1. [Statutory Commercial and Supervisory Mechanism] for Luxembourg EMI License
EU Passport Rights of Passage
Luxembourg EMI plans to pass cross-border services、When agents or branches enter other EEA countries，Home country notification and applicable registration procedures are required，and comply with relevant host country rules。The passport mechanism does not mean that you can operate unconditionally in a fixed "27 countries"，The UK and other markets outside the EEA must be confirmed separately。
Legal business authorization
EMI can issue electronic currency and provide related payment services within the scope of authorization.。payment account、transfer、Acquiring、Payment instruments and foreign exchange exchanges closely related to payment services should be confirmed on a case-by-case basis according to permitted activities.；Electronic money is not bank deposits。
Wholly owned holding structure
Foreign shareholders are not necessarily prohibited，However, shareholders who directly or indirectly hold qualifying shares、chain of control、ultimate beneficial owner、Sources of funds and wealth will be scrutinized；The final shareholding structure must also comply with applicable prudential、Transparency and other statutory requirements。
Statutory tax rate base
corporate income tax、municipal business tax、VAT and financial services tax treatment depends on the location of the entity、Transaction and customer facts，Not subject to uniform conditions for granting CSSF licenses。It should be confirmed based on the Luxembourg tax authority information and professional tax opinions at the time of application and transaction.。
2. [Statutory classification and capital standards] of Luxembourg CSSF payment license
| Statutory license type | Business authority and regulatory definition | Legal minimum initial capital |
|---|---|---|
| electronic money institution (EMI) |
Authorized to issue electronic money (e-money)，And can provide a wide range of payment services and payment account operations。 | 350,000 EUR。Applicants must demonstrate that initial capital consists of eligible capital projects and is available at the time of authorization；Specific investment、Accounts and supporting documents are confirmed according to CSSF requirements。 |
| payment institution (PI) |
Payment services can be provided within the permitted scope，But cannot issue electronic money。Receipt of client funds、Holding and protection depend on the specific payment service and applicable rules，It cannot be summarized as that it should never be held for a short period of time.。 | According to specific service type，between 20,000 to 125,000 EURbetween。 |
illustrate：EMI must continue to maintain at least its own funds that are no less than the statutory initial capital.，Additional requirements will be calculated based on the method applicable to the average balance of electronic money and incidental payment services.；CSSF can be adjusted according to law。Capital composition、Sources of shareholders’ capital contributions and items that can be counted must be checked on a case-by-case basis。
3. [Corporate governance and local substantive requirements] for Luxembourg EMI
Local content versus central management：The applicant must be a Luxembourg legal person that complies with applicable laws，Registered office and central administration in Luxembourg，And have the business、System and outsourcing commensurate local personnel、place、Decision-making and control skills。CSSF official information does not provide the "at least 5 employees" threshold that is uniformly applicable to all EMIs.。
governance body：Members of the administrative body and those actually responsible for operations must have good reputations，and knowledge commensurate with the responsibilities、Skills and experience。Number of people、perform duties、Residency arrangements and time commitment are determined by law、organizational form、Business complexity and CSSF case review decisions，The unified "three directors" should not be applied、5years of experience” template。
AML/CFT governance：Applicants must designate AML/CFT responsible personnel and control functions that comply with Luxembourg law and CSSF requirements，Clarify management responsibilities、independence、resource、Debriefing and bench arrangements。permanent、language、Years of experience and scope of outsourcing must be confirmed based on responsibilities and cases，Unable to use unified “3 years experience” threshold。
Suitability and shareholder review：Administrative body members、The actual responsible operating personnel and qualified shareholders will accept the reputation、experience、financial soundness、Chain of control and source of funds review。10%It is one of the important thresholds for qualified shareholding.，But indirectly holding shares、Control or significant influence may also trigger review。
4. [List of documents submitted to Luxembourg CSSF for statutory review]
| File category | Submission details for statutory requirements (English/French) |
|---|---|
| Corporate Fundamentals and Equity Documents | Articles of association and registration information of Luxembourg legal person、Proof of initial capital and availability、Registered Office and Central Administration Arrangements、Equity and chain of control、UBO and sources of funds and wealth information；The specific legal forms and documents are subject to the CSSF list.。 |
| Business and Financial Documents | Contains at least 3 Annual financial forecast business plan。Capital flow and data flow structure diagram (Flow of Funds Diagram)。Capital adequacy ratio calculation instructions。Customer Fund Protection Methods、capital flow、Instructions for reconciliation and arrangements with cooperative institutions；Whether the bank's intention or confirmation materials are required and their form shall be determined according to the specific plan and CSSF requirements.。 |
| Internal Governance and Compliance Policy | Anti-money laundering and counter-terrorism financing (AML/CFT) Policy and KYC Handbook。Risk Management and Internal Control Framework。Data and IT security policy compliant with EU DORA regulations、Disaster recovery mechanism (BCP/DR) and outsourcing management policies。 |
5. [Statutory application and CSSF review procedures] for Luxembourg EMI license
first stage：Business scope、Entity and preparation
Determine the scope of electronic money and payment services，Establishing a qualified Luxembourg legal person，Prepare capital、governance、Local central management、Customer fund protection、system、outsourcing、AML/CFT and three years of financial information；Whether to conduct pre-application communication is determined according to CSSF procedures.。
second stage：Submit application dossier
Submit the application form according to the method specified by CSSF、business plan、governance、personnel、capital、Customer fund protection and control documents，And check the fees according to the official fee regulations in effect at the time of submission.。
The third stage：Completeness and Substantive Review
CSSF can provide business models、capital、personnel、governance、Customer fund protection、AML/CFT、Technology and outsourcing raise additional questions，and may require proposed managers to explain their responsibilities。Inquiries and interviews are not a fixed number of times or a unified process。
Stage 4：Authorization decisions and continued operations
Authorization decisions are made in accordance with Luxembourg legal procedures，and may come with conditions。Institutions must start business within the approved scope and conditions，Continue to maintain capital、Customer fund protection、governance、AML/CFT、DORA and regulatory filings；Official information does not guarantee a fixed 8 to 12 month cycle。
6. Client funds segregation (Safeguarding) Mechanism and [IT Compliance Red Line]
Customer fund protection：Relevant funds received for the issuance of electronic money or provision of payment services must be protected in accordance with applicable rules，Not allowed to be mixed with the institution’s own funds。Isolation or qualifying insurance/guarantee available；Account、assets、The organization and time must be checked according to the specific business。
Reconciliation and discrepancy processing：Institutions are required to reconcile internal books at a frequency commensurate with transaction volumes and safeguard methods、External accounts and amounts to be protected，Upgrade and make up for differences in a timely manner，and retain evidence according to the applicable retention period.；Whether it must be "automatic every day" and the specific number of years must be confirmed according to the rules and CSSF requirements。
DORA and testing：Institutions subject to DORA must establish ICT risks、event、business continuity、recover、Testing and third-party risk management。Testing depth and frequency are determined by risk and statutory classification；Not all EMIs uniformly require annual independent penetration testing。
ICT and other outsourcing：Suppliers are not blocked based on being located outside the EU，However, institutions must complete a risk assessment、written contract、Access audit rights、Data and security、Subcontract、Concentration、Business continuity and exit arrangements，and ensure that CSSF can effectively supervise。
7. [Details of government fees and statutory operating costs] for Luxembourg EMI license
| Funding and Expense Categories | Legal requirements and budget standards (EUR) |
|---|---|
| Legal initial paid-in capital | lowest 350,000 EUR。Must prove capital composition、Source and availability at the time of authorization；"Local bank frozen capital verification" should not be written as a unified legal form for all cases。 |
| CSSF official fees | This page cannot confirm the above fixed range from the verified CSSF authorization page。Apply、Authorization and ongoing supervision fees shall be in accordance with the CSSF fee regulations in effect at the time of submission or billing、Institutional Category and Business Fact Checking。 |
| Rigid statutory maintenance costs | external audit、The scope of ICT testing and professional services depends on statutory requirements、Organization size and supplier quotes；Commercial quotations are not government fees，Nor should it be labeled as a uniform “rigid statutory cost”。 |
| Comprehensive operating budget requirements | The business plan must demonstrate sufficient resources to support local governance、personnel、place、Systematic and ongoing compliance。There is no official basis on this page to support the harmonization of the “5 employees” or “€500,000 buffer” thresholds，Budgets should be prepared based on business forecasts and CSSF case requirements。 |
8. Luxembourg EMI application support provided by Hong Kong Huitong
Corporate establishment and personnel recruitment
Can assist in sorting out Luxembourg entities、Governance and staffing needs，And coordinate third-party services as agreed on the project。Personnel recruitment、Eligibility and suitability are ultimately reviewed by the applicant and CSSF，There is no promise that "matching means qualification"。
Compliance system and business plan preparation
Can assist in preparing business plans based on actual business、Financial Forecasting and Governance、AML/CFT、ICT、Business Continuity and Outsourcing Documentation；Applicant management must review、Approval and responsible for actual implementation。
CSSF Application and Interview Agent
Can assist in submitting application materials according to the scope of authorization、Preparation of inquiries and management briefings，and coordinate bank contacts；CSSF review、Personnel performance、Capital accounts and customer fund protection accounts are independently determined by relevant institutions。
9. Luxembourg EMI / PI regulatory license core legal questions and answers (FAQ)
In accordance with the Payment Services Act(PSL)，EMI authorized to issue electronic money，And can provide a wide range of payment services and payment account operations。PI is limited to providing payment services，No authority to issue electronic money。The statutory minimum paid-in capital of the two is respectively 35 million euros (EMI) and 2 Wanzhi 12.5 million euros (PI)。
EMI intends to provide cross-border services in other EEA countries、When operating as an agent or branch，Applicable notification procedures must be followed to the CSSF，and comply with relevant host country rules。The passport mechanism does not cover markets outside the EEA such as the UK，It does not constitute an unconditional business guarantee。
EMI initial capital must not be less than 350,000 euros，and must prove capital composition、Source and availability at the time of authorization。What can be included in capital projects and investment certificates are determined according to legal and CSSF case requirements.；"Local bank freeze" or all shareholder borrowing situations should not be written as a uniform statutory prohibition。
EMI must continue to meet its own capital requirements that are at least no less than the statutory initial capital.，And calculated based on the average outstanding electronic money and incidental payment services using the applicable method；CSSF can be adjusted according to law。The final amount must be calculated based on business data and capitalized items。
Electronic money is not a deposit。Relevant client funds must be safeguarded in accordance with applicable rules，Not allowed to be mixed with the institution’s own funds；Segregation or qualifying insurance/bondage available。Account、assets、Reconciliation frequency and difference processing must be confirmed according to the specific guarantee plan。
The registered office and central administration shall be located in Luxembourg，and have local decisions that are commensurate with the business、personnel、Location and control capabilities。CSSF will be based on business、Systems and Outsourcing Review Substance，This page does not use the "at least 5 employees" threshold that has no official basis.。
Applicants must configure AML/CFT management responsibilities and control functions in accordance with Luxembourg law and CSSF requirements，Ensure personnel have experience commensurate with responsibilities、Permissions、independence and resources。permanent、language、Years of experience and scope of outsourcing must be confirmed based on responsibilities and cases。
Foreign shareholders are not necessarily prohibited，But shareholders、chain of control、COUGH、Financial soundness and sources of funds and wealth will be reviewed。Whether 100% overseas holding can be adopted must also be combined with qualified shareholdings.、Group supervision and other applicable legal judgments。
Protected client funds may not be used for group financing or institutional operations。Institution’s own funds、Distributable profits and group transactions are subject to capital、company law、Related party transactions、Governance and regulatory requirements；All legitimate capital flows cannot be summarized with the exception of “dividends only”。
ICT services may use onshore or offshore suppliers subject to DORA and other outsourcing rules。Organizations must retain ultimate responsibility、risk assessment、Contract and Audit Access、Incident and continuity management、Subcontracting and exit arrangements；Test scope and frequency determined by risk and statutory classification。
CSSF will conduct a completeness and substantive review，You can also request supplementary documents or management explanations.。The total period depends on the scope、Material、personnel、system、Third Party Arrangements and Inquiries；There is no official basis for this page to promise unification for 4 to 12 months，Authorization decisions are made in accordance with Luxembourg legal procedures。
Authorized institutions must continue to fulfill financial、capital、Customer fund protection、AML/CFT、audit、Obligation to report statistics and major changes。specific form、frequency、Duration and audit scope depend on current rules、Institutional Category and CSSF Requirements，Submissions should be checked item by item through the CSSF declaration calendar and notifications。
10. Official supervision and application information
| official information | Main purpose | Link |
|---|---|---|
| CSSF：PI and EMI authorization procedures | Check Luxembourg PI and EMI applications、Review and Authorization Requirements | Open CSSF specific page (English) |
| EUR-Lex：Consolidated Text of the Electronic Money Directive | Check EMI initial capital、Business and Passport Legal Framework | Open the EUR-Lex specific page (English) |
11. Relevant regulations、Regulatory information and further reading
| Data category | Related information |
|---|---|
| Professional interpretation | |
| Licensing and regulatory authorities |
