Austria · Licensing

Payment Institution and E-Money Licence
in Austria

We prepare Austrian payment institution and e-money institution applications for the FMA, and the Austrian company that has to exist before one can be filed.

Initial capital EUR 20,000, EUR 50,000 or EUR 125,000 by payment service (ZaDiG 2018 § 16 Abs. 1)
EUR 350,000 for an e-money institution (E-Geldgesetz 2010 § 11 Abs. 1)
Decision or refusal within three months of a complete application (§ 9 Abs. 4)
Seat, head administration and one resident managing director in Austria (§ 10 Abs. 1)

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A payment terminal in use at a Vienna counter on a working weekday.

What we do on an Austrian payment or e-money authorisation, and what we do not

Two authorisations sit behind almost every payments business in Austria. A payment institution is authorised under the Zahlungsdienstegesetz 2018 to provide one or more of the eight payment services that act lists. An e-money institution is authorised under the E-Geldgesetz 2010 to issue electronic money, and may provide payment services alongside it. Both are granted by the FMA and both need an Austrian company.

We map the intended activity onto the statutory list, establish which route applies, form or supply the Austrian entity, assemble the § 9 application file, evidence the initial capital and the safeguarding arrangement, and handle the authority's requests for further information.

Four things we do not do, and each is here because the question is asked:

We do not grant or guarantee an authorisation. Only the FMA decides, and it can refuse.
We do not promise a decision date. The statute fixes one period and we quote nothing beyond it.
We do not sell a lighter Austrian licence, because Austrian law does not contain one.
We do not supply nominal directors to satisfy the residence condition in § 10 Abs. 1 Z 13.

Which of the eight payment services you intend to provide

ZaDiG 2018 § 1 Abs. 2 lists eight payment services. Which of them you intend to provide decides the capital, the own-funds method and whether you need an authorisation at all.

Z	Payment service	Route	Initial capital
1	Placing cash on a payment account, and the operations needed to run the account	authorisation	EUR 125,000
2	Withdrawing cash from a payment account, and the operations needed to run the account	authorisation	EUR 125,000
3	Executing payment transactions: direct debits, card payments, credit transfers and standing orders	authorisation	EUR 125,000
4	The same transactions where the funds are covered by a credit line	authorisation	EUR 125,000
5	Issuing payment instruments, or acquiring payment transactions	authorisation	EUR 125,000
6	Money remittance without a payment account in either name	authorisation	EUR 20,000 if this alone
7	Payment initiation services	authorisation	EUR 50,000 if this alone
8	Account information services	register entry, § 15	none; indemnity cover instead

Neighbouring authorisations are not this page. Crypto-asset services are covered in the crypto licence guide, and investment services and banking in what an Austrian investment firm licence requires. One boundary is worth naming precisely, because it catches a real business model: an Austrian e-money institution that wants to issue an e-money token needs a second authorisation, under Art. 48 of Regulation (EU) 2023/1114, and the FMA prices it at its own tariff post. Token issuance has its own page.

The eight services are § 1 Abs. 2 ZaDiG 2018; the authorisation requirement for Z 1 to Z 7 is § 7 Abs. 1; the capital tiers are § 16 Abs. 1. The reduced EUR 20,000 and EUR 50,000 tiers apply only where the institution carries on that service and nothing else. An account information service provider is entered in the register under § 15 and must produce professional indemnity insurance or an equivalent guarantee.

What the authorisation work includes

The Austrian entity.

A Kapitalgesellschaft or a cooperative, seat and head administration in Austria, part of the services provided there (§ 10 Abs. 1 Z 1 and Z 2). Usually a GmbH at EUR 10,000 (§ 6 Abs. 1 GmbHG).

The route.

Issuing stored value that other people accept is e-money (E-Geldgesetz § 1 Abs. 1), and that one fact moves the capital floor from EUR 125,000 to EUR 350,000.

The service perimeter.

The authorisation names the services it covers and may exclude parts of them (§ 10 Abs. 3). Too wide raises the tier; too narrow needs an extension, which is a fresh fee.

The § 9 file.

Seventeen heads of information, from the business model and a three-year budget to the ICT arrangements under Regulation (EU) 2022/2554.

The initial capital.

Common equity tier 1 under Regulation (EU) No 575/2013, at the managing directors' unrestricted and unencumbered free disposal in Austria (§ 10 Abs. 1 Z 7 with § 9 Abs. 1 Z 3).

The safeguarding arrangement.

Variante A, segregation, or Variante B, an outside insurance policy (§ 18 Abs. 1). The FMA has to find it satisfactory (§ 10 Abs. 1 Z 8).

The management body.

Fitness, propriety, no GewO § 13 exclusion ground, and the three conditions in § 10 Abs. 1 Z 13 to Z 15: residence, German, no other main occupation outside payments, e-money or banking.

The filing.

The FMA hears the Oesterreichische Nationalbank before granting (§ 10 Abs. 2) and may consult the home supervisor of a qualifying holder.

A payment institution is not a bank

This is the most common misunderstanding a foreign founder arrives with, and the statute is blunt about it. Money a payment institution receives for the execution of payment transactions, and balances on the payment accounts it keeps, are not deposits within § 1 Abs. 1 Z 1 BWG and may not bear interest (§ 7 Abs. 4). Taking deposits commercially is barred outright (§ 7 Abs. 5), and doing it anyway is a ground for withdrawing the authorisation (§ 11 Abs. 2 Z 4). E-Geldgesetz § 3 Abs. 4 and Abs. 5 say the same, and § 20 forbids interest on held e-money in one sentence.

What protects the client is safeguarding, not deposit guarantee. Under § 18 Abs. 1 Variante A the funds are never mixed with anyone else's, move to a separate trust account or into secure low-risk liquid assets by the end of the business day after receipt, and stay attributable to each user by amount; the closing sentence gives that user a right to object in execution under § 37 EO and to separate in insolvency under § 44 IO. Variante B replaces the segregation with an insurance policy or comparable guarantee from outside the group. E-Geldgesetz § 12 applies the same regime to e-money, with a five business day outer limit for funds taken by payment instrument.

How an application runs, from the Austrian company to the decision

Form the Austrian company, or take over a ready-made one.

Normally a GmbH at EUR 10,000, Firmenbuch court fees EUR 47 plus EUR 475, so EUR 522 from 1 August 2026 (Gerichtsgebührengesetz Tarifpost 10 Z I, BGBl. II Nr. 227/2026). See buy a company in austria where the register entry is wanted sooner.

Settle the services and the route.

Map the intended activity onto § 1 Abs. 2 and read off the capital tier. Everything downstream follows from this step and nothing downstream repairs it cheaply.

Put the substance in place.

Seat and head administration in Austria, part of the services provided there, and a management body satisfying § 10 Abs. 1 Z 9 to Z 15, including the resident and the German-speaking director.

Raise and evidence the initial capital.

Common equity tier 1, unrestricted and unencumbered, at the managing directors' free disposal in Austria.

Build the § 9 file, and only then submit it.

Seventeen heads of information, plus the § 9 Abs. 2 description of the applicant's testing and organisational arrangements and the § 9 Abs. 3 statement on digital operational resilience.

Answer the authority's questions.

The FMA hears the Oesterreichische Nationalbank before granting and may consult supervisors in other member states about a qualifying holder or a director.

The decision.

Within three months of receipt, or of the transmission of everything the decision needs where the application was incomplete, the FMA must grant the authorisation or refuse it by written decision (§ 9 Abs. 4). The register entry is made at the same time as the grant.

Austria · payment and e-money authorisation

From the Austrian company to the decision, and where the clock starts

01 /
The Austrian company
Normally a GmbH at EUR 10,000 share capital, then the Firmenbuch entry.
GmbHG § 6 Abs. 1
02 /
The route
Payment institution, or e-money institution. Map the intended activity onto § 1 Abs. 2 and read off the capital tier. Nothing downstream repairs this step cheaply.
ZaDiG 2018 § 1 Abs. 2
03 /
The substance
Seat and head administration in Austria, part of the services provided there, and a management body satisfying § 10 Abs. 1 Z 9 to Z 15, including the resident and the German-speaking director.
ZaDiG 2018 § 10 Abs. 1
04 /
The file
Seventeen heads of information, plus the § 9 Abs. 2 description of testing and organisational arrangements and the § 9 Abs. 3 statement on digital operational resilience.
ZaDiG 2018 § 9 Abs. 1 to 3

Stage 05 · the § 9 Abs. 4 clock, three months

Case 1 · the file is complete on receipt

Three months from receipt → grant or written refusal

The register entry is made at the same time as the grant.

Case 2 · the file is incomplete

Clock not runningThree months, restarted

The three months run from the transmission of everything the decision needs. An incomplete file does not start the clock; it moves where the clock starts.

→ The clock starts at completeness, not at the filing

ZaDiG 2018 § 9 Abs. 4

Between the file and the decision the FMA hears the Oesterreichische Nationalbank, and may consult supervisors in other member states about a qualifying holder or a director. Every period here is a statutory limit on the authority. No duration of ours appears in this graphic.

The statutory period is short and it starts late. ZaDiG 2018 § 9 Abs. 4 runs three months from receipt or, where the application is incomplete, from the transmission of everything the decision needs. An incomplete file does not start the clock; it moves where the clock starts.

Not sure whether your model is a payment service or e-money?

Send the flows you intend to run and the group structure behind them. You get the route, the capital tier and the document list in writing.

Request a licensing scoping review · Start your onboarding

Capital you must hold, and what the state charges

Three amounts are easy to run together: the company's share capital, the regulatory initial capital and the ongoing own-funds requirement. Only the first is company law.

Route	Initial capital floor	Ongoing own funds	Provision
Payment institution, money remittance only	EUR 20,000	Method A, B or C	§ 16 Abs. 1 Z 1
Payment institution, payment initiation only	EUR 50,000	none; § 17 Abs. 1 exempts it	§ 16 Abs. 1 Z 2
Payment institution, any of Z 1 to Z 5	EUR 125,000	Method A, B or C	§ 16 Abs. 1 Z 3
Account information service only	none	none; § 17 Abs. 1 exempts it	§ 15 Abs. 2
E-money institution	EUR 350,000	Method D, and Method A, B or C on unrelated payment services, cumulatively	E-GeldG § 11 Abs. 1 and Abs. 3
The company itself, a GmbH	EUR 10,000 share capital	not a regulatory figure	GmbHG § 6 Abs. 1

What the Austrian state charges to decide the application

The authorisation fee is fixed by an Austrian regulation and payable to the FMA whatever the outcome. These are state fees. Our own fee is not published on this site.

Tarifpost	What it prices	to 31 Aug 2025	from 1 Sep 2025
I.E.1	grant of a payment institution authorisation	8,000	10,000
I.E.2	extension of that authorisation	1,750	2,190
I.E.3	non-opposition to a qualifying holding, per interested acquirer	500	625
I.E.4	change of legal form, demerger or merger	900	1,125
I.E.5	processing an account information service registration	4,000	5,000
I.E.6	approval of a change of own-funds method	500	650
I.F.1	grant of an e-money institution authorisation	9,000	11,250
I.F.2	extension of an e-money authorisation to payment services	1,750	2,190
I.F.3	non-opposition to a qualifying holding	500	625
I.F.4	change of legal form, demerger or merger	900	1,125
I.F.5	approval of a change of own-funds method	500	625
I.F.6	approval of an estimate-based own-funds calculation	500	625
III.O.7	grant of an Art. 48 MiCA authorisation to issue an e-money token		11,250

The tiers are § 16 Abs. 1 ZaDiG 2018 and § 11 Abs. 1 E-Geldgesetz 2010, both read at source on 17 September 2026. Method A is 10 percent of the previous year's fixed overheads; Methods B and C are scaled calculations on payment volume and on a relevant indicator; Method D is 2 percent of average outstanding e-money over the preceding six calendar months.

Austria · initial capital and own funds

One test takes the higher of two figures. The other adds them

Part 1 · a payment institution: the higher of

A · the statutory floor

Initial capital by service
Money remittance onlyZaDiG 2018 § 16 Abs. 1 Z 1	EUR 20,000
Payment initiation onlyZaDiG 2018 § 16 Abs. 1 Z 2	EUR 50,000
Any of § 1 Abs. 2 Z 1 to Z 5ZaDiG 2018 § 16 Abs. 1 Z 3	EUR 125,000

B · the calculated figure

Labelled, not quantified

The own-funds figure calculated under § 17: Method A, B or C. No amount is shown because it is read off your own overheads and payment volume, and no illustrative figure is invented. Method A is 10 per cent of the previous year’s fixed overheads; Methods B and C are scaled calculations on payment volume and on a relevant indicator.

Payment initiation only, and an account information service, are exempt under § 17 Abs. 1

The binding figure

The common equity tier 1 may fall below neither A nor B, whichever is higher.ZaDiG 2018 § 16 Abs. 2

Part 2 · an e-money institution: the two add

The floor
EUR 350,000
Common equity tier 1 that may not be breached at any time.E-GeldG 2010 § 11 Abs. 1
Method D, on e-money
Labelled, not quantified
At least 2 per cent of average outstanding e-money over the preceding six calendar months.E-GeldG 2010 § 11 Abs. 3 Z 2
Method A, B or C, on unrelated payment services
Labelled, not quantified
Calculated separately on payment services not linked to the issuance of e-money.E-GeldG 2010 § 11 Abs. 3

Cumulative, not alternative. The floor sits under both

ZaDiG 2018 § 16 Abs. 2 says the common equity tier 1 may fall below neither the floor nor the calculated figure, whichever is higher. E-Geldgesetz § 11 Abs. 3 goes further: for an e-money institution the two calculations are cumulative, not alternative, and the floor sits under both.

FMA-Gebührenverordnung, BGBl. II Nr. 230/2004 as last amended by BGBl. II Nr. 130/2026, Anlage 1, Tarifposten I.E, I.F and III.O.7, in the version in force from 6 June 2026. The right-hand column was set by the Part 2 recast in BGBl. II Nr. 187/2025 and has applied since 1 September 2025; the left-hand column is the superseded tariff, shown because it is still in circulation. The annual supervisory cost is separate and is not a fixed figure: § 89 ZaDiG 2018 apportions it by each institution's reported minimum own-funds requirement, with a floor of EUR 2,000 and a ceiling of 1.5 per thousand.

What the FMA asks you to file

The business model, naming each payment service and whether credit under § 7 Abs. 6 is intended.
A business plan with a budget for the first three financial years.
Proof that the initial capital is at the managing directors' free disposal in Austria.
A description of the measures safeguarding users' funds under § 18.
Governance and internal control, including administration, risk management and accounting procedures.
The arrangements for ICT services under Regulation (EU) 2022/2554, and incident handling and reporting.
Procedures for recording, monitoring, tracing and restricting access to sensitive payment data.
Business continuity, with critical operations identified and the plans tested periodically.
A security policy document with a risk assessment and the mitigating controls.
The internal control system for the FM-GwG and Regulation (EU) 2015/847.
The organisational structure, agents, branches, outsourcing and participation in a payment system.
Qualifying holders and their repute, the directors, the auditor, the legal form, the articles and the seat.

An authorisation file being assembled and reviewed before it is submitted. — Seventeen heads of information under § 9 Abs. 1, plus the § 9 Abs. 2 and Abs. 3 descriptions, are what makes this file long rather than difficult.

What applicants get wrong, and what it costs

Looking for a lighter Austrian regime.

There is not one. § 7 Abs. 1 subjects every service in § 1 Abs. 2 Z 1 to Z 7 to authorisation and names one exception, § 3 Abs. 1: central banks, public authorities and the Oesterreichische Kontrollbank. The § 15 register entry is the only lighter route and it is for account information services alone.

Reading "Kleinbetragszahlungsinstrument" as a small licence.

§ 35 and § 57 use that word for low-value payment instruments and relax information and liability duties for them. They say nothing about a lighter institution.

Treating the capital floor as the requirement.

§ 16 Abs. 2 makes the binding figure the higher of the floor and the § 17 calculation, and § 11 Abs. 3 E-Geldgesetz makes two calculations apply cumulatively on top of the EUR 350,000.

Assuming a limited network stays outside forever.

A closed-loop instrument is outside the act under § 3 Abs. 3 Z 11, but § 3 Abs. 4 requires a notification once the preceding twelve months pass EUR 1,000,000, and missing it carries up to EUR 30,000 (§ 99 Abs. 3).

Starting before the decision.

Up to EUR 50,000 for a § 1 Abs. 2 Z 1 to Z 7 service without the entitlement (§ 99 Abs. 1), up to EUR 100,000 for issuing e-money without authorisation (E-Geldgesetz § 29 Abs. 1). § 104 Abs. 1 adds that there is no claim to any remuneration, cost or charge connected with that business.

Want the route and the capital tier settled before you spend anything?

Tell us which flows you intend to run, where the clients are and who will sit on the board. You get the route, the tier and the state fee that follows from it.

Request a licensing scoping review · Start your onboarding

Related services

Crypto-asset services. The FMA also authorises crypto-asset service providers under MiCA, on a separate file with its own capital classes: the crypto licence guide.
Banking and investment services. A deposit business or an investment service is a different act and a different tier: what an Austrian investment firm licence requires.
Brand protection. A payments brand is worth registering before the authorisation is public: how to register a trademark in Austria.

How this page is kept accurate

Last updated 17 September 2026. Every figure on this page is cited to the paragraph of the act or the tariff post of the ordinance beside it, with the gazette reference and the date the version took effect. Both statutes were read at source through the Federal Chancellery's open-data service. We are not a law firm, we hold no authorisation, and we are not the FMA's agent. Only the FMA decides, and it can refuse. Our fee is quoted on request.

Frequently asked questions

How much initial capital does an Austrian payment institution licence need?

ZaDiG 2018 § 16 Abs. 1 tiers it by service: EUR 20,000 where the institution only carries on money remittance, EUR 50,000 where it only provides payment initiation services, and EUR 125,000 where it provides any of the services listed in § 1 Abs. 2 Z 1 to Z 5.

How much capital does an e-money institution need, and is EUR 350,000 the whole requirement?

E-Geldgesetz 2010 § 11 Abs. 1 sets a common equity tier 1 floor of EUR 350,000 that may not be breached at any time. It is not the whole requirement. § 11 Abs. 3 Z 2 adds own funds of at least 2 percent of average outstanding e-money, and the closing sentence makes the two tests cumulative.

Is there a small or simplified payment institution licence in Austria?

No. ZaDiG 2018 § 7 Abs. 1 makes every service in § 1 Abs. 2 Z 1 to Z 7 subject to authorisation, and the only exception on its face is § 3 Abs. 1, which covers central banks, public authorities and the Oesterreichische Kontrollbank. Account information services get a register entry under § 15, not a lighter licence.

What is an e-money institution, and what counts as e-money?

E-Geldgesetz 2010 § 1 Abs. 1 defines e-money as electronically or magnetically stored monetary value, issued on receipt of funds as a claim on the issuer, used to make payment transactions and accepted by persons other than the issuer. An e-money institution is a legal person the FMA has authorised to issue it (§ 3 Abs. 2).

How long does the FMA take to decide on an application?

ZaDiG 2018 § 9 Abs. 4 gives the FMA three months from receipt of the application or, where the application is incomplete, three months from the transmission of everything the decision needs. That is the only period either act fixes. The clock runs from completeness, not from filing, and we quote no timeline of our own.

Do I need a managing director resident in Austria?

ZaDiG 2018 § 10 Abs. 1 Z 13 requires at least one managing director to have the centre of his life interests in Austria. Z 2 separately requires the seat and the head administration to be in Austria and at least part of the services to be provided there. We supply no nominal director.

Does the application have to be in German?

Neither act says the file itself must be in German. What ZaDiG 2018 § 10 Abs. 1 Z 14 does say is that at least one managing director must have a command of German, and it makes that a condition of the grant rather than a matter of convenience. The statute fixes the person, not the language of the file.

What does the Austrian state charge for the authorisation?

The FMA-Gebührenverordnung, Anlage 1, sets EUR 10,000 to grant a payment institution authorisation (Tarifpost I.E.1), EUR 11,250 for an e-money institution (I.F.1) and EUR 5,000 to process an account information service registration (I.E.5). Those amounts have applied since 1 September 2025. Our own fee is quoted on request.

What does FMA supervision cost each year?

It is not a fixed amount. ZaDiG 2018 § 89 divides the cost of payment services supervision among the institutions in proportion to the minimum own-funds requirement each one reported for the preceding December, then applies a floor of EUR 2,000 (Abs. 4) and a ceiling of 1.5 per thousand of that figure (Abs. 6).

Is a payment institution a bank, and can it take deposits or pay interest?

No to both. ZaDiG 2018 § 7 Abs. 5 bars a payment institution from taking deposits commercially, and § 7 Abs. 4 provides that funds received for payment services are not deposits within BWG § 1 Abs. 1 Z 1 and may not bear interest. E-Geldgesetz § 20 forbids interest on held e-money outright.

What happens to client money if the institution fails?

Client funds are safeguarded, not covered by deposit guarantee. Under ZaDiG 2018 § 18 Abs. 1 they sit on a separate trust account or in secure low-risk liquid assets, identifiable to each user by amount, or are covered by an outside insurance policy. Variante A gives the user a right of separation in insolvency under IO § 44.

Do I need an authorisation for a gift card or a closed-loop wallet?

ZaDiG 2018 § 3 Abs. 3 Z 11 puts instruments usable only at the issuer's premises, within a limited network of providers, or for a very limited range of goods or services outside the act. § 3 Abs. 4 then requires a notification to the FMA once the transactions of the preceding twelve months pass EUR 1,000,000.

What happens if I provide payment services in Austria without the authorisation?

ZaDiG 2018 § 99 Abs. 1 carries a fine of up to EUR 50,000, and E-Geldgesetz § 29 Abs. 1 up to EUR 100,000 for issuing e-money. § 104 Abs. 1 adds a civil consequence: no claim to any remuneration, cost or charge connected with the business, and connected sureties and guarantees are ineffective.

Can an Austrian authorisation be used in the rest of the EEA, and how do I check that a provider is authorised?

An Austrian institution notifies the FMA before operating in another member state (ZaDiG 2018 § 28). The FMA keeps the public registers required by § 13 Abs. 2 and by E-Geldgesetz § 6 Abs. 2, and the EBA publishes the EU-wide register of payment and electronic money institutions.

Request a licensing scoping review

Send the flows, the group structure and the board you have in mind. You get the route, the capital tier, the state fee and the file list.