Payment Institution Setup in Albania

Payment services in Albania are governed by a dedicated regulatory framework that draws on European models, and providing them generally requires a license from the Bank of Albania. Setting up a payment institution therefore combines two tracks: a corporate one — incorporating and organizing the local entity, registered with the National Business Center (QKB) — and a regulatory one, the licensing procedure itself.

The two tracks are connected. The company's capital, governance, shareholding and internal organization are all reviewed as part of the license examination, so decisions taken at incorporation stage can help or hurt the application later.

Andoni Law & Tax assists fintech operators, founders and international groups through both tracks, from the first regulatory assessment to the day-to-day compliance of the licensed institution.

What This Service Covers

Depending on the project, our payment institution work may include:

• assessment of whether the planned services fall within the Albanian payment services framework
• incorporation and organization of the Albanian entity, including registration with the National Business Center (QKB)
• preparation and legal review of the license application to the Bank of Albania
• legal input on the program of operations, business plan and governance documentation
• capital, internal control and management suitability requirements
• AML/KYC policies and safeguarding arrangements for client funds
• agent and outsourcing arrangements, where applicable
• post-license reporting, notifications and compliance support

When This Service Is Appropriate

Typical scenarios include:

• a fintech company planning to offer payment services to customers in Albania
• a money remittance or transfer operator formalizing or expanding its activity
• an e-commerce or platform business whose model may involve handling third-party funds
• an EU-licensed payment or e-money institution entering Albania, where EU authorizations do not extend
• an existing Albanian institution adding services, changing shareholders or restructuring

Why Legal Support Matters

A payment institution application is examined on substance: the authority looks at whether the model is genuinely understood, whether client funds are protected, and whether the governance and compliance framework matches the risk of the activity. A file assembled from templates rarely reads that way.

Legal support also matters because the boundary questions are the hardest ones — whether a given flow of funds is a payment service at all, whether an exemption may apply, and how the model should be described so the regulator sees it accurately. These questions are best answered before the structure is fixed.

We coordinate with the client's technical, financial and compliance advisers so the legal documentation matches how the product actually works.

How We Work

1. We assess the model

We review the planned services and fund flows and assess whether, and how, they fall within the Albanian payment services framework.

2. We set up the structure

We assist with incorporating and organizing the Albanian entity, including capital, governance and shareholder documentation aligned with licensing requirements.

3. We prepare the license file

We draft and review the application, program of operations, internal policies and safeguarding documentation before submission to the Bank of Albania.

4. We follow the procedure

We assist with the examination process, clarifications and additional document requests until the authority's decision, where applicable.

5. We support the licensed institution

After licensing, we advise on reporting, notifications, agent arrangements, policy updates and regulatory change.

Frequently Asked Questions

Do payment services require a license in Albania?

In general, yes — providing payment services as a business in Albania is a regulated activity, subject to licensing or registration with the Bank of Albania, depending on the model. The specific services should be reviewed before launch.

Can foreign investors set up a payment institution in Albania?

In many cases, yes. Foreign shareholders are common in the sector, subject to the suitability and documentation requirements that apply to shareholders and beneficial owners.

Does an EU payment license cover Albania?

No. Albania is not an EU member state, so passporting does not apply, and services provided in Albania generally require a local authorization. The exact perimeter should be assessed case by case.

What is the difference between a payment institution and an e-money institution?

Broadly, a payment institution provides payment services, while an electronic money institution also issues e-money. The two are subject to different requirements, so the business model determines which authorization may be appropriate.

Do you prepare the internal policies and AML documentation?

Yes. We draft and review AML/KYC policies, safeguarding documentation and related internal procedures, in coordination with the client's compliance function.

Planning to Set Up a Payment Institution in Albania?

Contact Andoni Law & Tax to review your services, fund flows and structure, and to plan the incorporation and licensing steps with a clear view of the documents involved.

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