Czech Republic EMI and PI License in 2026: CNB Complete Guide
A 2026 deep dive into the Czech EMI and PI licence: Czech National Bank (CNB) authorisation, EUR 20k-EUR 350k capital, 3-month statutory clock, small-scale payment provider regime, digital portal filing, EU passport.
CNB as a CEE payments regulator
The Czech National Bank (CNB, Česká národní banka) is the Czech central bank and supervisor for credit institutions, PIs, EMIs, investment firms and insurance. It operates one of the most digitally mature regulatory portals in the EU: applications are filed only electronically, either via the Czech data-box system or by e-mail with a recognised electronic signature.
The Czech regime follows PSD2 and EMD2 directly. Four types of payment licences are offered:
- Payment Institution (PI). Full PSD2 licence with EU passport.
- Electronic Money Institution (EMI). Full EMD2 licence with EU passport.
- Small-Scale Payment Service Provider. Domestic Czech PSD2 Article 32 track.
- Small-Scale E-Money Issuer. Domestic EMD2 Article 9 track.
Building a business on this licence?
See what the platform covers for it: the regulator's IT questions, rails, providers and the technical part of your application.
Request demo
Capital and scope
| Licence | Initial capital | Scope |
|---|---|---|
| PI | EUR 20k / 50k / 125k by services | PSD2 Annex I, EU passport |
| EMI | EUR 350k | All PI services plus e-money, EU passport |
| Small-scale PSP | No fixed minimum | Domestic Czech services only, volume cap |
| Small-scale EMI | No fixed minimum | Domestic Czech services only, volume cap |
Process and timeline
- Incorporation. Czech s.r.o. or a.s. with both its registered office and its real head office in the Czech Republic (§ 9(1)(b) and § 68(1)(b) of Act No. 370/2017 Coll.).
- File preparation. Per Decree No 1/2022 Coll. on applications and notifications under Act No. 370/2017 Coll. on payment transactions. Business plan, governance, AML/CFT (Act 253/2008), safeguarding, ICT/DORA, outsourcing, fit-and-proper.
- Electronic submission and fee. Only electronic via data box or signed e-mail. No paper filing. The administrative fee for receiving the application is CZK 50,000 (Act No. 634/2004 Coll., tariff item 65).
- Statutory clock. The CNB decides within 3 months from the start of the administrative proceedings, which is the day the application reaches it (§ 10(2) for PIs, § 69(2) for EMIs). Requests for missing documents make the process longer in practice.
Substance. Czech-resident director recommended, local AML officer, real office. CNB's substance expectations are moderate compared to BaFin or CBI but tightening.
MiCA and PSD3 context
Czech Republic's MiCA implementing measures were finalised in 2025. Grandfathering window runs to 1 July 2026 with applications required by 31 July 2025 for transition protection. For payments, Czech PIs and EMIs move to the PSD3 and Payment Services Regulation rules, which are expected to apply around 2028.
Ship a Czech EMI or PI product with Crassula
Crassula provides the core-banking platform behind a Czech PI or EMI: ledger, accounts with IBANs, cards, SEPA rails, KYC onboarding and the ICT and outsourcing details your DORA file needs. AML monitoring under Act 253/2008, safeguarding sign-off and CNB reporting stay with your compliance team and their tools. Request a demo to see it.
FAQ
The Czech National Bank (CNB). Single point of contact for all payment and e-money authorisations plus conduct and AML supervision.
Act No. 370/2017 Coll. gives the CNB 3 months from the start of the administrative proceedings, which is the day the application arrives (§ 10(2) for PIs, § 69(2) for EMIs). If documents are missing, the CNB asks for them and the process takes longer. Filing the application costs a CZK 50,000 administrative fee.
Only electronically, via the Czech data-box system or by e-mail with a recognised electronic signature. No paper submissions.
The Czech implementing decree that sets out application and notification requirements under Act No. 370/2017 Coll. on payment transactions, including required documents, format and submission channels.
Crassula provides the core-banking platform: ledger, accounts with IBANs, cards, SEPA rails, KYC onboarding and ICT documentation for your DORA file. AML monitoring, safeguarding sign-off and CNB reporting stay with your compliance team.
