Electronic Money Issuer (EMI) License in the Philippines for Wallet and Payment Projects

With the rapid development of e-money and payment services, the Philippines is experiencing significant changes in its financial landscape. Anyone with a business looking to enter the e-money market should consider obtaining a license from the Bangko Sentral ng Pilipinas (BSP). This authorization is a crucial step towards introducing advanced digital payment systems. The information below will help you understand the process of obtaining an EMI license BSP, highlighting the main aspects and procedures.

Who Requires a Philippines OPS License?

Under the direct regulation of the Bangko Sentral ng Pilipinas (BSP), entities responsible for managing payment systems must hold a Philippines Payment Institution License (Operators of Payment Systems (OPS)). Among the broad list of service providers are, for example, independent ATM providers, payment collection centers, online sellers, and payment gateway services if they are involved in payment system management.

In order to achieve the BSP’s objectives of ensuring the integrity, efficiency, and reliability of the country’s payment infrastructure, BSP Circular No. 1049 provides for the licensing of payment system operators.

By enforcing the requirements of Republic Act No. 11127, this license gives the BSP the authority to supervise and regulate payment systems. Strengthening consumer protection and enhancing overall financial stability in the Philippines is what this regulation is aimed at.

Advantages of working with Prifinance:

Understanding E-Money and EMI License in the Philippines

E-money acts as a digital alternative to physical cash, facilitating cashless transactions through cards, mobile devices, and the web. The Bangko Sentral ng Pilipinas (BSP) defines e-money as electronically stored value:

• Held in a non-interest-bearing account,
• Valued in Philippine Peso or foreign currencies,
• Preloaded by users for making payments,
• Accepted for payments by its issuer and others, including merchants,
• Created equal to the funds received,
• Representable as a claim against its issuer,
• Withdrawable or transferrable for cash or equivalent.

Covering a wide range of electronic payments and financial services, the tools include various forms of prepaid and stored-value cards, as well as digital wallets on mobile phones.

As a critical authorization for offering digital payment solutions and electronic fund transfers nationwide, the EMI license Philippines entitles companies to act as e-money issuers in the Philippines.

Philippines Payment License Activities

1. Cash-in service providers
2. Merchant acquirers
3. Payment facilitators
4. Payment gateways
5. Bills payment services
6. Platform providers
7. Payment processors for goods and services

For consumer safety, it’s crucial to use services provided by OPS registered with the Bangko Sentral ng Pilipinas (BSP).

Philippines Payment License Activities

A Philippines Payment License authorizes a wide range of payment-related functions, including:

• Managing payment or fund transfer platforms.
• Operating payment software systems.
• Creating payment operation rules.
• Facilitating cash or equivalent deposits into accounts.
• Linking accounts to other financial entities.
• Running payment instruments systems or networks.
• Providing payment and financial services infrastructure.
• Supporting transactions between account holders and external parties.
• Exchanging payment information among participants.
• Serving multiple financial institutions for payment transactions.
• Enabling acceptance of payment instruments across sectors.
• Handling payments for individuals, businesses, or government.
• Collecting payments for transmission to merchants or creditors.
• Facilitating payments to various parties or creditors.

Depending on specific requirements, such as regulatory requirements or involvement in providing money transfer services, registration with the BSP is mandatory for an OPS before or within one month of commencing operations.

Classification of EMIs Under EMI License BSP

EMIs (Electronic Money Issuers) fall into three distinct categories:

• EMI-Bank is designed for banks.
• EMI-NBFI is a designation applied to non-bank financial institutions that are supervised by the BSP.
• EMI-Other: non-bank institutions registered as money transfer agents under section 4511N of the MORNBFI.

EMI License of the Philippines and Germany

To obtain an electronic money issuer BSP license to operate in the field of electronic money, you need to register as a legal entity. In addition, it is necessary to maintain sufficient liquidity to pay out payments to e-money users and meet certain capital requirements (e.g., PHP 200,000,000 for large banks). It is also essential to comply with compliance and reporting standards, including anti-money laundering certificates.

Among the requirements for obtaining an EMI license is the submission of a detailed application that must include a business strategy, compliance with financial crime laws, operational readiness, as well as financial, management and IT capabilities. Between 20,000 and 350,000 euros is required for initial capital, depending on the payment services provided.

Philippines EMI License Requirements

For acquiring a BSP EMI license, organizations must meet several structured criteria:

Legal Status

Must be a legally registered entity in the Philippines, applicable to corporations or partnerships.

Financial Stability

1. Maintain adequate liquid assets to ensure E-money redemptions, protecting E-money holders.
2. EMI-Banks are required to meet either the standard bank capitalization or a specific EMI-category capital minimum, for instance, PHP 200,000,000 for large-scale EMI-Banks.

Compliance and Reporting

1. Keep detailed records and report to the BSP’s supervisory department, retaining transaction and due diligence records for at least five years.
2. Obtain a Certificate of Registration from the Anti-Money Laundering Council following the 2021 AMLC Registration and Reporting Guidelines.

Steps to Secure a Philippines Payment License for OPS

For entities aiming to operate payment systems under the Philippines payment system license framework, these are the core requirements:

• Establish your operation as a stock corporation designed specifically for managing payment systems.
• Assess whether your operations comply with the functions for OPS as defined by the Monetary Board.
• The BSP treats all types of payment systems equally, whether they’re payment gateways, processors, or aggregators.
• There are no restrictions on foreign ownership for registering as OPS.

Application Process

File an Application for Registration (Form 1) with the BSP no later than one month after initiating OPS activities.

Documentation

1. Submit a detailed business plan outlining your model and targeted markets.
2. Include your business registration or permit from the appropriate local government authority.

Timing

Register within a month of starting, except when earlier registration is necessary due to regulatory requirements or for offering remittance services.

Fees and Evaluation

1. No fee for submitting the application. Identified OPS under Circular No. 1049 pay a PHP 20,000 fee upon COR issuance, except for banks and EMIs.
2. Online registration leads to an automatic Provisional Certificate of Registration (PCOR), issued within three days for banks and EMIs, valid for three months.

Compliance and Oversight

1. The BSP may review system or network infrastructure post-COR issuance as part of its oversight.
2. Adopt a risk-based approach for AML/CFT compliance. Flexible ID requirements may apply to financial inclusion products.
3. Ensure detailed sender/beneficiary information in payment transactions.
4. Foreign entities serving Philippine customers must also register as OPS.

EMI License BSP Application Steps

To obtain a Philippines E Money Institution license from the BSP, follow these key steps:

Application Submission

Submit a detailed application, including a business plan, IT, and security details to the BSP.

Evaluation by BSP

The BSP assesses the application, possibly with on-site checks for operational and compliance readiness.

Outcome

Await BSP’s decision. Approval results in receiving the EMI license, while rejections are provided with feedback.

Adherence to AML and Fraud Prevention

Strict compliance with Anti-Money Laundering regulations and implementing robust fraud prevention measures are crucial for securing and keeping the Philippines Electronic Money license.

FAQ

What defines e-money in the Philippines?

E-money is digital money used for cashless transactions via cards, mobile devices, and online, stored electronically, and often linked to the Philippine Peso or other currencies. It’s pre-funded by customers and accepted widely for payments.

Who needs an EMI license from the BSP?

Entities planning to provide digital payment services in the Philippines require a Philippines EMI license from the Bangko Sentral ng Pilipinas (BSP) to operate legally as electronic money issuers.

How to apply for a Philippines OPS license?

For an OPS (Operators of Payment Systems) license, entities must:

• Be incorporated as a stock corporation.
• Perform a self-assessment of OPS alignment.
• Submit the Application for Registration and necessary documents to the BSP.
• Comply with AML regulations and fraud prevention strategies.

What does the Philippines PI license registration involve?

OPS registration involves submitting detailed business and IT plans, complying with AML/CFT standards, and possibly undergoing BSP evaluations, including on-site inspections for operational compliance and readiness.