EMI licensing path in Ukraine.
EMI (E-Money Institution) licence in Ukraine is supervised by National Bank of Ukraine (NBU). Time-to-licence is typically 4–8 months; Ukraine licences do not benefit from EU passporting.
What this licence allows.
Issue e-money (wallets, IBANs, prepaid cards); payment services where derived from e-money issuance.
Ukraine's payment services law (1591-IX) aligned with PSD2 in 2021. No EU passporting, but NBU has explicit acceptance of EU-licensed providers for remittance corridor work.
- Corporate structure + beneficial ownership (UBO ≤ 25%)
- Initial capital deposited in a regulated EU/EEA bank
- Three-line-of-defence governance model
- AML programme + transaction monitoring policy
- Risk-based KYC + sanctions screening process
- ICT-security questionnaire (DORA-aligned from 2025)
- Outsourcing register (BSS, payment partners, cloud)
Three paths to EMI in Ukraine.
Acquire EMI directly from NBU
Time: 4–8 months. Initial capital: UAH 5M / UAH 10M (Class A/B; ~€115k / €230k). Full control, full obligations. Coreal helps with the IT-security questionnaire and three-lines-of-defence model.
Partner with a Ukraine licence-holder
Partner with an existing NBU-licensed entity. Coreal contributes the regulated tech stack; partner contributes the licence.
Use the Coreal EMI passport
Coreal operates under its own EU EMI licence. Operator gets a fully-branded wallet without acquiring any licence. Ships in ~60 days.
Who is the EMI regulator in Ukraine?
National Bank of Ukraine (NBU). They oversee authorisation, ongoing supervision and enforcement for EMI licence holders in Ukraine.
How long does EMI authorisation take in Ukraine?
Typically 4–8 months end-to-end. The bottleneck is usually the regulator's risk and IT-security questionnaire — plan for ≥4 months of regulator dialogue.
Does this licence work cross-border?
No. Ukraine licences do not benefit from EU passporting — you would need a separate authorisation in each EU member state of operation.
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.