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Obtaining an EMI license in Hong Kong: pros & cons

September 23, 2020

An Electronic Money Institution (popularly known as an EMI for short) is a fully licensed financial institution which engages in electronic payment services. The full license for a Hong Kong electronic money institution currently has no restrictions to either trading period or sector of activities.

The HKMA regulations for obtaining an EMI license are complex to adhere to, especially if one is not currently residing in Hong Kong. The requirements are relative to e-money services and stored value facilities (SVF) in Hong Kong. Approval from and reporting to the Hong Kong Monetary Authority (HKMA) is required to obtain such a license.

However, there is the option of applying for a limited license for an e-money institution. Limited license holders and owners have the ability to provide services throughout the territory of Hong Kong and Asia; however certain restrictions are applicable regarding the general turnover and company annual profit.


The financial structure of an EMI provides solutions to current economic situations faced by international business transactions, internet banking provisions and international transfers (particularly in USD).

Certain distinctive characteristics of this financial structure includes:

  • Enables accessible remote bank account opening for individuals and companies.
  • Issuance of Visa or MasterCard accounts linked to client and partner accounts.
  • Authorised payments to banks globally, including currencies such as USD-EUR-GBP as the most popular.
  • Provides the option to accept SWIFT payments from any international bank account worldwide.
  • Decision-making on payments and account opening independently.
  • Possibility of opening correspondent accounts around the world.


  • The provision of services for the withdrawal of cash into a payment account for operations.
  • The provision of services for the depositing of cash into a payment account for operations.
  • The provision of international fund remittance.
  • Conduction of payment transactions, the transferal of funds from a payment account.
  • Enabling direct debits, including standing orders.
  • Enabling credit transfers, including one off payments (even where the funds are covered by a credit line for a payment service user).
  • Issuance of payment instruments and/or acquiring of payment transactions.
  • Issuance of electronic money, the provision of operational services and closely related ancillary services.
  • The operation of payment systems.
  • Business activities other than issuance of electronic money.


The licensing process involves some requirements for approval with the HKMA, however the process is relatively straightforward with regards to EMI activities in Hong Kong. Primarily, the future EMI license owner must:

  • Be at least 18 years old and of sound mental capacity.
  • Own an initial capital of no less than USD $225,000 for the EMI license type.
  • Own a bank account for individual or corporate purposes.
  • Have available documentation showing income (such as tax declaration or certificate from tax control authorities).
  • Not have any previous injunctions or court orders in Hong Kong.
  • Have purchased (or show a long-term lease) of a building for the company office.


A list of the main documentation required to be submitted with the application includes:

  • A schedule of operations or a detailed business plan.
  • The company’s articles of association.
  • A forecast budget for the first three financial years, demonstrating that the EMI is able to operate soundly and employs the appropriate internal control systems, procedures and resources.
  • A description of the measures taken for safeguarding electronic money holders’ funds, and where payment services not relating to issuance of electronic money are to be provided.
  • A description of the management roles, including any administrative, risk management and accounting procedures.
  • A description of the internal control mechanisms established in order to comply with obligations in relation to AML and the prevention of money laundering and terrorist financing.
  • A description of the structural organisation, such as the intended use of branches, agents, natural or legal persons through which the EMI intends to distribute or redeem electronic money or other entities to which activities will be outsourced.
  • Particulars of all individuals holding qualifying holdings in the authorised capital of the EMI, the size of their holdings in the authorised capital and/or voting rights.
  • The identity of directors, including the persons responsible for the management of the electronic money issuance activities of the EMI, including any evidence that they are of good repute and meet the necessary legislation requirements.
  • The registered office address.

Eltoma Corporate Services can assist with the following activities according to the local requirements and legislation:

  • Providing qualified legal assistance.
  • Liaising with HKMA.
  • Filling out and submitting the required documentation and applications.
  • Full legal support and representation of client interests with the HKMA.
  • Incorporation of companies and the establishment of office spaces in Hong Kong.
  • Creating a legal opinion for the payment system, working with cryptocurrencies, banking systems.

After acquiring the license, Eltoma can deliver it locally or using a secure international courier.

If you are interested in obtaining your EMI license in Hong Kong, contact us, we would be happy to provide a free, no obligation consultation.

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