limits the depth of local presence. Founders should include the tax dimension in their passporting decision, ideally with advice from a tax adviser who knows both the German rules and those of the relevant host states.

Regulatory Classification in Practice

The classification of new business models as e-money (or not) has been the subject of ongoing analytical development at the national and EU level. The functional test — whether the stored monetary value represents a redeemable claim on the issuer, issued upon receipt of funds, and accepted by third parties — provides the framework, but its application to specific products requires careful legal analysis.

Business models that have been treated as e-money issuance in regulatory practice include traditional prepaid cards, digital wallet balances tied to consumer-facing applications, and certain virtual account structures. Business models that have been treated as outside the e-money perimeter include closed-loop gift card arrangements where the value can only be redeemed at the issuing retailer, certain reward-point programmes that do not represent a money-denominated claim, and pure credit or billing arrangements that do not involve stored monetary value.

The line between these categories is not always obvious, and regulatory classification can evolve as products develop. Founders should obtain a specific legal opinion on the classification of their intended product before committing to an EMI licensing path or before assuming that an alternative structure avoids the EMI perimeter.

A further aspect of growing importance is the development of hybrid products that combine elements from several regulatory categories. A product that provides stored value but also suggests a return, for example, may touch on e-money, financial instruments and collective investment at the same time. Such hybrid products require particularly careful legal analysis; a creative product name does not change the legal classification. The economic substance of the product determines its regulatory classification, not its marketing.

Ongoing Supervisory Touchpoints

After authorisation, EMIs engage with BaFin through a structured set of supervisory touchpoints. Monthly, quarterly, and annual reporting obligations apply to different categories of information, including own funds calculations, safeguarding reconciliations, transaction volumes, incident reports under DORA, AML statistics, and financial statements. BaFin also conducts on-site inspections, targeted thematic reviews, and ad hoc investigations where supervisory concerns arise.

The quality of supervisory engagement matters. EMIs that respond promptly and substantively to BaFin queries, that self-report material issues proactively, and that maintain clear channels of communication with the authority tend to experience more constructive supervision. EMIs that are unresponsive, evasive, or slow to remediate identified issues face escalating supervisory attention and, in serious cases, enforcement action.

EMIs should also size their internal compliance resources so that they can respond to audits and special inspections without endangering day-to-day operations. A BaFin on-site inspection can tie up considerable staff time, and institutions that staff their compliance function so thinly that every inspection becomes a bottleneck create additional risks for themselves. Adequate resourcing of the control functions (compliance, risk management and internal audit) is not a question of cost optimisation but a precondition for holding a licence sustainably.

Costs and Timelines

The total cost of obtaining and maintaining a German EMI licence is a material consideration. Published cost estimates vary widely depending on the complexity of the business model, the existing maturity of the applicant’s compliance and IT infrastructure, and the external advisory support engaged. Founders should budget meaningfully for legal counsel, regulatory advisory support, compliance technology, IT security tools, audit and assurance services, and the ongoing cost of regulatory reporting and supervision.

The typical pre-licence preparation phase lasts several months, during which the applicant builds out its governance, policies, IT architecture, and documentation. Nine to fifteen months is a common rule of thumb for the active application process with BaFin; an applicant that does not answer supplementary questions in time risks rejection, because an application that is still incomplete twelve months after receipt despite a request must be rejected (Section 10(3) of the ZAG). Post-authorisation operational build-out adds further time before the licensed activity can commence at scale.

Common Application Pitfalls

Certain mistakes are regarded as typical of EMI applications. They include:

• Weak e-money classification analysis: Applicants that cannot clearly articulate why their product is e-money (or is not) create analytical uncertainty that undermines the entire application.
• Inadequate safeguarding architecture: Incomplete descriptions of how client funds will be routed, held, and reconciled in segregated accounts.
• Generic AML frameworks: Templates that have not been tailored to the specific typologies and risks of the applicant’s business model.
• Under-documented IT governance: IT documentation that does not reflect the actual architecture or that fails to satisfy the DORA requirements.
• Fit-and-proper weaknesses: Managing directors without demonstrable e-money or payment services experience, or governance arrangements that concentrate excessive authority in a single founder.
• Insufficient capital cushion: Budgeting to the EUR 350,000 statutory minimum without realistic planning for ongoing own funds growth.
• Passive engagement with BaFin: Applicants who treat the process as a passive document submission rather than an active supervisory dialogue.

Practical Preparation Guidance

Serious preparation for an EMI application begins well before any formal submission. Founders should expect to invest in parallel workstreams covering legal and regulatory scoping, governance build-out, IT architecture and documentation, AML framework construction, fit-and-proper preparation for managing directors, financial planning, and external advisory engagement. Each of these streams should be timed to converge at a point where the full application package can be submitted as a coherent whole.

The most successful applicants approach the EMI licensing process as an operational preparation exercise rather than a documentary one. They invest in genuinely building out their compliance and risk management infrastructure before submission, rather than hoping to address gaps in response to Nachforderungen. This approach is more expensive up front but typically produces faster and smoother processes, and it creates a post-authorisation operating platform that is genuinely fit for purpose.

Strategic Alternatives and the Dual-Track Approach

Not every firm that needs e-money capability should pursue a German EMI licence. The regulatory weight of a BaFin licence is matched by the substantial preparation effort it requires, and for some firms, alternative approaches may be more appropriate. Common alternatives include obtaining an EMI licence in a smaller EU jurisdiction (such as Lithuania, Luxembourg, or the Netherlands) and passporting into Germany, operating as an agent or distributor under an existing licensed institution, or partnering with a Banking-as-a-Service (BaaS) provider that holds the relevant authorisation.

Each alternative has trade-offs. Licensing in a smaller EU jurisdiction typically offers faster processing and lower upfront costs, but the resulting licence may carry less commercial weight with German enterprise clients. Agent arrangements preserve speed to market but limit product control and margin capture. BaaS partnerships shift the regulatory burden but create commercial dependency on the partner institution.

Some firms adopt a dual-track approach: launching under a partner arrangement or a passporting licence to validate the business model, while simultaneously preparing a proprietary German EMI application for the long term. This strategy can be effective if managed carefully, but it requires careful legal structuring to ensure that early-stage activities do not compromise the subsequent licensing application.

Conclusion

The German EMI licence remains one of the most demanding, and one of the most valuable, regulatory authorisations in European fintech. It requires substantial preparation, genuine operational substance in Germany, and the commitment of meaningful resources to compliance infrastructure. For firms whose ambitions justify this investment, it provides a commercial credential and a passporting platform that few alternative jurisdictions can match. Aegiron Capital Group runs the preparation for the licensing procedure as a project for founders pursuing EMI authorisation in Germany, alongside the German law firm you engage. Approached with the right preparation and expectations, the EMI licence is a demanding but navigable path to the European single market.