Services · Licences & special services

EMI account opening: Wise, Revolut and alternatives

Updated 5 October 2026

Money in an EMI is not insured, and since October 2025 European EMIs have been closed to Russians without EU residence. When a payment account still beats a bank, which providers take non-residents and companies, and where these accounts fall short.

Money sitting in a Wise, Payoneer or Paysera balance is not a deposit. If the payment firm goes bust, no government scheme pays you back: you get whatever the firm managed to ring-fence in a separate protected account. The UK Financial Conduct Authority (FCA) found that payment firms which failed between 2018 and 2023 were short, on average, of 65% of the money they owed their users.

Even so, freelancers, online sellers and holding companies can hardly do without these accounts. An EMI (electronic money institution, a licensed payment firm that is not a bank) opens a multi-currency account with an IBAN (International Bank Account Number), usually in days rather than months, and it takes on profiles that a conservative bank will not even look at: non-residents, young companies, remote workers.

Since October 2025 that door has been shut for Russian citizens without EU residence. The EU's 19th sanctions package bars European payment firms from issuing e-money and cards to Russian nationals and residents. The exception covers anyone with citizenship or a residence permit in the EU, the European Economic Area (EEA: the EU plus Norway, Iceland and Liechtenstein) or Switzerland. Below: when an EMI account can really replace a bank, which providers open accounts for non-residents, what has changed for Russians, Belarusians and Ukrainians, and where these accounts are weak.

What is an EMI account and how is it different from a bank account?

The key difference is what happens to your money. A bank takes a deposit and can lend it out. An EMI issues electronic money: when $1,000 arrives, the firm credits $1,000 of e-money to your balance and must hold the actual funds apart from its own, in a protected account at a bank or in safe liquid assets. This is called safeguarding.

In the EU, EMIs are governed by the E-Money Directive 2009/110/EC (EMD2). Article 11 requires e-money to be redeemed at par at any time: you can withdraw your $1,000 on any day, and it has to be exactly $1,000. Article 12 bans paying interest for the time money sits in the balance. An EMI also cannot lend out its users' funds.

The capital gap explains a lot. The entry bar for an EMI is 14 times lower than for a bank, which is why Europe has so many of them, and their quality varies. Next to market leaders sit small firms with far thinner safety margins.

Not every well-known fintech brand is an EMI. In the EEA, Revolut serves customers through Revolut Bank UAB, a Lithuanian bank licensed by the European Central Bank and the Bank of Lithuania, and deposits there are insured by the Lithuanian state scheme up to $120,000. In the UK, Revolut received a full banking licence on 11 March 2026, when the Prudential Regulation Authority (PRA) allowed it to exit the restricted mobilisation phase it had been in since July 2024.

Who is an EMI account for?

An EMI beats a bank when speed, currencies and cross-border payments matter more than storing large sums. The typical cases look like this.

• Freelancing and remote work. Clients in the US and Europe pay in dollars and euros, and the money needs to be converted quickly and spent by card in your country of residence.
• E-commerce. Marketplaces and payment gateways pay out to EMI accounts, while suppliers in China or Turkey want to be paid in their own currency.
• A young company. A bank in the country of incorporation may take months to review the application, but contractors need paying and first customers need to pay you now.
• A holding or foreign company. For a company in the UK, the UAE or Hong Kong, an EMI often becomes a second account that keeps the business running if the main bank freezes it.
• Relocation. Until a local bank opens an account, an EMI lets you receive a salary, pay rent and hold several currencies.

An EMI is the wrong tool for savings and for businesses that need credit, guarantees, letters of credit or cash handling. That calls for a bank: see our guide on how to open a foreign bank account in 2026 and the personal accounts abroad section.

Which payment systems open accounts for non-residents?

For an EMI, a non-resident is anyone living outside the country where the firm is licensed. Most large EMIs open accounts for residents of dozens of countries, but each keeps its own list of accepted countries, nationalities and business types. That list moves: after new sanctions or a regulator's intervention, whole groups of users can lose access within a month or two.

These are the four best-known names, not the only options. We work with 49 payment systems, including EMIs that specialise in companies from particular countries, in e-commerce, or in businesses that compliance teams rate as higher risk (compliance meaning the anti-money-laundering checks every provider must run). The shortlist starts from your profile: citizenship, country of residence, country of the company, currencies, volumes and counterparties.

A Lithuanian IBAN is not a valid reason for a counterparty to refuse payment. Article 9 of EU Regulation 260/2012 on SEPA (Single Euro Payments Area) bans payers and payees from requiring an account in a particular EU country. Refusing a payment because of a foreign country code is known as IBAN discrimination, and the European Commission treats it as a breach of the regulation.

Can Russians open Wise, Revolut or Payoneer in 2026?

A Russian citizen without EU residence cannot open an e-money account with a European payment firm: it is expressly prohibited. EU Regulation 2025/2033, the 19th sanctions package adopted on 23 October 2025, extended Article 5b(2) of Regulation 833/2014 with three bans covering Russian nationals, residents of Russia and Russian companies:

• crypto-asset services;
• issuing payment instruments, meaning cards, plus acquiring (accepting card payments) and payment initiation by third-party services;
• issuing electronic money, which is what every EMI account runs on.

The exemptions sit in Article 5b(3). The bans do not apply to nationals of the EU, the EEA or Switzerland, or to holders of a temporary or permanent residence permit there. In guidance dated 13 March 2026, the European Commission added that a national type D visa (a long-stay visa for study, work or family reunification) usually qualifies too, once the holder has registered at their place of residence.

The permit's expiry date matters. A new card can be issued only if the residence permit is valid for the card's entire validity period, so a one-year permit will not get you a five-year card. Renewing or re-issuing an existing card counts as issuing. The ban also covers additional cards and corporate cards in the name of a Russian national, even when the account belongs to an EU company.

Wise showed what this means in practice. It blocked physical and digital cards for customers with Russian and Belarusian citizenship and set a deadline of 30 January 2026 to upload an EEA or Swiss passport, or a residence permit or visa proving residence there. Payoneer stopped serving residents of Russia back in December 2022, and in 2022 Paysera closed accounts of Russian citizens without the right to live or work in a supported country.

EU banks face a separate rule, Article 5b(1): they cannot accept deposits from Russian nationals or residents once the total at one bank exceeds $120,000. The exemptions are the same: citizenship or residence in the EU, the EEA or Switzerland.

The last row is not a loophole. The Commission warns that using a company as a conduit to obtain prohibited services is sanctions circumvention, banned by Article 12 of Regulation 833/2014. A genuine company with operations, staff and counterparties is a different matter, but it still needs a spotless record of where its money comes from.

For a Russian citizen, the only lawful route to European payment services is residence in the EU, the EEA or Switzerland. For remote workers, the most accessible options are digital nomad visas, for example in Spain or Portugal. If moving to Europe is not the plan, look at banks in countries that have not joined EU sanctions: Armenia, the UAE and others, each with its own rules. EU Regulation 765/2006 imposes equivalent restrictions on Belarusian nationals and residents.

Wise and Revolut for Ukrainians: what has changed?

Sanctions do not apply to Ukrainians, but they face other hurdles. Revolut launched in Ukraine on 11 February 2025, verifying identity through the government app Diia, and in December 2025 announced it was closing accounts of Ukraine residents. They got 60 days' notice: until 22 February 2026 they could withdraw money and download statements, and after that date only transfer the remaining balance to an external bank account. The reason was the National Bank of Ukraine's requirement to open a local branch or obtain a Ukrainian banking licence. Ukrainians living in the EEA were not affected.

Wise does not deliver cards to Ukraine: to get a card you must live in a country where Wise issues one, and Ukrainians in Europe can get a physical card delivered only to an EEA address. Ukrainians with temporary protection or a residence permit in the EU usually open Wise and Revolut accounts as residents of their host country, with a document proving their status.

EMI business account: what gets checked and which documents you need

For a company, a payment firm asks the same questions a bank does, just faster and through an online form. Rejections rarely come down to the country of incorporation; more often the EMI simply could not work out where the money comes from and why the company needs the account.

A standard pack looks like this:

• the company's constitutional documents and a registry extract, apostilled and translated for offshore companies;
• details of directors and UBOs (ultimate beneficial owners, the people who ultimately own or control the company), with passports and proof of address;
• a description of the business: what the company sells, who its customers and suppliers are, and in which countries;
• contracts, invoices or links to the website and marketplaces that show real activity;
• expected volumes: how much will come in and go out each month, and in which currencies;
• source of funds for the first incoming payments and source of wealth for the owners.

Companies with no real presence have the hardest time: an offshore entity with a nominee director, no website and no contracts. Substance helps here (real presence: an office, staff, a local director), as does a clear ownership structure. The country of incorporation matters too: a company in Lithuania or the UK has a wider choice of EMIs than one in the Seychelles or Belize. Bank options for businesses are collected in our business accounts abroad section.

If the business needs not an account in someone else's system but its own right to process customer payments, that is a licensing question. One example is a payment services provider licence in Malta.

EMIs in Europe, the UK, Hong Kong or Singapore: what is the difference?

Every country names the licence differently, but the principle is the same: the payment firm holds users' money apart from its own, and there is no government guarantee of the kind a bank deposit enjoys.

The choice usually follows the currency and the counterparties. If revenue comes in euros over SEPA, a European EMI is more convenient; if in pounds, a British one; if suppliers and customers are in Asia, one in Hong Kong or Singapore.

The pitfalls: frozen accounts, EMI failures, CRS and tax reporting

Freezes without warning. In the EU, a payment firm can end an open-ended contract with a consumer only on at least two months' notice, under Article 55 of PSD2 (the second Payment Services Directive). But once an EMI has anti-money-laundering questions, it freezes the account immediately and keeps it frozen until it gets answers. Typical triggers are a large unexplained payment, a transfer from a high-risk country, or volumes that do not match the declared profile.

When the payment firm fails. A case from Lithuania: on 22 June 2023 the Bank of Lithuania revoked the EMI licence of UAB PayrNet for serious and systematic breaches and found the company insolvent. Users' funds were held in separate accounts and about 97% was returned, with the rest passed to the insolvency administrator. The process dragged on, though: the court opened bankruptcy proceedings on 13 November 2023, and claims were accepted until 4 January 2024. In the UK, after a run of such failures, the FCA tightened the rules from 7 May 2026: daily reconciliation of users' funds, monthly returns to the regulator, an annual safeguarding audit and a resolution pack to return money quickly if a firm collapses.

Reporting to tax authorities. Since 1 January 2026, e-money accounts have been expressly within the scope of CRS (Common Reporting Standard, the framework under which countries automatically exchange data on foreigners' accounts). In the EU this was written into law by DAC8 (Directive 2023/2226 on administrative cooperation in taxation); other countries are moving to the new version on their own timetable. An account is not reported only if its rolling 90-day average balance never exceeded USD 10,000 during the year. For which countries exchange data, see our article on accounts outside CRS in 2026.

Russian currency control reporting. Russian citizens and foreigners with a Russian residence permit who spent more than 183 days in Russia in a year must report flows through foreign e-wallets to the Federal Tax Service (FNS) if more than $7,200 was credited to the balance during the year. The deadline is 1 June of the following year: reports for 2025 were due by 1 June 2026. The form is set by Russian Government Resolution No. 1365 of 12 December 2015. If the EMI account belongs to a foreign company owned by a Russian tax resident, the CFC (controlled foreign company) rules apply on top: see CFC notifications and reporting.

New EU rules ahead. On 27 November 2025 the European Parliament and the Council reached political agreement on PSD3 and the PSR, a new payment services directive and regulation. The E-Money Directive will be repealed, and EMIs will become a sub-category of payment institutions that must be re-authorised. The final texts were published on 23 April 2026, and the core rules will apply 21 months after entry into force, most likely in 2028. Account holders at smaller EMIs should watch whether their provider secures the new authorisation.

Who should not rely on a payment system account?

• Russian citizens without residence in the EU, EEA or Switzerland, as far as European EMIs go: the ban is explicit and no amount of paperwork gets around it.
• Savers. Anything beyond what you need for day-to-day payments is better kept in a bank with deposit insurance or with a broker.
• Businesses that need loans, bank guarantees, letters of credit or cash. An EMI offers none of these.
• Crypto, gambling and forex projects without their own licence. Large EMIs generally turn them down, and the specialist ones usually cost more.
• Paper companies. A nominee director, no website, no contracts and no staff mean low odds with any payment system.

How we help you open a payment system account

We start with a review: the owners' citizenship and residence, where the company is registered, which currencies and countries the payments involve, and what volumes to expect. If sanctions or compliance rules put European EMIs off-limits, we say so at the outset and suggest alternatives instead of filing an application that is bound to fail.

We then shortlist, from the 49 payment systems we work with, those whose requirements fit your profile, prepare the business description and document pack, and help you through online verification and follow-up compliance questions. The decision to open the account rests with the payment firm. If you need a company for the account, we register one in a suitable country. More corporate services are in the licences and special services section.

Fees

FAQ