We assist in the full licensing process of obtaining an E-money or Payment Institution license in Cyprus
If you are looking to obtain an Authorised Payment Institution or Electronic Money (E-Money) Institution license in Cyprus, Advapay can offer you its legal, technical and business expertise and consulting support.
Application preparation, communication with the regulator, business services
Filling out an application form
Communication with regulatory authority during the application phase
Assistance in the development of a business plan
Assistance in the opening of safeguarding accounts
Company formation, staffing services
Preparation of legal, financial and IT documents
Legal documents – AML, KYC, IT/Security policies, etc.
Financial documentation – 3-years financial forecast, P&L statement, the flow of funds
Company operational documentation – internal policies, risk operation policies, internal audit, etc.
Overview of the Cyprus fintech market
Cyprus is an internationally recognised and reputable financial and business centre because of its fintech business-friendly legal and tax environment. The legal system was derived from English common law. Cyprus is a favourable location to operate in the EU zone after the transition period of Brexit.
Regulator and legislation
The Central Bank of Cyprus is a regulator of electronic money services – it supervises and licenses the establishment and operation of such fintech companies as payment and e-money institutions. The provision of electronic money services in Cyprus is regulated by the Electronic Money Laws of 2012 and 2018.
The Cyprus Securities and Exchange Commission (CySEC) governs activities and ensures financial regulations and operations comply with the European MiFID financial harmonised law.
Doing business in Cyprus
– Low set up and operating costs.
– The English language is widely used on the island, and a highly trained workforce is usually multilingual.
– The base tax situation in Cyprus is very advantageous for businesses: corporate income tax is set generally at 12.5% for resulting net profits.
– This tax rate may be further reduced – subject to careful tax planning.
– There is no capital gains tax in Cyprus.
– Cyprus encourages research and development by introducing an 80% tax exemption on qualifying profits from the exploitation of R&D-related intellectual property qualifying assets.
– Cyprus international tax environment is beneficial because of the extensive network of Double Taxation Treaties with 52 countries.
– Tax relief can be granted to investors under specific criteria.
– The state offers generous withholding tax exemptions.
There are authorised E-money institution and Payment institution licenses available in Cyprus. The regulator doesn’t offer small institution licenses.
Office. The company must register its office in Cyprus and carry out at least a part of its electronic money service business and/or provision of payment services in the country.
Staff requirements. It is required to have a minimum of two executive directors and two non-executive directors. However, the CBC usually requires a minimum of 5 directors, at least two of which must be executive directors. These executive directors must reside in Cyprus and prove their capabilities and extensive experience and knowledge in the banking and fintech sector.
Shareholders. It is required to have at least two shareholders of the company. They must provide proof to the CBC and confirm that they have enough funds to sustain the EMI or PI.
The registration and authorisation for a license are free of charge.
1) Details of the applicant with all requested information and documents.
2) Programme of Operations with all required information and documents.
3) Business Plan with all required information and documents.
4) Structural Organisation description.
5) Evidence of Initial Capital.
6) Measures to safeguard the funds of electronic money users and/or payment services users.
7) Governance arrangements and Internal Control Mechanisms.
8) Procedure for monitoring, handling and following up on security incidents and security-related customer complaints.
9) Process for filing, monitoring, tracking and restricting access to sensitive payment data.
10) Business Continuity Arrangements.
11) Principles and definitions applicable to the collection of statistical data on performance, transactions and fraud.
12) Security policy document.
13) Internal Control Mechanisms to comply with obligations related to Money Laundering and Terrorist Financing (AML/CFT obligations).
Identity and suitability assessment of persons with qualifying holdings in the applicant.
14) Identity and suitability assessment of members of the management body and key function holders of the electronic money institution.
15) Identity of Statutory Auditors and Audit Firm.