If you're thinking about offering digital wallets, prepaid cards, or payment apps in Malaysia, there's one thing you absolutely need: an EMI license. This license makes you a legally recognized electronic money issuer and gives you the green light to operate in the country’s growing digital payments market.
Malaysia is not just any place to build a fintech. It’s a country with a strong push for digital innovation, solid financial infrastructure, and a regulator that actually knows what it’s doing — Bank Negara Malaysia (BNM). They’re the ones who issue EMI licenses and make sure companies play by the rules.
With the right license, you can plug into the local banking system, offer secure payment products, and grow in a market that values both compliance and tech-forward thinking.
But — and this is key — BNM doesn’t hand out licenses lightly. You’ll need to follow the law to the letter, prove that your business is stable and secure, and show how you’ll protect users' money. If you can do that, the license doesn’t just open doors — it builds long-term trust with partners and customers.
What Rules Do You Need to Follow?
Let’s be real: getting licensed in Malaysia takes effort. BNM looks at everything — your structure, your business model, your risk controls, and how you handle client funds. They also expect you to follow strict anti-money laundering (AML) rules, which means knowing your customers (KYC), monitoring transactions, and reporting anything shady.
All of this is covered under Malaysia’s Financial Services Act and the updated Policy Document on Electronic Money (as of 2025). That document is basically your rulebook — it explains how to apply, what risks you can take, how to store funds safely, and how to run internal audits.
If your business can’t meet these expectations, you’re not getting that license. Simple as that. But if you’re serious about running a clean, transparent, and secure operation, then Malaysia is one of the most fintech-friendly places in the region.
Legal and Structural Requirements for Getting an EMI License in Malaysia
Before you can even think about applying for an EMI license in Malaysia, your business has to be properly set up under local law. That means no foreign branches, no overseas entities trying to sneak in. The only acceptable structure? A Sendirian Berhad (Sdn Bhd) — Malaysia’s version of a private limited company.
This setup isn’t just a formality. It gives you a clear legal identity, helps define who’s responsible for what inside the company, and limits each shareholder’s liability based on their ownership. Malaysia’s regulator, Bank Negara Malaysia (BNM), won’t review applications from companies without a real local presence — so if you don’t have a registered company in Malaysia, you’re out of the game before it even starts.
Your company must also have a physical office in Malaysia, and it can’t be a mailbox or a virtual address. This office should be where your main operations happen, and it must be available for inspection by the regulator.
That’s not all. You’ll need a local management team, including:
- A resident executive director with experience in digital finance or payments
- A compliance officer responsible for risk control, internal audits, and anti-money laundering procedures
These roles can’t be left blank. BNM expects your corporate structure to be fully built before you even submit the application. If the key people aren't in place, your EMI license application won’t move forward.
So You Want an EMI License in Malaysia? Here's What You’re Signing Up For
Getting an EMI license here isn’t just a formality — it’s a full-blown commitment. You’ll need strong finances, solid people, airtight tech, and a business model that won’t collapse the minute you go live.
Let’s break it down.
1. Your Company Needs Real Money — Not Just Paper Promises
Malaysia doesn’t mess around when it comes to capital. If you're applying to operate on a large scale, the bar is high: at least 5 million MYR (that’s about $1.18 million USD). Planning something smaller? You still need 100,000 MYR minimum — and that money needs to be fully available, not tied up in vague assets or loans.
This isn't just a checkbox. Bank Negara Malaysia will ask:
- Where exactly did the money come from?
- Can your investors keep the business running long-term?
- Is your financial setup clean and transparent?
If your answers don’t hold up, they can delay or shut down your application. You’ve got one shot to show your business is financially stable from the ground up.
2. Who’s Running the Show?
BNM will take a microscope to your team. Everyone — directors, shareholders with real influence, senior execs — will go through a "fit and proper" test. This includes:
- Do they know what they’re doing in fintech or payments?
- Are they free of conflicts, shady ties, or political baggage?
- Are they actually in Malaysia and involved — or just a name on paper?
Spoiler: If you’ve got figureheads or ghost managers, your application’s dead in the water.
3. Your Tech Stack Better Be Bulletproof
You can’t run a digital money operation on wobbly infrastructure. BNM wants proof that your system is:
- Fast, stable, and scalable
- Built with disaster recovery and backup plans
- Designed to protect every bit of user data — encrypted, always
- Resilient enough to keep going even when something breaks
They also expect you to be proactive about cyber threats. This means vulnerability testing, threat response protocols, and regular system reviews. You need a tech risk manager — someone dedicated (and not your lead developer) whose job is to stress-test the system and stay paranoid so the rest of the company doesn’t have to.
Multi-factor login? Mandatory. Regular security audits? Absolutely. If you don’t take security seriously, Malaysia won’t take your company seriously either.
The Process of Obtaining an EMI License in Malaysia
In Malaysia, the Financial Services Act and the most current Policy Document on Electronic Money spell out specific rules for how electronic money institutions (EMIs) can get licenses. The application process includes a step-by-step look at the applicant's business structure, financial signs, level of internal growth, and ability to use technology. At every step, there needs to be careful paperwork that follows the official forms and follows the steps set by Bank Negara Malaysia (BNM).
Business Plan Preparation
Before submitting the license application, the applicant must prepare a comprehensive operational model for the future electronic money issuer. The regulator’s initial assessment of the project largely depends on the quality of this business plan. It serves as the foundation for determining whether the applicant is a suitable candidate for entering the digital payments market.
The business plan should present a full picture of strategic, financial, and technological aspects and include solid arguments to prove the proposed model is both viable and sustainable.
The functional section of the plan should explain how the company plans to issue and manage electronic money, and what infrastructure it will use to deliver services. This includes:
- Format of the payment instruments (e.g., mobile wallets, prepaid cards);
- Distribution channels;
- User identity verification methods;
- Transaction handling procedures.
If the business will offer additional services — such as peer-to-peer transfers, bank account integrations, or auto top-up features — these must be outlined separately. The regulator doesn’t just review whether a product exists but assesses whether it has real practical value and fits within the current payment environment in Malaysia.
The financial section must show that the company will be able to operate without losses after licensing and continuously meet its obligations to users. Forecasts should cover a minimum of three years and include:
- Expected issuance volumes;
- Revenue and cost structure;
- User base growth projections;
- Capital structure and liquidity plans.
The document must demonstrate the company's ability to cover operational costs, meet regulatory standards, and withstand short-term financial fluctuations without needing outside financial help.
The final section focuses on the market strategy — explaining how the product will secure a stable position in its target segment. This includes:
- Target audience behavior;
- Unmet market needs;
- Local payment environment specifics;
- Digital wallet usage trends;
- Underserved regions.
The justification of the market niche is especially important. The regulator wants to ensure that the proposed solution will have real value for end users and contribute meaningfully to Malaysia’s fintech ecosystem.
Compilation of Corporate and Financial Documentation
The documentation submitted as part of the application for an EMI license in Malaysia must strictly comply with the regulatory framework established by Bank Negara Malaysia (BNM). It should provide a full and transparent overview of both the legal foundation of the applicant’s business and its financial capacity to operate as an electronic money institution. BNM requires that applicants submit verifiable evidence covering each critical aspect of the company — from its incorporation background to the integrity of its key personnel.
Below is a general breakdown of the documents typically required when applying for an EMI license in Malaysia:
The applicant must include a valid and up-to-date copy of its Articles of Association along with the Certificate of Incorporation. If the company is newly formed and has not yet completed a full financial reporting cycle, BNM allows submission of alternative supporting records, such as documentation of share issuances, internal management reports, and recent bank statements. If the applicant is part of a corporate group, the most recent annual report of the parent company must also be submitted to provide additional context.
A complete disclosure of the company’s ownership and group structure is a mandatory part of the licensing process. The applicant must submit a clearly structured diagram illustrating all direct and indirect relationships between the applicant, its parent entities, and any subsidiaries. The chart should specify ownership percentages and controlling interests across all affiliated entities. BNM places strong emphasis on transparency to ensure that the actual controlling parties are fully identifiable and accountable.
To secure an EMI license, the applicant must provide solid proof of capital origin and availability, demonstrating that the funding is legitimate, traceable, and sufficient for ongoing operations. Each shareholder acting as a financial sponsor must submit documents confirming their financial capacity and willingness to support the business. This includes bank letters, proof of liquidity, and a written explanation of how they intend to ensure funding throughout the company’s operating cycle.
The application package must include a notarized declaration from the company and its directors affirming that they have no history of criminal activity, fraud, financial misconduct, or regulatory violations that could damage their professional reputation. Additionally, the company must submit a written commitment to notify BNM immediately of any events that could adversely affect its financial condition, management integrity, or standing in the market. This obligation applies to all future developments that may arise during or after the licensing process.
If the applicant is a subsidiary of a foreign legal entity, a formal letter is required from the supervisory authority in the parent company’s home jurisdiction. This letter must confirm two things: (1) that the foreign regulator has no objections to the establishment of a Malaysian branch or subsidiary, and (2) that the parent company meets all prudential norms and has no record of regulatory breaches. Without this letter, BNM may treat the application as non-compliant.
The applicant is expected to provide a detailed description of its internal monitoring and audit framework. This should outline the methodology used for internal assessments, the allocation of responsibilities among various departments, and — if applicable — the role of the parent company in overseeing local operations. The submission must also include documentation proving that the company has a functioning compliance program, with established procedures for detecting violations and responding to regulatory obligations.
To complete the application, the company must submit comprehensive information about its leadership. This includes biographies, academic and professional qualifications, signed declarations of integrity, and a detailed breakdown of each executive’s and director’s specific duties. BNM requires clear evidence that the applicant has a fully formed and competent management structure capable of meeting all legal, financial, and operational obligations tied to EMI licensing.
Important Note: Any missing elements, inconsistencies, or formatting errors in the documentation may lead to automatic rejection of the application without advancing to the main evaluation phase. All materials must be submitted in the name of the applicant company, and the submission must be accompanied by a cover letter signed by a duly authorized representative. The signatory’s authority must be documented and approved through a formal board resolution issued in advance.
Submission to Bank Negara Malaysia
Applications can only be submitted during official acceptance periods defined by BNM. Before formal acceptance, BNM will first check whether all required documents are included. Receiving confirmation of submission does not mean the application has entered the review phase.
If any documents are missing or unclear, BNM may return the application or request clarifications. Once the application is formally registered, it is moved into the active evaluation phase.
Internal Regulatory Review
The review begins with a structured evaluation by various BNM departments, each responsible for different aspects:
- Legal compliance;
- Financial resilience;
- Operational risks;
- Sector-specific regulatory obligations.
The analysis goes beyond checking whether the documents are complete — it looks at the internal logic of the entire file. BNM assesses how well the materials align, how transparently the company presents itself, and whether the business case holds up under scrutiny.
If anything seems questionable, BNM may issue specific follow-up requests related to financial projections, technical systems, funding sources, governance, or roles of individual team members. If inconsistencies are found, the applicant may be asked to revise documentation, submit alternate proof, or provide more in-depth explanations.
BNM doesn’t assess each file in isolation. In some cases, it may contact tax authorities, foreign regulators, or other supervisory bodies to verify information about the company’s owners, funding, or compliance history. The regulator may also compare the application to similar past cases to maintain consistent licensing standards.
No interim results are shared during this process, and the review may be paused if the applicant doesn’t respond to inquiries or fails to meet follow-up requirements.
Final Decision and License Issuance
Once the full assessment is complete, BNM prepares a final evaluation based on the legal, financial, and operational findings. This results in a recommendation either to approve or deny the license.
The decision is made by a designated committee within BNM that includes officials not involved in the prior review stages. If approved, the EMI license is issued in official form, including a list of conditions that must be met before operations can begin.
These conditions may include:
- Issuance volume caps;
- Transaction limits;
- Regional service boundaries;
- Reporting obligations;
- Cybersecurity compliance;
- Independent audit requirements.
If the application is denied, the applicant receives a formal explanation outlining the exact reasons for the rejection and recommendations for how the application could be improved and resubmitted. Appeals can only be filed through BNM’s established regulatory appeal channels.
How to Apply for an EMI License in Malaysia and What to Expect Along the Way
The typical time required to get an EMI license in Malaysia is six to twelve months. The exact timeline depends heavily on two things: how complete your documentation is, and how prepared your team is to respond to additional questions from Bank Negara Malaysia (BNM) during the review process.
Delays can happen for many reasons — some are predictable, others not. If your submission has gaps, inconsistencies, or unclear sections, expect the review to slow down significantly. Incomplete data makes it harder for BNM to assess your project objectively and may trigger multiple requests for clarification.
What Can Cause Delays or Rejection?
One of the most common reasons for early-stage rejection is inadequate capital. If your company doesn’t meet the minimum capital requirement, or relies on unclear or borrowed funding, your application may be refused without further review. Another red flag is a poorly defined financing model — if it’s not clear how your operations will be funded long-term, the regulator may lose confidence in your business viability.
Ownership structure is also a critical factor. BNM expects full transparency about shareholders and controlling entities. If your ownership includes offshore companies or hidden beneficiaries that can't be verified, that alone could derail your application.
BNM also pays close attention to corporate governance. If your organization lacks real internal control — for example, no independent audit functions or a weak compliance framework — it can raise doubts about your ability to operate safely in a fast-moving market. These weaknesses often signal that the company is not ready for the responsibilities of managing digital funds.
Even the personal histories of your directors and executives matter. Any past violations, regulatory issues, or questionable conduct can disqualify the entire application, no matter how strong the rest of your business looks.
Why Legal Preparation Is Key
The way your application is structured — and how clearly the legal aspects are presented — plays a major role in how efficiently it moves through the system. Working with specialists who understand the Malaysian licensing process is a major advantage. Proper preparation helps reduce technical errors, minimize clarification requests, and establish a more collaborative relationship with the regulator.
In a market where many companies are applying and the rules are strict, it’s often the quality, consistency, and legal soundness of your materials that make the difference between approval and delay.
Final Thoughts
Getting an EMI license in Malaysia isn’t just about knowing the rules — it’s about proving your business can fit into the local regulatory environment and bring value to the fintech market. Even a strong product idea won’t succeed without careful legal planning and a well-structured licensing strategy.
BNM evaluates each application in multiple phases. They look beyond surface-level compliance — they assess your ownership transparency, your operational strength, and the real motivation behind your entry into the Malaysian market.