payment institution licence
Payment Institution and E-Money Licence in Romania
The Romanian company the BNR can authorise, its capital tier set out and the corporate part of the file assembled. The BNR decides.
- Payment institution applicant: a Romanian company with its real seat in Romania
- Initial capital: lei equivalent of EUR 20,000 to EUR 125,000, by service
- BNR decision: 3 months from a complete file, the statute's term
The company is formed first; the authorisation follows, decided by the BNR.
A Romanian vehicle the BNR can authorise
From our Bucharest office we handle the administrative work around a BNR authorisation, for payment, e-money and account-information businesses. A payment institution licence in Romania goes only to a company formed under Law 31/1990, with its real seat in Romania and part of its payment services here (Law 209/2019 art. 9(2)). The company comes first.
The question is which regime, which vehicle, and what the structure must carry: the capital tier, own funds, BNR-approved managers, the payment account, safeguarding. An EMI licence in Romania is often weighed against what the ASF asks of a crypto-asset service provider under MiCA. The route is chosen by you and your Romanian lawyer.
What's included
Administrative work around the authorisation. The BNR authorises; legal work goes through a Romanian lawyer.
The route schedule
Your planned activity set against the eight payment services of art. 7(1) Law 209/2019 and the five routes. The perimeter opinion comes from your Romanian lawyer.
The Romanian company
An SA company in Romania or an SRL (how an SRL with a sole member is formed and run), on standard forms the founders sign, filed at ONRC and its ANAF registration forms filed under their power of attorney.
The capital stack, set out
500 lei for a new SRL or 90,000 lei for an SA, against the tier's initial capital and the own funds kept afterwards. Funding is your decision with your adviser.
Payment account and safeguarding
Coordination with the bank for the company's own account, due within 60 working days of formation, and for the arrangement that holds client funds.
The corporate and identity file
Articles, register extracts, the ownership chain to the qualifying holders, and the managers' and holders' identity, repute and experience documents: collected, translated, assembled.
Coordination of the rest
The programme of operations, business plan, security, AML and continuity policies are written by you with your lawyer and compliance specialists. Insurance is placed with an insurer. We keep the file together.
Tracking the BNR's clock, then the hand-over
The statutory clock tracked and the answers to the BNR's questions coordinated with your lawyer; documents the company signed may be filed by us, never as its representative before the BNR; the documents for agent and branch notifications prepared for the authorised company to file; a list of ongoing duties for your compliance officer and accountant, including AML reporting under Law 129/2019.
Where the service stops
We hold, sell or transfer no authorisation, never apply in our own name, and are not a payment institution. No perimeter opinion, bespoke drafting, tax advice, tax returns, books, managers or shareholders, and no promised outcome or timeline.
Five routes into Romanian payments
The conditions of each route as the statute sets them; which one your model falls under is your lawyer's opinion.
Five routes into Romanian payments in 2026, from Law 209/2019 as published in MO I 913/2019, Directive 2009/110/EC and Directive (EU) 2015/2366.
| Route | Who decides and how | What sets it apart | Source |
|---|---|---|---|
| Payment institution (instituție de plată) | BNR authorisation, held before activity starts | Initial capital by service tier: the lei equivalent of EUR 20,000, EUR 50,000 or EUR 125,000; a Romanian company with its real seat in Romania | Law 209/2019 art. 9, 18; BNR registers |
| E-money institution, EMI (instituție emitentă de monedă electronică) | BNR authorisation under art. 7 Law 210/2019 | Issues e-money and may provide payment services; takes no deposits and issues no e-money through agents; EU floor of initial capital not less than EUR 350,000 | EMD2 art. 3(5), 4, 6(2) |
| Account information service provider, AISP | BNR registration, not authorisation, under the art. 25-26 procedure | No art. 18 capital tier; professional indemnity insurance or a comparable guarantee | Law 209/2019 art. 19, 96-102 |
| Excluded service | No authorisation; a limited network files nothing below EUR 1 million in 12 months and asks for the BNR's opinion above it, decided within 30 days | Phone-bill payments stay within EUR 50 per transaction and EUR 300 a month per subscriber, with a filing every 12 months and an auditor's opinion; excluded entities are not supervised by the BNR | Law 209/2019 art. 4(1)(k), (m), 106(1), 107(2), 108(1), 110(2) |
| Authorisation in another member state, passport into Romania | The home authority notifies the BNR, which gives its view within one month | An EU authorisation is valid in all member states; the institution must ensure Romanian AML compliance for services given through its agents and distributors, binding them by contract, and reporting sits with the single contact point it sets up in Romania | Law 209/2019 art. 58(1); PSD2 art. 11(9); Law 129/2019 art. 5, 8 |
How the authorisation works
For a payment institution authorised in Romania, with who acts and the term a statute sets.
law a term set by statute none no official time is published
- I
Map the model, choose the route
You and your Romanian lawyer
- no official time published
- II
Form or adapt the Romanian company
Founders, then ONRC
- company formed first
- registrar: one working day, the statute's term (art. 105(1) Law 265/2022, 2022 text)
- III
Payment account and safeguarding
You and the bank
- account within 60 working days of formation
- IV
Pay in the initial capital
You
- capital at the tier, lei equivalent (art. 18)
- no official time published
- V
Prepare the file
You and your lawyer; us for the corporate part
- no official time published
- VI
File with the BNR
The applicant company
- no official time published
- VII
The BNR's assessment
BNR
- decision: 3 months from a complete file (art. 26(1))
- questions within 20 working days
- answers within 30 working days, clock paused
- VIII
Decision, register, start
BNR
- effective on register entry (art. 26(8))
- start within 12 months, or the BNR may withdraw (art. 28(1)(a))
No total duration is promised. Articles are of Law 209/2019 unless stated.
Map the model and choose the route
You and your Romanian lawyer decide; we prepare the schedule against the eight payment services. No official time is published.
Form or adapt the Romanian company
An SRL or SA with its real seat in Romania, filed at ONRC under the founders' power of attorney (Law 31/1990 art. 36(1)). Registrar: one working day, the statute's term (Law 265/2022 art. 105(1), 2022 text), never a promise. A company from our ready-made companies overview is adapted instead; the BNR assesses its holders too.
Open the payment account, arrange safeguarding
You and the bank, with our coordination: the payment account every Romanian company must hold opens within 60 working days of formation, a duty since 1 January 2026 (Law 239/2025).
Pay in the initial capital
You pay in the capital of the tier your services fall in, as the lei equivalent set by Law 209/2019 art. 18. No official time is published.
Prepare the file
You write the programme of operations, business plan and policies with your lawyer and compliance specialists; we compile the corporate and identity documents and translations. ANPC review of consumer documents is optional.
File with the BNR
The applicant company files; we may submit the documents it signed, but never represent it before the BNR. The BNR's filing channel and file language are not set out in the texts we read; we confirm them against the BNR's current instructions and tell you before filing.
The BNR's assessment
A decision within 3 months of a complete file (art. 26(1)); the BNR may ask questions within 20 working days, answers within 30 working days with the clock suspended; managers approved before they act.
Decision, register, start
The authorisation takes effect on entry in the BNR register (art. 26(8); the register is kept under art. 68(1)); a refusal is reasoned. The BNR may withdraw the authorisation if activity has not started within 12 months of the grant (art. 28(1)(a)).
An AISP follows steps 1, 2 and 5 to 8, with insurance instead of initial capital; an excluded service needs no authorisation; a passported institution is authorised at home and notified to the BNR.
Not sure which route your payment model falls under?
The plan sets your model against the eight services and five routes, as the brief for your lawyer. No route chosen for you, no licence promised.
Documents you will need
BNR regulations issued under Law 209/2019 set the application file; EUR-Lex lists BNR Regulations 4/2019 and 5/2019 among Romania's transposition measures on EUR-Lex. We work from the BNR's current rules with you.
- Passport of each founder, qualifying holder and proposed manager.
- Evidence of each manager's and holder's good repute, knowledge and experience.
- The ownership chain to the qualifying holders, with each holding's size.
- A corporate holder's registration documents, with a Romanian translation.
- A power of attorney for the ONRC filings.
- The registered-office arrangement: the company's real seat in Romania.
- The planned services and markets, for the route and the tier.
- The initial capital at the tier, in lei equivalent.
- Programme of operations, business plan, safeguarding, governance, security, continuity and AML documents.
- Professional indemnity insurance or a comparable guarantee, for initiation or account information.
Romanian requirements in 2026
Law 209/2019 as published in MO I 913/2019 (listed among Romania's measures on EUR-Lex), with the safeguarding change of OUG 5/2026 and the payment-account rule of Law 239/2025.
Romanian requirements for a payment institution in 2026, from Law 209/2019 as published in MO I 913/2019 and the acts named in each row. Our fee is on request.
| Rule | What the statute says | Act and article |
|---|---|---|
| Who can apply | A Romanian legal person formed under Law 31/1990, with its real seat in Romania and part of its payment services there; a foreign company cannot apply directly | Law 209/2019 art. 9(2) |
| Initial capital | Lei equivalent of EUR 20,000 (money remittance only), EUR 50,000 (payment initiation only) or EUR 125,000 (any of services a) to e)); a mix takes the highest tier; the law sets a floor | Law 209/2019 art. 18 |
| Own funds | Never below the initial capital or the amount under Method A, B or C, whichever is higher, except an institution that offers only payment initiation or account information, for which the methods do not apply; adjustable by up to 20% either way | PSD2 art. 8-9; Law 209/2019 art. 34(1) |
| Company-law capital, not a substitute | 500 lei for a new SRL; 90,000 lei for an SA | Law 239/2025 art. VI(2); Law 31/1990 art. 10(1) |
| People and cover | Managers approved by the BNR before they act; qualifying holders suitable; professional indemnity insurance for payment initiation and account information | Law 209/2019 art. 13, 14, 19 |
| The BNR's clock | 3 months from a complete file; the BNR may ask questions within 20 working days; answers within 30 working days, clock suspended; up to 3 months to complete a file, extendable on request | Law 209/2019 art. 26 |
| Effect and refusal | Effective on entry in the BNR register; a refusal is reasoned, on grounds including capital, business plan, governance, managers, shareholders and security policy | Law 209/2019 art. 26, 27, 68 |
| After authorisation | May be withdrawn by the BNR if not started within 12 months, stopped for more than 6 months, or no part of the activity is in Romania; acquiring a qualifying holding, or raising one above 20%, 30% or 50% or to the point of control, needs prior notice and up to 60 working days of assessment | Law 209/2019 art. 28, 30, 33 |
| What changed in 2026 | Safeguarded funds may also be held at the BNR if it opens such accounts, and institutions may join designated payment systems; the company's own payment account within 60 working days of formation from 1 January 2026, fine 3,000 to 10,000 lei | OUG 5/2026 (MO I 172/2026); Law 70/2015 art. 1, 12, inserted by Law 239/2025 |
| State costs and sanctions | No BNR fee appears in Law 209/2019 as published; BNR fines of 5,000 to 50,000 lei on the institution; payment services without authorisation are a crime, 6 months to 3 years' imprisonment or a fine; the protected names may not be used by others | Law 209/2019 art. 7(3), 8, 77, 235 |
Company-law capital
- 500 lei for a new SRL
- 90,000 lei for an SA
Law 239/2025 art. VI(2); Law 31/1990 art. 10(1)
Initial capital at authorisation
- Lei equivalent of EUR 20,000: money remittance only
- Lei equivalent of EUR 50,000: payment initiation only
- Lei equivalent of EUR 125,000: any of services a) to e)
- E-money institution: EU floor not less than EUR 350,000
Law 209/2019 art. 18; EMD2 art. 4
Own funds after authorisation
- The higher of the initial capital and the amount under Method A, B or C
- The methods do not apply to payment initiation or account information alone
PSD2 art. 8-9; Law 209/2019 art. 34(1)
Three different numbers, never converted into one currency and never summed. The tier is a floor set by the law.
Problems we solve
What goes wrong before a BNR filing, and the text that decides it.
"Which licence do we need?"
The five routes set side by side with their conditions: tier capital, EMI, AISP registration, exclusion thresholds, passport in. We prepare the schedule; your lawyer gives the opinion.
Three capital numbers confused
Company-law capital (500 lei SRL, 90,000 lei SA), the tier's initial capital and the own funds kept afterwards are set out separately before the company is formed.
A foreign company that wants to apply
The BNR authorises only a Romanian company with its real seat in Romania. The other route is authorisation in another member state and a passport in, with the institution ensuring Romanian AML compliance through its agents.
"A licensed company for sale"
The authorisation stays with the company. Acquiring a qualifying holding, or raising one above 20%, 30% or 50% or to the point of control, needs prior notice and up to 60 working days of BNR assessment. No licensed company is offered here.
Account data, gift cards, phone billing
Account information alone is a BNR registration. A limited network asks for the BNR's opinion above EUR 1 million in 12 months; phone-bill payments have per-transaction and monthly limits.
Already authorised in another EU country?
Passport in through your home authority's notification to the BNR, or a Romanian company and its own authorisation: the plan sets out both.
Who prepares your licence file
Licensing and founder immigration lead, Bucharest. Romanian, English, Italian.
The BNR authorises; we are not a payment institution. Forming companies is AML-regulated work in Romania (Law 129/2019 art. 2(l)).
From our practice
We form the company and file at ONRC under a power of attorney, collect and translate the holders' and managers' documents, track the BNR's clock and keep your lawyer, bank and insurer in step.
Frequently asked questions
Can a company formed outside Romania apply to the BNR directly?
No. The BNR authorises only a Romanian legal person formed under Law 31/1990, with its real seat in Romania and part of its payment services there (Law 209/2019 art. 9(2)). A company formed abroad reaches Romanian clients another way: authorisation in its own member state and a passport into Romania.
Is the 500 lei SRL capital enough for a payment institution?
No. 500 lei is the company-law minimum for a newly formed SRL (Law 239/2025 art. VI(2)), and an SA needs 90,000 lei. The initial capital of the payment-institution tier is a separate, much higher amount, and, unless the institution offers only payment initiation, own funds must stay at or above it after authorisation.
How much initial capital does a payment institution need in Romania in 2026?
Under Law 209/2019 art. 18, the lei equivalent of EUR 20,000 for money remittance only, EUR 50,000 for payment initiation only, and EUR 125,000 for any of services a) to e). A mix of services takes the highest tier. Own funds are calculated separately. Our fee is on request.
How long does the BNR take to decide, and what stops the clock?
The BNR decides within 3 months of a complete application (art. 26(1)). It may ask questions within 20 working days, answered within 30 working days, with the clock suspended; an incomplete file can be completed within up to 3 months. The authorisation takes effect only on entry in the BNR register.
What does the BNR charge for the authorisation?
No authorisation fee appears in Law 209/2019 as published, so no BNR fee is given here. The amounts the law does set are the initial-capital tiers the company must hold and the fines for breaches, 5,000 to 50,000 lei on the institution (art. 77). Our own fee is quoted on request.
Can we buy a company that already holds a payment or e-money licence?
The authorisation stays with the company. Acquiring a qualifying holding, or raising one above 20%, 30% or 50% or to control, needs prior notice to the BNR and its assessment within 60 working days at most; disposals are notified too. An unused authorisation may be withdrawn after 12 months. We offer no licensed companies.
Can we start operating while the application is pending?
No. A payment institution must hold its authorisation before it starts. Providing payment services without the right status is a crime under Law 209/2019 art. 235(1), punished by 6 months to 3 years' imprisonment or a fine, and the protected name of a payment institution may not be used by anyone else.
Does a payment institution have to keep managers or staff in Romania?
The law requires a real seat in Romania and part of the payment services there, and the BNR may withdraw an authorisation if no part of the activity is carried on in Romania. Managers need the BNR's approval before they act. The texts we read set no further local-staff rule.
What is an EMI licence, and how does it differ from a payment institution?
An e-money institution is authorised by the BNR under art. 7 of Law 210/2019 to issue electronic money, and it may also provide payment services. It takes no deposits and issues no e-money through agents. EU law sets its initial capital at not less than EUR 350,000; a payment institution does not issue e-money.
We only aggregate account data: do we need a full licence?
No full authorisation. A provider of account information services only is registered by the BNR rather than authorised, under the same procedure and deadlines. It needs professional indemnity insurance or a comparable guarantee, and Law 209/2019 sets no initial-capital tier for it. Which route your model takes is your lawyer's opinion.
Do gift cards, closed-loop wallets or phone-bill payments need a licence?
They may fall under an exclusion. A limited network files nothing below EUR 1 million in 12 months and asks for the BNR's opinion above it, decided within 30 days. Phone-bill payments must stay within EUR 50 per transaction and EUR 300 a month per subscriber, with a filing every 12 months and an auditor's opinion.
Can a Romanian payment institution serve clients in other EU countries?
Yes, by passport. The request goes to the BNR, which forwards it to the host authority within one month and decides within 3 months of receiving it, taking that authority's opinion into account. Direct services can start from the BNR's notification; branches and agents only after their entry in the BNR register (Law 209/2019 art. 61-62).
Can an EU-licensed payment institution work in Romania without a Romanian licence?
Yes. An EU authorisation is valid in all member states: the institution works in Romania on the notification its home authority sends to the BNR, which gives its view within one month. The institution must ensure Romanian anti-money-laundering compliance through its agents and distributors, and reporting sits with the single contact point it sets up in Romania.
What are the requirements for a payment institution licence in Romania?
A Romanian company with its real seat in Romania, initial capital at its services' tier, own funds at or above it where the methods apply, BNR-approved managers, suitable qualifying holders, insurance for payment initiation or account information, and a complete file. Like every legal person, the company must also hold its own payment account in Romania (Law 70/2015).
Where can we check whether a payment or e-money institution is authorised?
In the BNR's public online registers of payment institutions and e-money institutions, where account information providers sit in a distinct section, and in its lists of EU institutions that notified services in Romania. The registers are kept up to date and are also published in machine-readable JSON.
Request your licence file plan
The plan covers the route schedule for your lawyer, the vehicle, the capital stack, the corporate file, the payment account and the BNR's clock. We reply Monday to Friday, 09:00 to 18:00 Bucharest time.