Spotting a Defunct or Withdrawn EMI Licence

TL;DR verification take

An active e-money institution (EMI) holds a current authorisation from a national competent authority (NCA) and appears on the European Banking Authority (EBA) EUCLID register with status "Active". A withdrawn EMI no longer holds authorisation but may retain branding or dormant websites. A defunct legal entity is dissolved or struck from the commercial register entirely. The difference matters: only active EMIs may legally issue e-money or hold customer funds. Verify status in three steps: check the EBA EUCLID register, cross-reference the NCA's national register, and confirm the entity's legal status at the relevant commercial registry.

Step 1: Check the EBA EUCLID register

The European Banking Authority (EBA) maintains EUCLID, a public register of all authorised payment institutions (PIs) and e-money institutions (EMIs) across the European Economic Area. This is the primary verification source.

1. Navigate to the EBA EUCLID register at euclid.eba.europa.eu.
2. Search by entity name, registration number, or country of authorisation.
3. Confirm the "Authorisation Status" field displays "Active".
4. Note the "Authorisation Date" and "Competent Authority" fields.
5. If the entity does not appear, it either never held authorisation or was withdrawn.

The EBA updates EUCLID within 5 working days of NCA notification. A missing entry is not conclusive - cross-reference the NCA's national register immediately.

Step 2: Verify the National Competent Authority register

Each European Union (EU) member state publishes its own authorised EMI list. The NCA register is the legal source of truth for that jurisdiction. The Bank of Lithuania (LB) had authorised 87 EMIs as of Q1 2025; the Financial Conduct Authority (FCA) in the United Kingdom maintained approximately 62 active EMI authorisations as of January 2025.

1. Identify the EMI's country of authorisation (from the company website, terms of service, or EUCLID).
2. Visit the NCA's official website for that country.
3. Search the NCA's public register by entity name or registration number.
4. Confirm the authorisation status is "Active" or equivalent.
5. Record the authorisation date and any supervisory notes or restrictions.

Common NCA registers:

| Country | Authority | Register URL pattern | |---------|-----------|----------------------| | Austria | Financial Market Authority (FMA) | fma.gv.at/en/consumers/registers | | Belgium | National Bank of Belgium (NBB) | nbb.be/en/authorisations | | France | Autorité de contrôle prudentiel et de résolution (ACPR) | acpr.banque-france.fr/en/authorisations | | Germany | Federal Financial Supervisory Authority (BaFin) | bafin.de/EN/Supervision/PaymentInstitutions | | Netherlands | Dutch Central Bank (DNB) | dnb.nl/en/authorisations | | Poland | Polish Financial Supervision Authority (PFSA) | knf.gov.pl/en/registers | | Spain | Bank of Spain (BdE) | bde.es/en/supervision/registers | | Sweden | Swedish Financial Supervisory Authority (Finansinspektionen) | fi.se/en/authorisation/registers |

If the entity appears in EUCLID but not in the NCA register, contact the NCA directly - this may indicate a data synchronisation lag or a withdrawn licence pending removal from EUCLID.

Step 3: Confirm legal entity status

A withdrawn EMI may still exist as a legal entity in the commercial register. Confirm whether the entity is active, dormant, or dissolved.

1. Visit the relevant national commercial registry or companies house website.
2. Search by entity name and registration number.
3. Record the entity's legal status ("Active", "Dormant", "Dissolved", or equivalent).
4. Note the date of the most recent filing or status change.
5. If status is "Dissolved" or "Struck Off", the entity cannot legally conduct EMI activities.

Example: A company may hold "Dormant" status in Companies House (United Kingdom) while its EMI authorisation was withdrawn by the FCA in 2022. The legal entity still exists but cannot operate as an EMI.

Understanding EMI authorisation status codes

The EBA EUCLID register and NCA registers use standardised status codes. Understanding these prevents misinterpretation.

Active: The EMI holds current authorisation and may issue e-money, accept funds, and provide payment services.

Active with restrictions: The EMI holds authorisation but operates under conditions - for example, limited to e-money issuance only, or prohibited from accepting deposits above a certain threshold. Check the "Restrictions" or "Conditions" field in the NCA register.

Withdrawn: The EMI's authorisation was formally revoked, suspended, or lapsed. The entity no longer has permission to issue e-money or hold customer funds. The withdrawal date is recorded.

Defunct or dissolved: The legal entity no longer exists or is struck from the commercial register. This is confirmed in the national companies registry, not the EMI register.

Red flags and warning signs

The entity does not appear in EUCLID or the NCA register: If an entity claims to be an authorised EMI but is absent from both registers, it is not authorised. Do not proceed.

The website claims authorisation but lists an outdated NCA: Some defunct EMIs retain old websites. Verify the current NCA from the entity's most recent regulatory filing, not the website.

The NCA register shows "Withdrawn" but the website is active: A withdrawn EMI may retain branding and social media presence. This is a red flag. Confirm the withdrawal date and do not send funds.

The entity appears in EUCLID but not in the NCA's national register: This is rare but indicates a synchronisation issue. Contact the NCA to clarify.

Authorisation date is more than 15 years old with no recent filings: Check the NCA register for supervisory notes or compliance issues. Dormant or inactive EMIs may face withdrawal.

The entity's legal status is "Dissolved" in the commercial registry: Even if the EMI register shows "Active", a dissolved legal entity cannot operate. Verify the commercial registry date against the EMI authorisation date.

Limitations

This article does not cover:

• Crypto-asset e-money issuance: Regulation (EU) 2023/1114 (Markets in Crypto-Assets Regulation - MiCAR) introduces separate authorisation pathways for crypto-asset issuers. MiCAR-regulated entities are not EMIs under the Electronic Money Directive (EMD2) and require separate verification.
• Anti-money laundering (AML) and know-your-customer (KYC) compliance: This guide verifies authorisation status only. A licensed EMI may still breach AML/CFT obligations. Consult the NCA's enforcement action register for disciplinary history.
• Deposit guarantee schemes: EMIs are not covered by deposit guarantee schemes in most jurisdictions. Verify whether customer funds are held in a segregated account or protected by insurance.
• Cross-border branch operations: An EMI authorised in one EU member state may operate branches in others under passporting rights. This complicates jurisdiction - verify the branch's legal status separately.
• Payment institution (PI) vs. EMI distinction: Payment institutions and e-money institutions are distinct. This guide focuses on EMIs only. Verify the entity's classification in EUCLID.

Frequently asked questions

Q: If an EMI is withdrawn, can it still hold my money?

No. A withdrawn EMI must cease all operations and return customer funds. The NCA may appoint a liquidator or receiver. Contact the NCA immediately if a withdrawn EMI holds your funds.

Q: How long does it take for a withdrawn EMI to be removed from EUCLID?

The EBA updates EUCLID within 5 working days of NCA notification, but the entity may remain visible with "Withdrawn" status for archival purposes. Always check the status field, not just the presence of the entry.

Q: Can an EMI's authorisation be suspended temporarily?

Yes. An NCA may suspend an EMI's authorisation for a defined period (e.g., 6 months) while investigating compliance breaches. Suspended EMIs appear in the NCA register with status "Suspended" or "Authorisation Suspended". Check the suspension date and expected end date.

Q: What should I do if I find conflicting information between EUCLID and the NCA register?

Contact the NCA directly. Provide the entity name, registration number, and the discrepancy. The NCA will clarify which register is current. Do not send funds until the discrepancy is resolved.

Q: Does an EMI need to renew its authorisation?

No. EMI authorisation is indefinite once granted, subject to ongoing compliance. However, the NCA may withdraw authorisation if the EMI breaches regulatory requirements. Check the NCA register regularly for supervisory actions or warnings.

Q: How can I check if an EMI has been fined or sanctioned?

Visit the NCA's enforcement or disciplinary action register. Most NCAs publish a list of supervisory measures, fines, and licence withdrawals. The EBA also publishes a register of significant enforcement actions across EU member states. This is separate from the authorisation status check.