Payment Institution and E-Money Licence in Romania
We file the Romanian company that applies at the Trade Register, provide its registered-office address and assemble your BNR file with a partner Romanian lawyer and your own specialists. The BNR decides.
- BNR authorisation: art. 9 Law 209/2019, art. 7 Law 210/2019
- Applicant: a legal person established in Romania
- Initial capital: EUR 20,000 to EUR 350,000, EU minimum
- Decision: 3 months from a complete file, EU rule
How we support a payment or e-money licence application
The BNR (Banca Națională a României, National Bank of Romania) authorises payment institutions under art. 9 Law 209/2019 and e-money institutions (EMIs) under art. 7 Law 210/2019. A legal person established in Romania applies; we file its registration and assemble its file. Only an issuer authorised as a credit institution or an EMI may offer e-money tokens to the public (art. 48 MiCA); the MiCA route is our crypto licence service.
RomaniaRegist is not a payment service provider and holds no client funds (art. 37(1) PSD2, Directive (EU) 2015/2366). The BNR grants a licence only on a favourable overall assessment (art. 11(2)), so no licence and no date are promised. A partner Romanian lawyer prepares bespoke legal texts; the company is filed as described on the company registration page.
What's included
Seven parts of the work, and where it stops. A trade mark for the institution's name is a separate file, run through our trademark registration service.
Scoping intake
We collect your description of the services and flows; a partner Romanian lawyer maps it to the Annex I payment services, e-money, account-information registration or an excluded service.
The Romanian applicant company
We file the company at the Trade Register (ONRC) under power of attorney and provide our registered-office address. The head office and business in Romania are the applicant's own; a partner lawyer drafts bespoke deeds.
The BNR application file
We collect the documents art. 5 PSD2 names, chase signatures and track the file; the content is written by you and your specialists.
Translations and apostilles
We coordinate certified translations and apostilles. A power of attorney notarised in another EU state still needs the apostille unless a bilateral treaty removes it; an EU criminal-record certificate needs none (Regulation (EU) 2016/1191).
Specialist liaison
A partner lawyer, the company's CECCAR accountant for the projections and accounting procedures, and a compliance specialist you appoint for the AML part write the file; you sign it.
Our own checks
As a trust and company service provider (art. 2(l)(3) Law 129/2019), we check identity and beneficial owners before any filing and may decline a client.
Where the service stops
No licence or date promised, no payment services or client funds, no bespoke drafting, no books or projections, no tax advice, no licensed company for sale.
Licence, registration or notification
A notification is not a licence. The three regimes side by side, as the BNR registers and PSD2 set them out.
| Regime | What it is | What the authority does | Source |
|---|---|---|---|
| Payment institution (instituție de plată) | provides the payment services of Annex I PSD2 | the BNR authorises it under art. 9 Law 209/2019; register section III.1 | BNR registers |
| E-money institution (instituție emitentă de monedă electronică) | issues electronic money (monedă electronică) and may also provide payment services | the BNR authorises it under art. 7 Law 210/2019; register section IV | BNR registers |
| Account information service provider (AISP, furnizor specializat în servicii de informare cu privire la conturi) | gives account information only | registered, not authorised, under Title II Chapter II Law 209/2019; register section III.2 | BNR registers |
| Excluded service (servicii de plată exceptate) | a service excluded under art. 4 lit. k) and, where applicable, lit. m) Law 209/2019 | notified under art. 106 and 108; not authorised or supervised by the BNR; register section III.3 | BNR registers |
| Limited-network provider | a provider relying on the limited-network exclusion | notifies the authority once its transactions over the preceding 12 months exceed EUR 1 million | art. 37(2) PSD2 |
| Anyone else | neither a payment service provider nor expressly excluded | may not provide payment services | art. 37(1) PSD2 |
Classifying a model is a legal opinion, lawyer work under art. 3(1)(a) and 3(2) Law 51/1995. Where a model also needs a sector authorisation, the licences and permits guide sets out where to look.
Initial capital and own funds by licence
These are the EU minimum amounts the Romanian laws transpose; the partner lawyer confirms the Romanian wording before the capital is paid in.
Payment institution against e-money institution
Authorisation
Payment institution: Art. 9 Law 209/2019E-money institution: Art. 7 Law 210/2019Initial capital
Payment institution: EUR 20,000 / 50,000 / 125,000, by serviceE-money institution: EUR 350,000Own funds
Payment institution: Method A, one of three methods; the BNR determines which applies: at least 10% of the preceding year's fixed overheadsE-money institution: At least 2% of average outstanding e-moneyWhat it does
Payment institution: Provides payment servicesE-money institution: Issues e-money, may also provide payment services, may not take depositsSafeguarding
Payment institution: Art. 38 Law 209/2019E-money institution: Art. 38 Law 209/2019 (art. 34(1) Law 210/2019)
EU minimum, PSD2 and EMD2
| Licence or rule | What it covers | Amount or rate, EU minimum | Source |
|---|---|---|---|
| Payment institution, money remittance only | point 6 of Annex I PSD2 only | EUR 20,000 | art. 7(a) PSD2 |
| Payment institution, payment initiation | point 7 of Annex I | EUR 50,000 | art. 7(b) PSD2 |
| Payment institution, services 1 to 5 | includes issuing payment instruments and acquiring (point 5) | EUR 125,000 | art. 7(c) PSD2 |
| E-money institution | issuing electronic money | EUR 350,000 | art. 4 EMD2 |
| When the capital is held | initial capital (capital inițial) | at the time of authorisation | art. 7 PSD2 |
| Own funds floor | own funds (fonduri proprii) of a payment institution | never below the initial capital or the calculated amount, whichever is higher | art. 8(1) PSD2 |
| Own funds, Method A | payment institution, except one offering only payment initiation, account information or both | at least 10% of the preceding year's fixed overheads; Method A is one of three methods and the BNR determines which applies | art. 9(1) PSD2 |
| Own funds for issuance | e-money institution | at least 2% of average outstanding e-money | art. 5(3) EMD2 |
Capital is the institution's own money, not a fee and not our price.
How the licence process works
Scope: which regime
The model is mapped to the Annex I services, e-money, account-information registration or an exclusion. We collect the description and arrange the partner lawyer; no official time applies.
Who acts: CLIENT and LAW; US collect
The Romanian legal person
We file at the ONRC; the registrar's one working day is the statute's term (art. 105(1) Law 265/2022, 2022 text). A company missing an authorisation required for its incorporation can be declared void (art. 56 lit. e) Law 31/1990, text of January 2024). Which comes first is not settled; the partner lawyer decides.
Who acts: US and ONRC; LAW
Initial capital
The shareholders pay in the amount for the chosen licence, held at the time of authorisation (art. 7 PSD2). The partner lawyer confirms the lei conversion and the eligible items.
Who acts: CLIENT
The application file
Management writes the file with the partner lawyer, a CECCAR accountant builds the projections and a compliance specialist you appoint the AML part. We collect documents, arrange translations and apostilles, and coordinate.
Who acts: CLIENT, LAW and ACCOUNTANT; US coordinate
Assessment and decision
The BNR grants the licence only on a favourable overall assessment (art. 11(2) PSD2). The EU rule is a decision within 3 months of a complete file (art. 12), the same for EMIs (art. 111).
Who acts: BNR
Register entry and start of business
Listed in BNR register III.1 or IV, the authorisation is valid EU-wide (art. 11(9) PSD2); a first cross-border activity is notified via the BNR. Unused for 12 months, it may be withdrawn under the EU rule (art. 13(1)(a)).
Who acts: BNR; CLIENT
After authorisation
Own funds, safeguarding, BNR anti-money-laundering supervision and prior notice of holding changes follow. Ongoing accounting stays with CECCAR professionals; regulatory and AML compliance with the institution itself.
The 3 months is the authority's term from a complete file; making the file complete is the work.
Who acts: CLIENT and ACCOUNTANT
How a Romanian payment or e-money licence is applied for
Client
Partner lawyer
RomaniaRegist
CECCAR accountant
ONRC
BNR
- Term 2one working day, the statute's term and not a promise, for the company filing only (art. 105(1) Law 265/2022, 2022 text)
- Term 53 months from a complete file, the EU rule (art. 12 PSD2; art. 111 for EMIs)
- Term 6an authorisation unused for 12 months may be withdrawn under the EU rule (art. 13(1)(a) PSD2)
The 3 months is the authority's term from a complete file; making the file complete is the work.
Not sure which regime your model falls under?
Describe your services and flows; a partner lawyer qualifies the model in a conversation, and we set out the company and file work.
What the BNR file contains and what you supply
What art. 5 PSD2 names, plus what we need from you for the projections, our own checks and the translations; the BNR's own list, form and channel are confirmed with the partner lawyer.
- A programme of operations for the planned services
- A business plan with a forecast budget for the first 3 financial years
- The source documents a CECCAR accountant turns into the projections
- Evidence of the initial capital for the chosen licence
- Safeguarding, governance and incident-handling descriptions, written with the lawyer
- Business continuity and a security policy with a detailed risk assessment
- Directors with evidence of good repute, knowledge and experience; qualifying shareholders with evidence of their suitability
- Identity and beneficial-owner documents for each of them, for our checks
- For payment initiation: professional indemnity insurance or a comparable guarantee
- Certified translations and apostilles; an EU criminal-record certificate needs no apostille
Duties after authorisation
These are the institution's own duties, not ours.
| Duty | What the rule says | Applies to | Source |
|---|---|---|---|
| Own funds | never below the initial capital or the calculated amount, whichever is higher | payment institutions | art. 8(1) PSD2 |
| Safeguarding (conturi de protecție a fondurilor) | funds not paid out by the end of the next business day are held in a separate account at a credit institution or, where the BNR opens such accounts, at the BNR, or invested in safe, liquid, low-risk assets as BNR rules define them; the BNR decides whether it opens such accounts | payment institutions | art. 38 Law 209/2019, as amended by OUG 5/2026 (Monitorul Oficial no. 172, 5 March 2026) |
| Safeguarding, e-money | the funds received in exchange for e-money are protected under art. 38 Law 209/2019 | e-money institutions | art. 34(1) Law 210/2019, as amended by OUG 5/2026 |
| Qualifying holdings | a stake reaching or exceeding 20%, 30% or 50% of the capital or votes needs prior written notice to the authority | both | art. 6(1) PSD2 (payment institutions); art. 3(3) EMD2 (EMIs) |
| Use of the authorisation | under the EU rule, may be withdrawn if unused within 12 months, or after more than 6 months without business, unless national law makes it lapse | both | art. 13(1)(a) PSD2 |
| EU passport | valid in all member states, with a notification through the home authority for a first cross-border activity; incoming EU payment institutions are on BNR list VII and EU EMIs on list VIII | both | art. 11(9) PSD2; BNR registers |
| Anti-money-laundering supervision | the BNR supervises Romanian payment institutions and EMIs | both | art. 27(1)(b)-(c) Law 129/2019 |
| E-money tokens | the issuer must be authorised as a credit institution or an EMI and have notified a white paper; other persons offer only with the issuer's written consent | e-money institutions | art. 48(1) Regulation (EU) 2023/1114 (MiCA) |
Accounting and returns belong to a CECCAR accountant (art. 21(1) OG 65/1994; art. 10(3) Law 82/1991) and tax advice to a CCF tax consultant (art. 3(1) OG 71/2001), not to RomaniaRegist.
Problems we solve
Five questions founders raise, and how each is handled.
Do I need a licence at all?
Authorisation, registration and notification all exist, and a notification is not a licence. Which one a model falls under is a legal opinion: we route it to the partner lawyer.
How long will it take?
Only the EU term is stated: 3 months from a complete file (art. 12 PSD2). We promise no duration; the registrar's one working day concerns the company filing only.
Can I buy a company that already has a licence?
That is a change of qualifying holding with prior notice, and under the EU rule an unused authorisation can be withdrawn. We sell no licensed company; an ordinary SRL comes through our ready-made companies service.
Do I need to live in Romania?
The texts we cite require a Romanian legal person with its head office and part of its business here; our address alone shows neither. They state no residence rule, and we supply no administrator.
Can a licence from another EU country serve Romania?
A passport can allow it, and the BNR lists EU institutions that notified services here. A Romanian licence is needed where the head office and part of the business are in Romania.
Want the company, the address and the file lined up?
Tell us the services you plan and where your team sits; we line up the company, the address and the file, with a partner lawyer for the legal texts.
Why work with RomaniaRegist
RomaniaRegist is a trust and company service provider notified to ONPCSB (art. 2(l)(3) Law 129/2019) and is not a payment service provider.
From our practice
Before a file is started, Victor checks who the directors and qualifying shareholders are and which specialist writes which part.
Licensing and founder immigration lead
Frequently asked questions
Can you guarantee the licence, or a decision date?
No. The BNR grants a licence only on a favourable overall assessment of the file (art. 11(2) PSD2), and the 3-month decision term runs from a complete file, not from our filing (art. 12). We assemble and coordinate the file; the decision is the authority's, and no date is promised.
Can I buy a Romanian company that already holds a BNR licence instead of applying?
We do not sell licensed companies. A stake reaching or exceeding 20%, 30% or 50% of the capital or votes needs prior written notice to the authority (art. 6(1) PSD2; art. 3(3) EMD2 for an EMI), and under the EU rule an unused authorisation can be withdrawn after 12 months (art. 13(1)(a)). A ready-made SRL carries no licence.
Do I need a licence at all, or does my model fit an exclusion that only needs a notification?
Three regimes exist: authorisation for payment institutions and EMIs, registration for account information service providers, and notification for excluded services, whose providers are not authorised or supervised by the BNR. Qualifying a model is a legal opinion for a partner Romanian lawyer (art. 3(1)(a) and 3(2) Law 51/1995); a notification is not a licence.
Is it enough to register as an account information service provider?
An account information service provider is registered under the lighter regime of Title II Chapter II Law 209/2019, not authorised. Payment initiation is a different service, point 7 of Annex I PSD2, and needs authorisation with at least EUR 50,000 of initial capital (art. 7(b)). Whether a model fits registration is a question for the partner lawyer.
Can a foreign-owned company get a payment institution licence from the BNR, or must the founders live in Romania?
PSD2 requires a legal person established in a member state, with its head office in the same state as its registered office and part of its payment business carried on there (art. 11(1) and (3)). A registered-office address alone does not show that. The texts we cite state no residence or nationality rule for directors and shareholders.
How long does the BNR take to decide on a payment or e-money licence application?
The EU rule is a decision within 3 months of receiving the application or, if it was incomplete, of all the information required (art. 12 PSD2); the same rules apply to EMIs (art. 111). The partner lawyer confirms the Romanian article, and no time for the whole process is published or promised.
How much initial capital does a payment institution need, by service?
At the EU minimum: EUR 20,000 for money remittance only, EUR 50,000 for payment initiation and EUR 125,000 for any of services 1 to 5 of Annex I (art. 7 PSD2), held at the time of authorisation. Law 209/2019 transposes these rules; the partner lawyer confirms the Romanian wording before the capital is paid in.
What is the difference between a payment institution and an e-money institution, and why does an EMI need EUR 350,000?
A payment institution provides payment services. An EMI issues electronic money, may also provide payment services and may not take deposits (art. 6 EMD2). Its initial capital is EUR 350,000 (art. 4), its own funds for issuance at least 2% of average outstanding e-money (art. 5(3)), and it safeguards the funds received in exchange for e-money.
What does the BNR application file contain?
At least what art. 5 PSD2 names: a programme of operations, a business plan with a forecast budget for the first 3 financial years, evidence of the initial capital, safeguarding, governance, incident, continuity and security policies with a risk assessment, and the directors and qualifying shareholders. The BNR's own list is confirmed with the partner lawyer.
Who must the directors and shareholders be, and what does the BNR check about them?
The file names the directors, with evidence of good repute and appropriate knowledge and experience (art. 5(1)(n) PSD2), and the qualifying shareholders, with evidence of their suitability (art. 5(1)(m)); the licence follows only a favourable overall assessment (art. 11(2)). A name-only director cannot meet that evidence, and RomaniaRegist supplies no administrator or shareholder.
Can a Romanian licence be used in other EU countries?
Yes, as an EU passport: an authorisation is valid in all member states (art. 11(9) PSD2), and a first cross-border activity is notified through the home authority, here the BNR. The same works in reverse: EU payment institutions that notified services in Romania appear on BNR list VII, EU EMIs on list VIII.
Is a licence from another EU country enough to serve Romanian customers?
A passport can allow it, and the BNR keeps a list of EU payment institutions that notified services in Romania (list VII). A Romanian licence is needed where the head office and part of the payment business are in Romania (art. 11(3) PSD2). Which route applies to a model is a question for the partner lawyer.
What changed for payment institutions and EMIs in 2026?
OUG 5/2026, published on 5 March 2026, amended, among other things, art. 38 Law 209/2019: funds not paid out by the end of the next business day go into a separate account at a credit institution or, where the BNR opens such accounts, at the BNR, or are invested in safe, liquid, low-risk assets. EMIs follow art. 38 too.
Do I need a separate MiCA licence to issue a stablecoin, or does an EMI licence cover it?
An e-money token may be offered to the public only by its issuer, authorised as a credit institution or an EMI and after notifying a white paper; others need the issuer's written consent (art. 48(1) MiCA). Other crypto-asset services follow the MiCA route on our crypto licence page; whether a token is an e-money token is for the partner lawyer.
What does a payment or e-money licence cost?
Pricing for our work is on request. The initial capital is not a fee: it is the institution's own money, from EUR 20,000 for money remittance only to EUR 350,000 for an EMI, at EU minimum level (art. 7 PSD2, art. 4 EMD2). BNR and Trade Register charges are confirmed with the file.
Ready to line up your licence application?
Send us the services you plan and who owns the company; we return a plan for the company, the address and the file.
Call +40 21 312 3456 or write to info@company-registration-in-romania.com, Monday to Friday, 09:00 to 18:00, Bucharest time.