Start with the floor, because the floor sets the ceiling on what anyone can charge for a licence alone. An electronic money institution in the EU requires €350,000 of initial capital, paid in and maintained for the life of the authorisation. A payment institution requires between €20,000 and €125,000, depending on which services it registers for. I would not call that capital a cost, because it stays on the balance sheet. It does have to arrive from documented sources, and every qualifying shareholder faces source of wealth checks.

On top of capital sits the application itself. Lithuania charges a state fee of roughly €1,500, and professional fees on a serious application run from €30,000 to well past €100,000. Then there are the first-year budgets, covering legal work, capital structuring, policies, governance and running the entity. I use these ranges: €250,000 to €450,000 in Lithuania, €250,000 to €500,000 in Cyprus, €300,000 to €500,000 and upwards in Malta, €350,000 to €600,000 and upwards in Ireland, and £300,000 to £600,000 and upwards for an FCA application.

So I put the all-in cash cost of manufacturing a new EMI in Lithuania, capital included, at €600,000 to €800,000. Cyprus, Malta and Ireland run higher, up to about €950,000 once capital is added. I would hold that range in mind through the rest of this piece. Every asking price in this market negotiates against that range, whether either side admits it or not. I now open with it.

Cash is the smaller half of the de novo cost. I think the calendar is the larger one, and I think it is why the secondary market exists at all.

I work to these timelines to authorisation. Three to six months in Lithuania. Six to twelve in Cyprus and Malta, nine to fourteen in Ireland, and twelve months or more with the FCA. Full EMI authorisation across European supervisors is usually quoted at six to eighteen months. Then comes the part my buyer discovered by living through it. Post-authorisation banking infrastructure takes another six to eighteen months, and card scheme access runs on its own clock in parallel with everything else.

A change of control on an existing licence, by contrast, takes two to six months. CySEC approves a change of control in two to four months against six to nine months for a new CIF application. The FCA approves one in three to six months against twelve to eighteen months for fresh authorisation. That is the trade the market is actually pricing: six to twelve months of regulatory calendar, bought for cash.

Here is where my original advice fell apart. I had assumed one scale for EMIs and payment institutions. The European market uses three bands. I measure twenty times between the bottom band and the floor of the top one, and sixty times at its ceiling.

A shell payment institution, licensed and clean but with no infrastructure behind it, trades between €100,000 and €300,000. An operational EMI with banking infrastructure in place and a limited client base trades between €400,000 and €1,500,000. A premium operational EMI, meaning established clients, multiple banking relationships, card issuing and SEPA Instant already live, trades from €2,000,000 upwards past €6,000,000.

I want to stress that all three carry the same regulatory permission. The licence contributes the €100,000 floor and nothing above it. Everything above that floor is paid for infrastructure, banking relationships, scheme access and a client book, and on the top band that is over 95% of the price.

I went through published mandates in the licence brokerage market this year to get the shape of it. One broker offers a Lithuanian EMI with EU passporting at €800,000. Buyer mandates sit at €2,000,000 for an EU EMI and £1,000,000 for an FCA EMI. A Cyprus MiFID II investment firm mandate sits at €250,000. Outside Europe the numbers drop sharply. A Seychelles securities dealer transacts at $150,000 to $200,000 and a Mauritius investment dealer sits at a comparable level. A standard South African FSP goes for $80,000 to $140,000, and the same FSP with crypto-asset permissions goes for $155,000 to $220,000.

I set the €800,000 Lithuanian EMI against the €600,000 to €800,000 cost of building one there. I cannot find a premium in that at all. It is the de novo cost, minus the risk of refusal, minus six to twelve months. Nobody is paying a multiple for regulated status in that band. They are paying to skip a queue.

I keep coming back to the crypto permission premium on the South African FSP. The same regulator, the same entity type, and the crypto-asset category costs roughly $75,000 more. That is one of the few places I can put a clean number on what a single additional permission is worth.

A single mandate in the 2026 market shows the split better than any model I could build. It offers a Cyprus investment firm whose active client book holds €14.8 million, around $16 million, of funds under management.

I compare that to the €250,000 sitting against a bare Cyprus CIF mandate in the same market. The authorisation reads as a rounding error next to the assets sitting on it. Any valuation conversation that starts with the licence type is starting in the wrong place, and I have started in the wrong place more than once.

This is the part of the process where documentation decides the price, because a client book is only worth what the buyer can verify about it. I use the N5Deal Asset ID Card and the platform's secure data room for that step. They lay out the jurisdiction, the permission set, the banking relationships and the client base in one structured presentation. The buyer then prices what it can see, instead of discounting for what it cannot.

The July 2026 MiCA deadline moved the crypto-asset side of this market sharply, and the register shows why. As of 20 September 2026, ESMA's interim MiCA register lists 352 authorisation records, covering 347 unique active firms across the EU.

The distribution is heavily concentrated. Germany holds 91 authorisations. France holds 35, the Netherlands 28, Cyprus 24, Malta 22, Spain 15, Luxembourg 13, and Czechia, Ireland and Liechtenstein hold 12 each. Every remaining member state holds 83 between them.

I count 347 firms as a small population for a market of 450 million people. Anyone who wanted CASP permissions and missed the transition is now looking at a fresh application or at one of a few hundred existing holders. Brokers in this market describe the deadline as a supply shock, and I would agree with that reading. I have not seen a published price series for CASP entities anywhere. That makes this the least transparent corner of an already opaque market.

I am also watching a second regulatory clock on the payments side. Advisers in this market expect entities acquired in 2026 to grandfather into the PSD3 and PSR framework, with transposition due in 2027, instead of applying fresh under the new regime. If that holds, a licence bought this year carries an option that a 2028 application will not. I have not read anyone who tried to price that option.

I price four things separately now, instead of pricing one thing badly.

First, the authorisation floor, which is the cash cost of a fresh application in the same jurisdiction, less the probability of refusal. In Lithuania that is roughly €600,000 to €800,000 including paid-in capital.

Second, the calendar, which is the six to twelve months a change of control saves against fresh authorisation, priced at whatever a month of delay costs the buyer's plan. For a buyer with a funded go-to-market this is usually the largest number in the model, and it almost never appears in the model at all.

Third, the operating stack: safeguarding accounts, correspondent relationships, card issuing, SEPA Instant, a compliance officer the supervisor has already accepted. This line separates the €400,000 to €1,500,000 band from the €2,000,000 plus band. I have not found anything else that separates them.

Fourth, the book, valued on its own revenue and churn rather than as a feature of the licence.

When I run those four, the spread between a shell and a premium EMI stops looking like an anomaly. I read it as four different assets sold under one label.

I have no transaction price series for MiCA CASP entities. The register tells me how many exist and where, and it tells me nothing about what any of them changed hands for. Brokers quote ranges on request and those ranges are not published anywhere I could verify. Every CASP price I have heard this year has been a single private quote, and a single quote is not a market.

I failed to pin down the refusal rate on de novo EMI applications in any EU jurisdiction on a comparable basis. That rate is the hinge of my whole floor calculation, because I have to weight the de novo cost by the chance of no licence at all. Supervisors publish authorisation counts. I could not find withdrawal and refusal rates in any form I could compare across countries. Informal estimates reach me often enough, and I will not repeat any of them here.

I cannot split the operational EMI premium between banking relationships and card scheme access. My buyer's experience says the safeguarding account was the harder of the two, and one buyer's eleven months is an anecdote rather than a distribution.

Of everything here, the PSD3 grandfathering question leaves me least confident. Transposition is expected in 2027, transitional regimes have moved before, and I would not put a number on an option whose terms are not final. I keep coming back to it anyway, because if it holds it is the largest unpriced thing in this market.

Treat this article as general commentary on how regulated financial licences are priced. It carries no legal, regulatory, tax or investment advice about any particular entity, jurisdiction or deal. Asking prices are not transaction prices. Capital requirements and fees change by supervisor and by service set. Change of control timelines depend on how complete the incoming owner's file is. The PSD3 and PSR transitional arrangements described here are expected rather than final. Before acquiring or selling a licensed entity, take the case to a financial services regulatory lawyer qualified where the entity is authorised. Take it also to an adviser who has completed a change of control with that supervisor, and to a compliance consultant who can test the permission set against the business you intend to run.