Most EMI founders think about the business plan the way investors do. The regulator does not.
An investor deck is allowed to be optimistic. A licensing file is not. An investor wants upside. A supervisor wants evidence that the institution can survive stress, stay inside its permissions, fund its controls, and operate without improvisation. That is why an EMI business plan is not just a growth document. It is a supervisory document. Under the EBA authorisation guidelines, which apply to EMI applications via the mutatis mutandis PSD2 framework, the business plan sits alongside the programme of operations, structural organisation, governance, safeguarding, controls, and capital information as a core part of the application.
That distinction matters more than most applicants expect. A regulator is not reading your EMI licence business plan to decide whether the story is exciting. It is reading it to decide whether the story is governable.
Why so many EMI business plans look weak
A weak EMI business plan usually has one of two problems.
The first is that it reads like a pitch deck in longer form. It talks about market size, disruption, product vision, and rapid expansion, but says very little about operating mechanics. The second is that it goes too far in the other direction and becomes a dry annex of numbers with no convincing explanation of how the business will actually function.
Neither approach works well. The EBA guidelines require more than ambition and more than spreadsheets. For EMIs, the business plan should include a marketing plan, financial history where available, a three-year forecast budget, target and stress scenarios with assumptions, explanations of the main income and expense lines, detailed projected cash flows, information on initial capital, and the projected own-funds position under the relevant prudential method.
So the real question is not whether the plan looks polished. The real question is whether it connects the commercial model to the prudential reality of a licensed institution.
What the regulator is actually looking for
A supervisor reading an electronic money institution business plan is usually trying to answer a handful of practical questions.
What exactly will this firm do? Who will use it? How will the money move? What will revenue depend on? How quickly can the business scale without breaking its controls? Does the applicant understand its cost base? Are the assumptions credible? Will the institution still look stable if volumes are lower, onboarding is slower, margins are thinner, or compliance costs are higher than expected?
The EBA’s 2025 follow-up peer review is useful here because it shows where supervisors still see gaps. It highlights continuing divergences in the review of business plans, governance, internal control mechanisms, AML/CFT frameworks, and local substance for PI and EMI applicants. That is a good reminder that the business plan is not read in isolation; it is assessed against the whole licensing package.
In other words, the regulator is not asking whether the business can grow fast. It is asking whether the institution still makes sense when the optimistic version of the story does not happen.
An EMI business plan starts with the operating model
The best EMI business plans do not start with growth projections. They start with operating logic.
Before the numbers become credible, the institution has to explain what it will actually do. The EBA’s programme of operations requirements are very specific for EMI applicants: the file should identify the e-money services to be provided, such as issuance, redemption and distribution, and where relevant give a step-by-step description of additional payment services, a diagram of the flow of funds, settlement arrangements, draft contracts between relevant parties, and processing times.
That is why a serious EMI business plan should be built around real operational flows. If the applicant cannot clearly explain how customer funds enter the system, where electronic money is issued, how redemption works, what third parties are involved, how settlement is performed, and where the institution earns revenue, the forecasts will look ornamental.
A regulator takes numbers more seriously when the mechanics underneath them are obvious.
Forecasts need to be defendable, not impressive
One of the easiest ways to weaken an EMI application is to use aggressive projections without supervisory discipline.
The EBA guidelines do not ask for generic financial optimism. They ask for a forecast budget calculation for the first three financial years showing that the applicant can employ appropriate and proportionate systems, resources and procedures to operate soundly. That forecast should include income statement and balance-sheet projections, target and stress scenarios, and the assumptions behind them, including transaction volumes and values, customer numbers, pricing, average transaction amount, and the expected path to profitability. It should also explain key income and expense lines and include a diagram and detailed breakdown of projected cash flows.
That means the numbers must be explainable line by line. If revenue depends on transaction fees, then the plan should show what drives transaction count, average ticket size, and customer mix. If the model depends on interchange, subscription pricing, FX spread, white-label distribution, or partner fees, those revenue drivers need to be broken out clearly enough for the supervisor to see what is core and what is speculative.
The same applies to costs. A regulator will usually trust a conservative cost base more than a heroic one. Compliance, safeguarding operations, customer support, audit, governance, AML controls, IT resilience, security, outsourced oversight, and reporting all cost money. An EMI business plan that treats control functions as a footnote usually looks immature.
Stress scenarios are where the real quality shows
Anyone can build a pleasant base case. Serious applicants build uncomfortable ones too.
The EBA guidelines explicitly require target scenarios and stress scenarios together with their underlying assumptions. That requirement is more revealing than it first appears. It tells you that the regulator is not only asking, “What happens if this goes well?” but also, “What happens if customer acquisition slows down, revenues lag, or the cost of staying compliant is higher than expected?”
This is where many EMI financial projections stop being convincing. The base case may be coherent, but the downside case is often cosmetic. A serious stress case should not be a symbolic 10% haircut. It should test whether the institution can still fund staff, controls, safeguarding mechanics, outsourced services, and prudential requirements under commercial underperformance.
That is the kind of stress logic regulators tend to respect, because it looks like management is planning to operate a supervised firm rather than merely launch a product.
Capital logic has to match the business logic
An EMI business plan is not only about profit and loss. It is also about capital sufficiency and own funds logic.
For EMI applicants, the EBA guidelines require information on initial capital and on minimum own-funds requirements. For firms intending to provide only e-money services, the projections should align with the own-funds method under the E-Money Directive; for firms that will also provide payment services, the plan should reflect the applicable PSD2 methodology determined by the competent authority, including annual projections over three years.
This is where a lot of otherwise decent applications lose coherence. The commercial forecast says one thing, the capital model says another, and the staffing or control model suggests something else entirely. A regulator notices that mismatch quickly.
A stronger plan makes these pieces reinforce each other. The forecast growth trajectory, operational footprint, control buildout, and prudential capital path should all tell the same story.
Governance, AML, and outsourcing must already be visible in the plan
A common drafting mistake is treating the business plan as the commercial chapter and leaving governance, AML, and outsourcing to other annexes. In practice, that separation is too artificial.
Supervisors compare the business plan against the wider application. The EBA’s 2025 follow-up report explicitly points to continuing supervisory focus on business plans, governance and internal controls, AML/CFT frameworks, and local substance.
That means your EMI business plan should already show the consequences of those workstreams. If the model depends heavily on outsourced onboarding, the plan should reflect oversight costs and operational dependencies. If the EMI expects cross-border activity, the staffing, compliance, and support assumptions should reflect that. If the institution will use agents, distributors, programme managers, or technical partners, the plan should show how that affects governance, control intensity, and ramp-up timing.
The strongest plans do not merely forecast growth. They forecast complexity.
The Czech Republic angle: the plan has to fit the filing reality
For Czech applications, this point becomes even more practical.
The CNB states that licensing and notification requirements for payment service providers and electronic money issuers are governed by Act No. 370/2017 Coll. on Payment Systems and by Decree No. 1/2022 Coll., and that applications are submitted electronically, with the CNB recommending use of the prescribed forms and supporting materials.
So in the Czech Republic, the business plan should not be drafted as a generic EU document and then localized at the end. It needs to fit the actual filing logic, the rest of the annexes, and the supervisory reading order. A plan that may feel acceptable in abstract terms can still look weak if it does not line up with the programme of operations, governance structure, fund-flow description, and prudential calculations in the rest of the file.
What makes an EMI business plan look serious
A business plan that regulators take seriously is not defined by volume, but by substance. It translates the business model into operational reality, clearly mapping how money flows, how services are delivered, and how risks are managed. Financial projections are not just presented — they are grounded in defensible assumptions and supported by a coherent three-year trajectory.
Crucially, a strong EMI plan demonstrates awareness of downside scenarios, showing that the institution is prepared not only for growth but for stress. It reflects the true cost of licensing, compliance, safeguarding, and ongoing supervision, avoiding both over-optimism and artificial complexity.
At its core, a serious EMI business plan aligns ambition with infrastructure — ensuring that revenue expectations are matched by capital, governance, staffing, and control frameworks. This is why the most credible plans read less like promotional materials and more like structured, regulator-ready operating blueprints.
How AMS Europe approaches EMI business plans
At AMS Europe, the business plan is not treated as a standalone document, but as a central pillar of the entire EMI application. It is developed in parallel with the programme of operations, governance structure, safeguarding model, AML framework, and financial projections, ensuring full internal consistency from the outset.
Our focus is not simply to present a compelling narrative, but to build a plan that remains robust under regulatory scrutiny. Every assumption is designed to withstand cross-checking against the rest of the application file, creating a cohesive and credible submission.
For Czech EMI projects, this also means aligning the business plan with the CNB filing framework, as well as with broader European regulatory expectations under the E-Money Directive, PSD2 authorisation logic, and relevant EBA guidelines. The result is a document that speaks the regulator’s language while accurately reflecting the commercial reality of the business.
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Final thought
Regulators are not looking to be impressed by an EMI business plan — they are looking for reasons to trust it.
That trust is built through clarity, realism, and consistency. When financial projections reflect the actual operating model, when downside scenarios feel credible, when capital planning is logical, and when the cost of compliance is transparently accounted for, the business plan begins to serve its true purpose.
It stops being a formal requirement and becomes what it should be: clear evidence that the institution is operationally ready, financially sound, and prepared to function under regulatory supervision.
FAQ
What should an EMI business plan include?
An EMI business plan should combine commercial logic with regulatory substance: a clear operating model, three-year financial projections, stress scenarios, capital planning, and a detailed explanation of how the institution will generate revenue and manage risks in practice.
Why do regulators care so much about stress scenarios?
Because stress scenarios show whether the business can survive outside its optimistic assumptions. Regulators want to see that the institution remains stable and compliant even if growth slows, costs increase, or margins are under pressure.
Does the business plan need to match the programme of operations?
Yes, full alignment is critical. If the operational flows, services, or fund movements described in the programme of operations do not match the business plan, the entire application may lose credibility.
Is an EMI business plan basically the same as an investor deck?
No — the purpose is fundamentally different. While investor materials highlight growth potential, an EMI licence business plan must demonstrate control, sustainability, and the ability to operate under regulatory supervision.
How detailed do EMI financial projections need to be?
They should be detailed enough to explain every key driver of revenue and cost, including transaction volumes, pricing, customer growth, and compliance expenses, with assumptions that can be clearly defended under scrutiny.
What are the most common mistakes in EMI business plans?
The most common issues are overly optimistic projections, lack of operational detail, and weak linkage between the business model, financials, and regulatory requirements — all of which raise red flags for supervisors.
How is this handled in the Czech Republic?
In the Czech Republic, EMI applications must align with the CNB’s filing framework, including prescribed forms and supporting documents, meaning the business plan must fit seamlessly into the overall structure of the submission.
What makes an EMI business plan look credible to a regulator?
Credibility comes from consistency and realism: when the operating model, financial forecasts, capital planning, and control framework all support each other, the plan starts to look like a viable, supervised institution rather than just a concept.
