EMD2 compliance for standalone fintech.
E-Money Directive (Directive 2009/110/EC, amended by PSD2). Enforced from 2011-04-30 (currently under review for EMD3 / PSR alignment). Supervised by EBA + national competent authorities. Coreal generates the evidence pack automatically on every Minctrl build — see /security-compliance for the full posture.
What this regulation covers.
Authorisation of Electronic Money Institutions (EMIs), e-money issuance, redemption and safeguarding.
For a standalone fintech, the salient angles are: EMI / PI / MiFID-II licence acquisition timelines (6–15 months); Sponsor-bank dependency for IBAN issuance; Customer-acquisition unit economics vs CAC payback. Primary licence: EMI or PI (most common); MiFID-II for neobrokers.
- Art. 5 — Initial capital (€350,000)
- Art. 7 — Own-funds requirements (Method D)
- Art. 8 — Safeguarding requirements
- Art. 11 — Redemption obligation
What lands in the regulator file.
All items journaled, replayable, 7-year retention.
Which EMD2 articles apply to a fintech?
Primarily: Art. 5 — Initial capital (€350,000); Art. 7 — Own-funds requirements (Method D); Art. 8 — Safeguarding requirements. The full mapping is in the Coreal compliance posture document — see /security-compliance.
What evidence does Coreal generate per audit?
EMI authorisation file; Safeguarding model (segregated account or insurance); Own-funds calculation (Method D). The Minctrl pipeline produces this artefact set automatically on every build — see /company §05 'How we ship'.
What are the penalties for non-compliance?
Member-state specific; FCA and BaFin have both withdrawn EMI authorisations for safeguarding breaches.
Bring the perimeter,
leave with a brief.
Read the Wave-1 runbook first.
The full 90-day launch sequence — phases, partner-bank gates, who signs off when. No form to read it.
Read the runbook →INDICATIVE DATA · Numbers and timelines reflect public regulator filings, vendor documentation and our own delivery experience. Per-engagement values vary with operator profile, BSS vintage and regulatory perimeter. Engage early for a fitted estimate under NDA.