How to Get an Electronic Money Issuer (EMI) License in the Philippines

An electronic money issuer (EMI) license in the Philippines is granted by the Bangko Sentral ng Pilipinas (BSP) through the Monetary Board. There is no single application window: an entity that wants to issue e-money must first be a BSP-supervised financial institution (BSFI) — a bank or a non-bank financial institution such as a quasi-bank, non-stock savings and loan association, or cooperative — and then secure the appropriate authority before issuing any e-money. Engaging in EMI operations without prior BSP approval exposes the owners and operators to enforcement action and sanctions. The path below follows BSP Circular No. 1166 and the National Payment Systems Act.

Who needs an EMI license

Under BSP Circular No. 1166, the rules on the issuance and operations of e-money cover BSP-supervised financial institutions that issue e-money and engage in e-money business in the Philippines. E-money issued under closed-loop electronic wallet systems — where the wallet is accepted as payment only by the merchant-issuer, with its subsidiaries and affiliates treated as one entity — is not covered.

An open-loop electronic wallet system, where the wallet is accepted by persons or entities other than the merchant-issuer, falls within the regulated space. So does any arrangement that results in another person or entity conducting, or appearing to conduct, regulated e-money activities without the requisite BSP authority, as BSP Memorandum No. M-2026-030 reminds supervised institutions.

The application path, step by step

1. Determine your entity type. EMIs are classified as EMI-Banks or EMI-Non-Bank Financial Institutions (EMI-NBFI), which includes cooperatives. Banks may offer e-money services subject to prior BSP approval under an Electronic Payment and Financial Services (EPFS) license and compliance with the prudential criteria and licensing requirements for EPFS.

2. Apply for a Certificate of Authority if you are an EMI-NBFI. A BSFI planning to be an EMI-NBFI applies in accordance with the guidelines on outsourcing and electronic services and operations. The procedures for applying for an EMI license, and the licensing requirements, are specified in the BSP Citizen's Charter.

3. Meet the capital requirement. The required capital for an EMI-Bank is the higher of the minimum capitalization for banks depending on bank category, or the EMI category minimum: PHP 200,000,000 for a large-scale EMI-Bank and PHP 100,000,000 for a small-scale EMI-Bank. The same amounts apply to EMI-NBFIs. Cooperatives must maintain the higher of the EMI-NBFI minimum and the capital required under the Philippine Cooperative Code of 2008.

4. Prepare the governance and systems requirements before issuing. Prior to issuance of e-money, the institution must have sound management, administrative and accounting procedures and adequate internal controls; properly designed and independently tested computer systems; security policies; robust due diligence in accrediting e-money agents and merchant partners; a fraud risk management system; a business continuity and disaster recovery plan; and an effective audit function.

5. Register with the AMLC. In line with the BSP's authority to check compliance with the Anti-Money Laundering Act and the Terrorism Financing Prevention and Suppression Act, BSFIs must also secure a Certificate of Registration with the Anti-Money Laundering Council under the AMLC Registration and Reporting Guidelines.

Capital, liquidity, and scale classification

An EMI is classified as large scale if the twelve-month average value of aggregated inflow and outflow transactions is equal to or greater than PHP 25 billion. Review of aggregated transactions is done twelve months after commencement of EMI operations, with quarterly assessment thereafter by the appropriate BSP supervising department. Once classified as large scale, an EMI will not be reclassified as small scale unless approved by the BSP, and it is expected to comply with the PHP 200 million capital requirement within one year from reclassification.

On liquidity, institutions must hold liquid assets at least equal to the amount of outstanding e-money issued for each currency in which the obligations are denominated. Those with an outstanding e-money balance of at least PHP 100,000,000 must hold at least 50 percent of that balance in trust for e-money balance liquidation, with the remainder in eligible liquid assets such as earmarked bank deposits, government securities, or a BSP settlement account. Liquid assets maintained for this purpose must remain unencumbered and are not subject to attachment.

What happens after the license is granted

The authority to engage in e-money business is revoked if operations do not commence within six months after receipt of the notice of approval of the EMI license, unless a longer period is approved by the BSP. An EMI license also becomes revocable if the institution has been inactive for more than six months after commencement of operations.

License holders must maintain transaction and due diligence records for at least five years, submit the required reports to the supervising department, and report all changes and enhancements to the e-money platform. E-money must be issued and redeemed at face value, cannot earn interest, and is not considered a deposit. Large value pay-outs of more than PHP 500,000 in a single transaction require enhanced due diligence and must be done through banks by check or electronic fund transfer.

Frequently asked questions

Can a startup apply for an EMI license in the Philippines? The rules are addressed to BSP-supervised financial institutions. A new venture generally needs to be organized as, or affiliated with, a bank or an NBFI such as a quasi-bank, non-stock savings and loan association, or cooperative, and then obtain the appropriate BSP authority.

How much capital is required for an EMI license? For both EMI-Banks and EMI-NBFIs, the required capital is PHP 200,000,000 for large scale and PHP 100,000,000 for small scale, or the applicable minimum capitalization for the entity type, whichever is higher.

What happens if e-money is issued without BSP approval? Any entity or person found engaging in EMI operations without prior BSP approval is subject to enforcement action, without prejudice to legal action against the owners and operators under the New Central Bank Act.

Practical takeaways

• EMI authority comes from the BSP through the Monetary Board; no entity may issue e-money without prior approval.
• Closed-loop wallets are outside the scope of the e-money rules; open-loop arrangements are covered.
• Capital thresholds are PHP 200,000,000 (large scale) and PHP 100,000,000 (small scale) for both EMI-Banks and EMI-NBFIs.
• Governance, systems, liquidity, and AMLC registration requirements must be satisfied before issuance begins.
• The license can be revoked for failure to commence operations within six months or for prolonged inactivity.

Primary sources

The rules discussed above are drawn from the following primary sources. Where the firm's library holds the document as a PDF it is embedded here in full; the rest are cited by title.

Amendments to the Regulations on Electronic Money (E-money) and the operations of Electronic Money lssuers (EMl) in the Philippines (Reuploaded with Appendices)Open in Law LibraryDownload PDF

Arrangements Involving Regulated Electronic Money ActivitiesOpen in Law LibraryDownload PDF

• REPUBLIC ACT NO. 11127 - AN ACT PROVIDING FOR THE REGULATION AND SUPERVISION OF PAYMENT SYSTEMS

This article is general information and not legal advice. For your specific situation, consult a lawyer or ask ASG Legal AI.