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Small-scale Electronic Money Institution (SEMI)

Small-scale Electronic Money Institution (SEMI)

A small-scale electronic money institution is an entity that issues electronic money and provides related or unrelated payment services. Electronic money represents monetary value stored electronically, which the institution is obliged to exchange back into money at any time at the request of the holder. Under this model, money is not tied to a specific physical form but exists in virtual form, which allows it to be used for online and offline transactions.

A small-scale electronic money institution is limited in the amount of electronic money it can issue, namely EUR 5 million. A small-scale issuer may provide payment services that do not involve electronic money only if the monthly average amount of payment transactions it executes in the Czech Republic does not exceed EUR 5 million over a 12-month period.

This model is ideal for entities that focus on specific market segments and offer innovative payment solutions with lower transaction volumes.

What can we do for you?

  • We will assess your business model and evaluate it in terms of the appropriate licence (small-scale electronic money institution, electronic money institution, etc.).
  • We will discuss with you the scope of the licence you should apply for in the licensing procedure before the CNB.
  • We will prepare a detailed checklist for the licence application.
  • We will advise you on the appropriate organisational structure and internal management.
  • We will help you prepare a detailed business plan as one of the most important parts of the licence application, including financial projections.
  • We will arrange a personal meeting with the CNB to discuss the business plan before submitting the licence application.
  • We will prepare all necessary internal regulations, including AML/CFT guidelines, regulations on the issuance of electronic money, the provision of payment services, risk management and outsourcing.
  • We will assess the requirements for persons with qualifying holdings in the client and senior management, including their trustworthiness.
  • We will create the necessary client documentation.
  • We will help you prepare all other relevant documents for the licence application, including resumés, affidavits and other declarations.
  • We will assist you in obtaining a draft agreement with a bank for the management of bank accounts on which client funds will be held, or in obtaining a draft agreement with an insurance company or the necessary collateral.
  • We will ensure that the authorised representatives through whom you will provide payment services are entered in the list maintained by the CNB.
  • We will guide you through the entire licensing process.
  • Throughout the licensing procedure, we will actively communicate with the CNB and, in cooperation with you, ensure that any information and documents requested by the CNB are provided, including participation in any meetings with CNB representatives.
  • Once you obtain the licence, we will be happy to assist you in fulfilling your regular reporting obligations to the CNB, ensure compliance, assist you in the event of an inspection by the CNB, or provide you with any other legal services.

If you are interested in obtaining a small-scale electronic money institution licence, arrange an initial meeting with us, where we will discuss all the steps that need to be taken together to achieve this.

People

Jan Šovar, partner Finreg Partners

Jan Šovar

Partner

Ondřej Mikula, partner Finreg Partners

Ondřej Mikula

Partner

Petra Šimůnková, advokátka Finreg Partners

Petra Šimůnková

Associate

Denis Tichánek, advokátní koncipient Finreg Partners

Denis Tichánek

Associate

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