General Overview

The 2nd Electronic Money Directive 2009/110/EC (EMD) was implemented in Gibraltar via the Financial Services (Banking) Act (the Act) and the Financial Services (Electronic Money) Regulations (the Regulations).

EMD also permits e-money institutions to engage agents and appoint distributors to provide services on behalf of the e-money institution. These can also be located within another EEA State, however, the e-money institution must notify of its intention to use an agent or distributor in another EEA State. The requirements relating to the use of agents and distributors are contained in Part IV of the Regulations. The GFSC will therefore expect payment institutions to have appropriate systems and controls in place to effectively oversee the activities of its agents and distributors.

An EEA Agent is defined in the Regulations as an agent through which an authorised e-money institution, in the exercise of its passport rights, provides payment services in the EEA other than in Gibraltar.

A Distributor is defined in the Regulations as a person who distributes or redeems electronic money on behalf of an e-money institution but who does not provide payment services on its behalf.

Any e-money institution authorised under the Act wishing to passport into another EEA state should notify the GFSC using the forms available in this section.

E-money institutions that also hold an authorisation to conduct payment services are not required to submit a separate notification. These activities can be included within the firm’s e-money notification.



Application fee(s) must be submitted with the notification form(s). Notifications will not be considered incomplete if the fee has not been paid and will not be processed until the fee is received.

The annual fee is not payable until your notification is approved.

  Freedom to provide Services Freedom of Establishment / Branch Engagement of an Agent/Distributor in another EEA State
Application Fee £100* £5,000** £50*
Annual Fee £100 per jurisdiction, subject to a maximum of £500 £1,000 per jurisdiction, subject to a maximum of £5,000 N/A

*The fees are per country and per notification.
**The fees are per branch.

Details of the payment methods can be requested from the Accounts Team.

Please note that host states may also levy their own fees. These will be requested directly from you by the host state regulator when they receive the notification.

Agents and Distributors:
If the agent or distributor has not been previously registered with us, then an application for this is also required.

Please click here for further information on registration fees.

Service Level Standards

The timescales for processing a notification are prescribed by the EMD. We recommend that you take note of these to ensure that you plan for your business needs in advance.

These are:

  Freedom to provide Services Freedom of Establishment / Branch
Since Date of receipt by the GFSC 1 Month 1 Month

When can I start providing services?

The host state regulator has one month, from the date we forward the notification, to process the notification. Therefore you may start providing services either 1) when one month has lapsed and no communication has been received from the host state regulator or 2) before the one month has lapsed if the host state regulator has acknowledged receipt of the notification.