Safeguarding Account for EMIs: Providers and Costs (2026)

A safeguarding account is a segregated account at a credit institution, designated for your customers' money and acknowledged in writing by the bank, so that if your EMI fails that money stays out of reach of your creditors. In the EU and the UK you need one before you can be licensed, and since April 2025 euro-area central banks no longer hold it for you. So a new EMI has to find a commercial bank willing to take it on.

For a newly licensed EMI in the EU, the realistic best options are the fintech-facing banks that publicly offer these accounts: ClearBank Europe (Netherlands), European Merchant Bank (Lithuania), Magnetiq Bank (Latvia) and LHV, with Solaris (Germany) only as a second account. In the UK the same role is played by ClearBank, LHV and Griffin. The big universal banks also hold safeguarding money, mostly for established, high-volume firms. None will open an account just because you're applying for a licence; they underwrite your business model, owners and customers, and the best one is the one that will sign your acknowledgement letter in time.

This guide covers what the account legally has to be, who offers one in Europe as of October 2026, what a small or newly licensed EMI should expect to pay and prove, what regulators have fined firms for, and why applications get refused. If you're on the other side of the table, a business choosing which EMI to trust, our EMI vs bank comparison covers what safeguarding means for you as a client.

What a safeguarding account is, legally

Two pieces of EU law set the rule.

• The Electronic Money Directive (2009/110/EC), Article 7, requires an EMI to "safeguard funds that have been received in exchange for electronic money." Funds received by card or another payment instrument must be safeguarded once they land in the EMI's account, and "in any event" no later than five business days after the e-money is issued.
• PSD2 (2015/2366), Article 10 sets the two permitted methods, which EMD2 borrows: segregate the funds and deposit them in a separate account at a credit institution (or invest them in secure, liquid, low-risk assets), or cover them with an insurance policy or comparable guarantee from an insurer or a credit institution.

Most firms use segregation. That means three practical things:

1. The account sits at a credit institution. Not at another EMI or payment institution. The Bank of Lithuania has fined firms for exactly this: PanPay Europe in 2019 for holding most client funds with EMIs and PIs in other member states, and Wallter in 2020 for client funds held with e-money and payment institutions, in accounts opened in other legal entities' names, and in accounts not designated for safeguarding.
2. It is designated. The account title and the bank's records must show it holds client funds, not your operating cash.
3. The bank acknowledges it in writing. The acknowledgement letter confirms the bank knows the money belongs to your customers and has no right of set-off or lien over it for your debts. Regulators ask for it with the licence application.

If you're still deciding whether your model needs an e-money or payment licence at all, or whether a partner can hold the funds flow for you, our comparison of merchant of record vs payment facilitator covers who carries which liabilities.

Why the central bank is no longer an option

On 19 July 2024 the Eurosystem said it "will not provide accounts to non-bank PSPs for safeguarding users' funds at central banks." From April 2025 non-bank payment firms could join TARGET (T2 and TIPS) for settlement, but not to park client money. The EBA then confirmed in a Q&A answered on 8 May 2025 that a balance held on a central bank settlement account "cannot be considered by itself a safeguarding measure" under Article 10(1).

That hit Lithuania hardest. Many Lithuanian EMIs had been safeguarding through accounts at the Bank of Lithuania, and the central bank announced in August 2024 that it would stop providing dedicated safeguarding accounts from April 2025. Those firms had to move the money to commercial banks.

Who offers safeguarding accounts to EMIs in Europe

What follows are institutions that publicly market safeguarding or client-fund accounts to licensed or applicant EMIs and PIs, as of October 2026. It is a long list to test against your currencies, customer base and regulator, not a recommendation, and none of them is obliged to take you.

A recent example of how it works for a new licensee: emoni, which received its EMI licence from De Nederlandsche Bank in March 2026, announced on 2 October 2026 that ClearBank Europe provides its safeguarding accounts and SEPA connectivity, and that ClearBank supported it during the licence application. That pattern, bank relationship first and licence second, is the norm. Crypto-facing firms can get the same treatment under closer review: ClearBank Europe announced on 3 June 2026 that it provides safeguarding and banking infrastructure to Bybit EU, a MiCA-licensed exchange.

Best safeguarding account for a newly licensed EMI in the EU

For a new licensee the best account is the one you can actually get in time, from a bank whose risk appetite matches your business plan. Order of operations matters more than the brand.

• Start the bank process before or alongside the licence application. EMBank, for example, states that a safeguarding account is required before applying for an EMI or PI licence and issues the acknowledgement letter for the application. Even where your regulator accepts a commitment at filing, it will want the account open before you take customer money.
• Pick a bank that covers your currencies. One bank rarely does EUR, GBP and USD safeguarding well. Map every currency you'll hold to an account.
• Check the letter. Confirm the bank will sign the acknowledgement in the form your regulator expects. In the UK the template is now CASS 15 Annex 1.1, updated 7 May 2026, and the FCA's own approach document notes that banks vary in their willingness to sign the model letter.
• Plan the second bank now. The Central Bank of Ireland's December 2025 feedback found firms holding "significant proportions of safeguarded funds held in individual credit institutions" without a documented credit risk appetite, and expects concentration limits. UK firms must now periodically assess whether to diversify. A second account is what keeps you trading when the first bank exits.
• Ask about reconciliation data. Daily reconciliation needs clean, same-day balance data. Ask for a sample statement file or API response before you sign.

Before choosing your home regulator, compare how each one supervises safeguarding in our jurisdiction files for Lithuania, Malta and Cyprus.

Most affordable safeguarding account for a small EMI

No provider on the list above publishes a safeguarding price list, so any figure you read online is a quote from someone's file, not a market rate. What you can control is the structure of the cost. Expect some mix of:

• a one-off due diligence or onboarding fee
• a monthly account fee, sometimes per currency
• a minimum balance, or a minimum monthly fee that behaves like one
• per-transaction fees on sweeps in and out
• interest treatment on balances: some banks pay something, some pay nothing, and that can matter more than the monthly fee once you hold real volume

Get those five lines in writing from every bank.

The bank fee is rarely the biggest cost. The real money goes on the controls around the account: daily reconciliation, the people or software that run it, the annual safeguarding audit where your regulator requires one, and the time lost if a bank exits you and you have to re-paper. A cheap account at a bank that offboards you in month nine is the most expensive option you can pick.

In the UK there is one concrete saving for very small firms. Under the FCA rules in force since 7 May 2026, a firm that has not been required to safeguard more than £100,000 of relevant funds at any time in at least the last 53 weeks is exempt from the annual safeguarding audit. The daily reconciliation and the monthly safeguarding return still apply.

Insurance or a guarantee instead of a bank account

The second Article 10 method is an insurance policy or guarantee. Its attraction is working capital: segregated money can't be used to run the business, insured funds can. UK use is growing for that reason, though segregation is still the norm.

It is not a shortcut around banking. Regulators expect:

• policies written in trust for customers, with "no condition or restriction on the prompt paying out of funds" beyond the insolvency event (the Central Bank of Ireland expects the policy terms to state how a valid claim is made and the payment timeline)
• the policy held by the licensed entity itself, not a group company; the Central Bank of Ireland flagged both points in its December 2025 feedback
• a fallback: in the UK you must notify the FCA at least two months before relying on insurance for the first time, decide at least three months before expiry whether to continue, and have a plan to move to segregation if cover isn't renewed

Payouts still land in a designated account, so you need a bank anyway. For a small EMI, insurance is a later layer, not a way around the account.

What regulators fine EMIs for

The findings repeat across countries.

The Coinbase case matters for small firms because it wasn't about fraud. It was about plumbing: according to reporting on the decision, some institutional clients paid dollars into accounts held by another group company rather than the Irish licensee, and daily shortfalls reached about €5.2 million in 2024 before they were fixed. If your group runs treasury centrally, the licensed entity still has to own, see and reconcile its own safeguarding every day.

The negative-balance point catches many new firms. If one customer is overdrawn, you can't net that against what you owe everyone else; the safeguarded pool has to cover every positive balance in full.

Why safeguarding accounts get refused or closed

Banks refuse and exit EMIs for the usual reasons, plus one: they inherit the risk of your customers.

• Customer base they can't underwrite. Crypto, gaming, forex and high-risk merchants on your book mean the bank is exposed to flows it can't see. Say so on day one; hiding it is how accounts get closed later, and it is the wrong thing to do. If you serve crypto businesses, expect questions on stablecoin exposure too; ESMA's deadline for non-MiCA stablecoins such as USDT is the current example banks ask about.
• AML controls that exist on paper only. Banks read your policies, then ask who runs transaction monitoring and how alerts are closed. An outsourced compliance function with no one in-house who can answer is a common red flag.
• Ownership they can't map. Layered holding companies without a clear chart to the individual owners slow everything down. An offshore holding company in the chain adds its own questions; we cover what banks accept for offshore companies.
• A business plan that doesn't match reality. If you declared EU consumers and your first months are B2B payouts to Asia, expect a review.
• Using the account as an operating account. A safeguarding account is for holding client money, not paying suppliers. Mixing the two is what regulators fine for, and banks close accounts for it.

The law gives you some cover, not a guarantee. PSD2 Article 36 requires banks to give payment institutions account access on an objective, non-discriminatory and proportionate basis, and to give the regulator "duly motivated reasons for any rejection." The Bank of Lithuania's guidance to banks says refusals and closures on money laundering grounds should follow an assessment of the specific case, and only where other risk-mitigation measures aren't possible. It has logged the fallout: by mid-2023 it had received 60 notifications of closed or restricted EMI and PI accounts since 2019. None of that obliges a particular bank to say yes, which is why you keep a shortlist. The same appetite question looks different from the client side; our guide to EU EMIs that onboard high-risk businesses covers it.

The application pack banks ask for

Have this ready before the first call:

• licence status: granted licence, or the application and where it stands with the regulator
• corporate documents and a full ownership chart to the individual beneficial owners, with ID and source of wealth for each
• the business plan you filed: products, target markets, customer types, expected volumes and average balances by currency
• AML/CFT policy, customer risk assessment, transaction monitoring set-up and the names of the MLRO and compliance team
• how you screen your merchant and customer book for sanctions, including payment rails that get designated mid-relationship (the UK's October 2026 listing of the Cryptomus and Heleket crypto gateways is the kind of event a bank will ask how you caught)
• safeguarding policy: method, reconciliation procedure, who performs and who signs off, cut-off times
• flow of funds diagram: where customer money comes in, which accounts it sits in, how it leaves
• other banking and scheme relationships, and any past account closures (they will find out anyway)
• for UK firms, the CASS 15 Annex 1.1 letter, so the bank's legal team can review it early

The setup that holds up

1. Two safeguarding banks, from the start. Different banks, ideally different countries, each covering the currencies you hold. Set a written concentration limit for each.
2. Daily reconciliation with a second pair of eyes. One person performs it, another reviews and signs off. Customer balances are reconciled gross; negative balances are never netted.
3. Letters on file and current. An acknowledgement for every safeguarding account, re-signed whenever an account changes.
4. Keep operating money separate. Fees you've earned move out of the safeguarding account promptly and on a schedule you can evidence.
5. An exit plan per bank. If a bank gives notice, you know where the money goes and how long a second account takes to open. If the same bank provides your scheme access, plan for losing both.
6. Watch the EU reform. PSD3 and the Payment Services Regulation were politically agreed in November 2025, and member states endorsed the final texts on 22 April 2026. Formal adoption and publication in the Official Journal were still pending in the latest status updates we could find, with most rules applying about 21 months after entry into force (around 2028). The new texts fold EMIs into the payment institution regime, tighten safeguarding and address concentration risk, and existing licensees will need re-authorisation. Build to the stricter standard now rather than re-papering later.
7. One entity, one set of accounts. If you're part of a group, the licensed entity holds its own safeguarding accounts, in its own name, and runs or properly oversees its own reconciliation. Group treasury and outsourced operations are where the 2026 Coinbase Ireland findings came from.

If you're a client of a small EMI, ask which banks hold its safeguarding money and whether there's more than one. Our guide to frozen business bank accounts covers the client-side plan.

Where Actionman fits

We work on the banking layer for operators and the firms that serve them: which banks fit a risk profile, what the file has to show, and how to spread accounts so one exit doesn't stop the business. No one can promise a bank will say yes; we make sure the file is complete and honest. If that's where you are, start with our offshore and corporate banking service and send us your licence status, currencies and customer types.