Launching an EMI or Payment Institution: The Technology Checklist

Getting an electronic money or payment institution licence is only half of the launch. The other half is the technology your application promised: systems that onboard customers safely, hold and move funds correctly, and give your compliance team full visibility.

This checklist covers what needs to be in place before your first customer arrives. It applies whether you build the stack yourself or launch on a platform.

1. Customer onboarding

• Identity verification (KYC) for individuals and business verification (KYB) for companies, including beneficial owners.
• Sanctions and PEP screening at onboarding and on an ongoing basis.
• Risk scoring that assigns every customer a risk level and drives how closely they are monitored.
• Document collection with a clear audit trail of what was checked, by whom and when.

2. Accounts and balances

• Client accounts with accurate, real-time balances, in every currency you plan to support.
• A clear separation between client funds and your own funds, reflecting your safeguarding arrangements.
• Statements and a full transaction history available to customers and to your operations team.

3. Payments

• Incoming and outgoing payments over the rails you need — for example SEPA, Faster Payments or SWIFT through your banking partners.
• Limits and fees configurable per customer segment, product or market.
• Clear payment statuses for customers, and exception handling for your operations team.

4. Transaction monitoring

• Know-your-transaction (KYT) monitoring with rules that match your risk assessment.
• Alerts routed to a queue where analysts can review, escalate and document decisions.
• The ability to freeze, hold or return funds when monitoring requires it.

5. Back office

Regulators and auditors will ask how your team operates day to day. Your back office should give you:

• One place to see a customer's profile, documents, risk level, accounts and activity.
• Roles and permissions so each team member sees and does only what their job requires.
• A full, tamper-evident audit log of every action.
• Reporting your compliance officer can use without asking engineering for exports.

6. Client-facing product

• A web banking portal — and, if needed, a mobile app — under your own brand and domain.
• Secure authentication, including strong customer authentication where it applies.
• Self-service for the routine tasks customers would otherwise email you about.

7. Integrations

Very few institutions build everything themselves. Plan which providers you will connect for verification, monitoring, cards, banking and, if relevant, crypto — and make sure your platform can switch providers without a rebuild.

8. Security and data protection

• Encryption in transit and at rest.
• Access control, logging and regular review of who can access what.
• Data protection processes aligned with GDPR, including retention rules and handling of data subject requests.

How long this takes

Built from scratch, this checklist is typically a multi-quarter engineering programme. On a platform already running in production, most items become configuration and integration work, and the timeline is driven by your providers and your regulator rather than by development.

Fyora covers this checklist with three modules — Client Portal, Back Office and Integrations Hub — and our team handles implementation and any custom development your licence requires.

FAQ

What is required before launch?

Onboarding, accounts, payments, monitoring, back office, a client-facing product, integrations and security.

What drives the launch timeline?

Provider readiness, regulatory requirements, configuration and integrations drive the timeline on an existing platform.