Definition
An EME (Établissement de Monnaie Électronique, electronic money institution) is a PSP licensed to issue, manage and distribute electronic money (e-money): units of value stored on an electronic medium (card, wallet, account) against funds received.
Stemming from the second Electronic Money Directive (EMD2, 2009), the status is granted by the ACPR, with a minimum capital of €350,000.
What is electronic money
Three cumulative criteria (Article L.315-1 of the CMF):
- Stored electronically (prepaid card, wallet, application token).
- Issued against funds received (€1 received = 1 unit issued, never money creation as an EC does).
- Accepted by third parties as a means of payment.
This is what distinguishes e-money from a simple accounting claim: transferable, accepted by other players and redeemable at any time by the holder.
EME vs EP vs EC
| EP | EME | EC | |
|---|---|---|---|
| Min. capital | €20-125K | €350K | €5M |
| Issues e-money | No | Yes | Yes (rare) |
| Issues cards | Acquirer only | Issuer (BIN sponsor) | Yes |
| Takes deposits | No | No | Yes |
| Ring-fencing | Yes (third-party EC) | Yes (third-party EC) | No |
| Granting credit | Tied to payment | No | Yes |
In practice, the EME is a specialised "super EP": it can perform all the payment services of an EP, plus the issuance of e-money.
The BaaS case: why so many fintechs are EMEs
The EME status is the legal foundation of European Banking-as-a-Service. Issuing white-label cards (a Visa or Mastercard programme) requires being a principal member of the network — and therefore holding a BIN and bearing the issuer risk, a role reserved for ECs and EMEs. Hence the structuring of Treezor, Swan, Modulr, Solaris and Hype as EMEs.
Strict ring-fencing of funds
Like an EP, the EME ring-fences the funds backing the issued e-money, with a third-party EC or through safe assets. In the event of failure, the wallet is not a deposit (so it is not covered by the FGDR), but the money is isolated from the EME's balance sheet.
What an EME cannot do
- Grant credit (except short-term credit ancillary to a payment, like an EP): neither consumer credit nor a structural overdraft.
- Take deposits: e-money is not a deposit and remains redeemable at any time.
- Remunerate the e-money: prohibited under European law. To offer a yield, EMEs go through a SICAV or a partner EC (Sumeria with Carmignac, for example).
- Be supervised by the ECB: EMEs stay with the ACPR (outside the scope of the SSM).
In the PSD2 ecosystem
The EME is a PSP within the meaning of DSP2: it bears the SCA obligations, can be an ASPSP (if it holds payment accounts) and must comply with the API RTS. It is also through EMEs that the majority of early-stage fintechs operate, on their own or as agents (Treezor, Swan, Modulr).
Concrete examples
- French EMEs: Treezor (a Société Générale subsidiary, BaaS leader), Swan (API-first BaaS), Sumeria (born from Lydia, 2024), Lemonway and Mangopay (marketplaces), Hype (prepaid cards).
- European EMEs: Modulr (UK), Solaris (Germany), Railsr (UK), Wise (multi-currency), Revolut (UK EME before its move to EC).
- The Qonto case: it issues its cards white-label via Treezor as an agent. Treezor holds the Mastercard relationship, Qonto operates the product — a move to doing it itself is planned with the EC licence.
- Sumeria and remuneration: since e-money cannot be remunerated, Sumeria distributes the funds via a Carmignac money-market SICAV that "carries" the yield.
- Cost of the status: minimum capital of €350K, own funds calculated on the e-money outstanding in circulation (~2% on average), quarterly reporting and an annual audit.
- Licensing lead time: 9 to 18 months with the ACPR, with a high failure rate on the first application — compliance support is almost mandatory.
- PSD3 / PSR evolution: a planned merger of the EP and EME regimes into a single PSP status (impact 2026-2028), a topic that EMEs are watching closely.