1. PI license legal access conditions and operational substantive requirements
Management Essence and "Four Eyes Principle" (Four-Eyes Principle)
Applicants must demonstrate that the institution is effectively directed and managed in Malta，And allocate directors and senior management personnel commensurate with the business。MFSA will review the "Four Eyes Principle"、Actual performance of duties and local substance；MLRO employment、live、The scope of employment and outsourcing must be determined in accordance with Malta AML/CFT rules and FIAU/MFSA case requirements，It cannot always be written that outsourcing is strictly prohibited。
Legal initial capital and continuing own funds
PI initial capital is graded by service type：Applicable to 125,000、5Thousand or €20,000 threshold。After being authorized, you must continue to calculate your own funds according to the applicable method.；MFSA can be adjusted on a case-by-case basis in accordance with the law，initial capital、Ongoing own funds and operating budgets must be reconciled separately。
suitability assessment (Fit and Proper Test)
Administrative body members、Actual responsible operating personnel、Key control functions and direct or indirect qualified shareholders will accept reputation、experience、invest、financial soundness、Chain of control and review of sources of funds and wealth。Personal questionnaires and supporting documents are determined based on the current MFSA form and case.。
Customer fund isolation mechanism (Safeguarding)
PI cannot treat funds received for payment services as deposits。Relevant funds still held beyond the applicable time point must be protected in accordance with the rules，Segregated accounts/low-risk assets or qualifying insurance/guarantee options available；Account、mechanism、Time and return arrangements must be confirmed based on actual services。
2. Malta’s PI related system changes and verification boundaries
- MiCA and PI authority boundaries
MiCA crypto asset service authorization and PSD2 payment institution authorization are different systems。Whether third-party companies hold MFSA’s PI、EMI or MiCA authorization，Should be verified by legal name and authority through MFSA directory；Insurance regulator IAIS document not legal basis for payments or crypto assets in Malta，PI does not automatically grant stablecoin service permissions.。
- DORA continuing obligations
PIs subject to DORA must maintain an ICT third-party arrangement information register，And according to the current notice of the competent authority、Format and deadlines for submission。Specific annual window may be adjusted，This page is not always written from January 1st to March 21st every year。
- MFSA fees must be reviewed according to current rules
Apply、Authorization and annual supervisory fees shall be reconciled against the Malta Financial Institutions Act subsidiary fee rules and the MFSA fee schedule in effect at the time of submission or billing。The information available on this page is insufficient to confirm the unified application fee of 10,000 euros and the annual base price of 15,000 euros.。
3. List of statutory application documents (Submit elements)
Three-year forward-looking financial budget model and own fund calculation report
Internal Control Systems and Anti-Money Laundering/Counter-Terrorism Financing (AML/CFT) Procedures Manual
Customer Fund Protection Methods、Account or Insurance/Guarantee、Record、Reconciliation and return arrangements
Comply with the Digital Operations Resilience Act(DORA) Standard ICT security and disaster recovery plan
Key Personnel and Shareholder Suitability Questionnaire，and proof of sources of funds and wealth prepared according to risk
4. MFSA application、Review and Continuing Operations Process
Stage one：scope、Governance and pre-application preparation
Confirm payment service、PI category、capital、shareholder、personnel、Malta practical management、Customer fund protection、AML/CFT、ICT and outsourcing。Whether to submit a letter of intent or attend a pre-application meeting will be determined according to the current MFSA procedures.。
Stage 2：Formal application and substantive examination
提交当期表格和支持文件。MFSA可要求补件或管理层说明；问询次数、回复期限和审查深度取决于个案，Not a fixed multi-round procedure。
Stage three：Obtain a letter of in-principle approval (In-Principle Approval)
如MFSA发出附条件决定，申请人须在指定期限完成资本、governance、personnel、ICT和客户资金保障等条件；具体条件和证明形式由个案决定。
Stage four：授权与持续合规
获授权后机构须在权限和条件内经营，Continue to fulfill capital、Customer fund protection、governance、AML/CFT、DORA、Audit and reporting obligations；Registration or reporting arrangements with FIAU shall be handled in accordance with applicable AML/CFT rules。
5. capital、Official charges and commercial operating cost boundaries
| Cost category | Statutory fee standards and budget assessment |
|---|---|
| Single application fee (Non-refundable) |
PI、Application fees for EMI and other permissions must be confirmed according to the MFSA fee schedule valid at the time of submission。This page has not verified "PI 10,000 euros、PI + EMI 15,000 euros" unified combination charge。 |
| Legal initial capital (License bottom line) |
Minimum payment requirements for all services 12.5million euros；Payment activation service (PISP) lowest 5million euros；Funds remittance service is the lowest 2million euros。 |
| annual supervision fee (Fixed + floating mechanism) |
Annual regulatory fees are required by type of institution、Approved services and current fee calculation rules。This page has not verified the base price of 15,000 to 25,000 euros and the floating ratio of assets/transaction volume.。 |
| Architecture and Compliance Costs (Third-party auditing and agency) |
personnel、system、audit、Bank and consultant fees are commercial project costs，Should be prepared based on actual business and supplier quotations，Not a government fee；MFSA does not have a unified upfront budget of 150,000 to 300,000 euros。 |
6. Application risks and evidence that needs to be strengthened
Flaws in proving the source of funds： shareholding 10% The original source of funds (SoW/SoF) documents submitted by the above shareholders are incomplete or have legal flaws.，Unable to meet penetration requirements for anti-money laundering compliance review。
Substantial operational deficiencies：Applicants must demonstrate that the institution is effectively directed and managed in Malta，and deploy appropriate personnel。Residence of directors and MLRO、Employment and outsourcing arrangements must be confirmed on a case-by-case basis and prevailing rules，We cannot make overseas or outsourcing illegal.。
Customer fund protection has not been implemented：Eligible account arrangements must be obtained when using segregation；Applicable insurance/guarantee methods should also be evaluated。The bank or insurance institution will conduct independent due diligence，MFSA authorization does not guarantee approval of the account or protection instrument。
7. Public list verification and application preparation scenarios
Distinguish PI、EMI and MiCA authorization
When inquiring about third-party companies，Legal name should be checked against the MFSA directory、Authorization category、Approved services and current status。MiCA crypto asset service authorization cannot be directly written as a PI license，Nor may the public institution be described as a client or regulatory endorser of Hong Kong Express。
Malta PI payment institution license application preparation scenario 2
This scenario is used to illustrate common application preparations、Remediation or continuing compliance matters，Does not represent specific customers、Approval cycle or application results。Actual requirements are reviewed by the competent authority on a case-by-case basis。
8. Practical Compliance Q&A (FAQ)：Analysis of legal conditions and regulatory procedures
Empty shells and arrangements that completely lack actual Maltese governance generally do not meet the authorization requirements。Applicants must demonstrate that at least two appropriate personnel effectively direct the business and have local management substance；concrete residence、Employment and office arrangements are reviewed by the MFSA on a business and case-by-case basis。
PI can pass cross-border services when eligible、Agent or branch notification to enter other EEA countries，Subject to completion of applicable procedures and compliance with host country rules。Notice does not exclude all host country consumer protection、AML/CFT or other applicable requirements。
PI can provide MFSA approved payment services，Includes applicable account actions、transfer、payment instrument、Acquiring、money transfer、Payment initiation or account information services。PI cannot issue electronic currency，Funds received for payment services cannot be treated as deposits。
The initial capital is RMB 20,000 depending on the service type.、5Thousand or €125,000 threshold；After authorization, continuing self-owned funds must be calculated according to applicable methods.。Final amount depends on approved services、Business data and case-by-case adjustments made by the MFSA in accordance with the law。
Proposed personnel and governance arrangements must be submitted when applying，and demonstrate that the person is able to meet the conditions prior to authorization。Whether a local employment contract must be signed at a specific stage，and MLRO residence、Employment or outsourcing arrangements，Must be confirmed according to the current requirements and case decisions of MFSA/FIAU。
Apply to a payment institution with complete information，The PSD2 framework provides that the competent authority will usually communicate its decision within 3 months.。Application preparation、Supplementary parts、Conditional matters and third-party audits are not included in the same calculation，Officials do not guarantee end-to-end 6 to 12 months。
Application fees and annual regulatory fees are calculated based on the MFSA fee schedule and agency authority in effect at the time of submission or billing。There is insufficient information on this page to confirm the €10,000 application fee、1.5Base price from 10,000 to 25,000 euros and related sliding ratios。
Eligible segregated accounts and insurance/guarantee options should be compared，and submit real business to potential partners、governance、Capital and Control Information。Hong Kong Huitong can coordinate materials according to scope，But there is no guarantee that the bank、EMI or insurance agency accepted。
DORA-applicable PIs can outsource ICT while maintaining ultimate responsibility，However, management due diligence is required、contract、access audit、Subcontract、Concentration、Continuity and exit risks，and maintain a register of information。Submit scope、The format and deadline shall be confirmed according to the current notice of MFSA。
Unclear sources of funds and wealth、Insufficient business risk assessment、Inappropriate management personnel or failure to secure customer funds may affect the application.。MFSA determines based on legal standards and all materials，It cannot be predicted that any single item will be rejected directly.。
Entities that qualify as small payment institutions in Malta may be eligible for the registration route，But it must meet the transaction volume、Personnel and other restrictions，and cannot use the EEA passport mechanism。Applicability and capital requirements must be confirmed according to the current rules of MFSA。
Institutions are required to perform applicable financial audits、capital、Customer fund protection、AML/CFT、DORA and regulatory filings。Is an independent system security audit required?、The specific FIAU questionnaire and submission frequency must be confirmed according to the institutional risk and current MFSA/FIAU requirements.。
9. Official supervision and application information
| official information | Main purpose | Link |
|---|---|---|
| MFSA Authorisations | Check the Malta payment institution application and authorization portal | MFSA authorization page (English) |
| Malta Financial Institutions Act | Check PI legal basis、Payment services and authorization | Official legal text (English PDF) |
| EUPSD2 | Check capital、Authorize、Client Fund Protection and EEA Notification Framework | EUR-Lex specific page (English) |
10. Relevant regulations、Regulatory information and further reading
| Data category | Related information |
|---|---|
| Licensing and regulatory authorities |
