How to Apply for an E-Money Issuer License in Namibia

Learn how to apply for an e-money issuer license in Namibia, including Bank of Namibia requirements, e-money application documents, licensing fees, corporate governance, compliance, digital money wallets and payment services.

If you want to issue electronic money in Namibia, the regulatory process is primarily handled by the Bank of Namibia (BoN) under the country’s national payment system framework. E-money issuers are treated as payment service providers, and applicants must satisfy regulatory, governance, operational, technological and compliance requirements before they can operate.

The regulatory framework has also evolved. The Payment System Management Act, 2023 and subsequent regulatory changes have strengthened the Bank of Namibia’s role in licensing payment service providers, including e-money issuers.

This guide explains the main steps involved in applying for an e-money license in Namibia, the documents and controls an applicant should prepare, the role of the Bank of Namibia, and important requirements relating to an electronic money wallet and payment services. For a broader overview of related regulatory procedures, see our Bank of Namibia registration guides.

What Is an E-Money Issuer in Namibia?

Electronic money is monetary value stored electronically and used to make payments. An e-money issuer provides the infrastructure, accounts or wallets through which customers can hold and use that electronic value.

An electronic money wallet may be an application, mobile-phone-based wallet, computer-based system or another device capable of electronically storing monetary value and facilitating transactions. The Bank of Namibia’s regulatory framework specifically addresses e-money wallets, interoperability and the operation of e-money schemes.

The Bank of Namibia currently lists PSD-3, Determination on Issuing of Electronic Money, among its payment-system determinations.

For historical background, the Bank’s Electronic Money Issuance document contains earlier requirements and fees associated with e-money issuing. Applicants should not assume that historical fees or requirements remain unchanged.

Who Regulates E-Money Issuers in Namibia?

The Bank of Namibia is the principal regulator for payment service providers, including electronic money issuers.

Since the Payment System Management Act, 2023, the Bank has been responsible for licensing and regulating payment service providers rather than sharing that licensing function with the Payments Association of Namibia. The Bank expressly identifies electronic money issuers among the payment service providers under its regulatory mandate.

The Bank’s current regulatory framework includes:

• PSD-1 for licensing and authorisation of payment service providers
• PSD-3 for issuing electronic money
• PSD-12 for operational and cybersecurity standards
• Other payment-system determinations and directives applicable to the proposed activities

The Bank’s official payment-system determinations provide the current regulatory reference point for applicants. Businesses considering a payment service provider structure can also review our payment service provider license guide.

Does NAMFISA Issue the E-Money License?

An e-money license itself is not something that an applicant should treat as an ordinary NAMFISA licensing and registration application. The Bank of Namibia handles payment-service-provider licensing and authorisation, including e-money issuers.

NAMFISA regulates other categories of financial institutions and intermediaries under its own legislation. Its Licensing & Registration department provides information about the institutions and intermediaries falling within NAMFISA’s regulatory mandate.

Therefore, before preparing an application, determine exactly what financial service your proposed business will provide and which regulator has jurisdiction. Businesses should also understand the distinction between a payment-service-provider application and other financial-sector registration requirements.

E-Money License vs Banking License

An e-money business should not automatically be treated as a bank.

Namibia’s regulatory framework has historically allowed both banking and non-bank institutions to issue e-money subject to applicable requirements. The Bank’s guidelines state that banking institutions and non-bank institutions may issue e-money in accordance with PSD-3 and the applicable guidelines.

A business that intends to conduct broader banking activities may instead require a banking license. The Bank’s banking license application guidelines explain the separate regulatory process applicable to banking business. For additional practical information, see our guide on applying for a commercial banking license in Namibia.

The distinction is important because the licensing requirements, capital expectations, governance arrangements and permitted activities can differ. Related banking matters can include Bank of Namibia approval for acquiring shares in a Namibian bank or establishing a foreign bank representative office in Namibia.

How to Apply for an E-Money Issuer License in Namibia

1. Establish the Business Structure

Start by determining the legal entity that will conduct the e-money business.

The proposed structure should be appropriate for a regulated financial-services operation and should clearly identify:

• Shareholders
• Directors
• Senior management
• Ultimate beneficial owners
• Business activities
• Governance responsibilities
• Sources of capital
• Operational responsibilities
• Technology and service providers

A suitable corporate governance structure is particularly important because the regulator needs to understand who controls the applicant, who is responsible for compliance and how key decisions will be supervised.

Applicants should also establish whether the proposed entity falls within the relevant definition of a payment service provider or e-money issuer before investing heavily in the application process. Where a proposed fintech product is still being developed, applicants may also consider whether the BoN FinTech Sandbox is relevant to the proposed innovation.

2. Define the E-Money Business Model

The application should clearly explain how the proposed electronic money service will operate.

For example, the business plan should explain:

• How customers will open accounts
• How electronic value will be loaded
• How customers will make payments
• Whether customers can withdraw or redeem funds
• Whether agents will be used
• How merchants will participate
• How transaction limits will work
• How customer funds will be safeguarded
• How the applicant will generate revenue
• Which payment services will be provided
• Which technology providers will be involved

A regulator needs more than a general statement that the applicant wants to operate a digital wallet. The proposed digital money wallet should be explained from the customer’s initial registration through to loading, payment, transfer, withdrawal and redemption.

The proposed product may also need to interact with other payment infrastructure, so applicants should consider requirements for joining the BoN clearing and settlement system and obtaining BoN approval for a new payment instrument, where applicable.

3. Prepare the E-Money Application

A non-bank institution intending to issue e-money must formally apply for authorisation under the applicable regulatory framework. The Bank’s guidelines specifically describe an application process for non-bank institutions, while banking institutions follow a notification process under the relevant rules.

The application should be comprehensive rather than simply consisting of a completed form.

Typical supporting documents and information may include documentation relating to:

• The applicant’s legal structure
• Ownership and beneficial ownership
• Directors and senior management
• Corporate governance
• Business and financial plans
• Capital and funding
• Risk management
• Compliance
• Customer due diligence
• Anti-money-laundering controls
• Information security
• Technology architecture
• Transaction processing
• Wallet operations
• Consumer protection
• Agent arrangements
• Outsourcing arrangements
• Business continuity
• Disaster recovery
• Internal controls
• Auditing
• Complaints handling

The precise requirements should be checked against the current PSD-1, PSD-3, Payment System Notice and any applicable Bank of Namibia guidance. If the proposed fintech also involves virtual assets, a separate regulatory analysis may be necessary; see our Namibia VASP license guide and guide to legally issuing crypto tokens.

4. Demonstrate Regulatory and Corporate Governance Readiness

Regulated payment businesses need clearly defined responsibilities.

The applicant should be able to demonstrate who is responsible for:

• Board oversight
• Executive management
• Compliance
• Risk management
• Financial reporting
• Internal controls
• Information security
• Technology
• Customer protection
• Anti-money laundering
• Operational continuity

The importance of governance is also reflected in information published about Namibia’s licensing environment. For example, guidance concerning regulated financial institutions commonly emphasizes appropriate governance and supporting documentation as part of the licensing process.

A strong governance framework should therefore be established before the application is submitted rather than created after regulatory concerns arise. Directors and senior officers should also be prepared for applicable BoN fit-and-proper assessments.

5. Prepare AML, CFT and Customer Due Diligence Controls

An e-money platform handles financial transactions and therefore requires appropriate controls for identifying customers and monitoring transactions.

The applicant should develop procedures covering:

• Customer identification
• Customer due diligence
• Beneficial ownership
• Transaction monitoring
• Suspicious transaction reporting
• Risk classification
• Record keeping
• Sanctions screening
• Fraud prevention
• Counter-financing-of-terrorism controls

The historical e-money framework specifically addressed customer due diligence and measures to prevent fraudulent activity.

The relevant AML/CFT requirements should be assessed against the laws and regulations applicable at the time of application rather than relying exclusively on older e-money documents.

6. Design the Electronic Money Wallet

Technology is a major component of an e-money application.

The proposed wallet should have appropriate controls for:

• User authentication
• Account security
• Transaction authorisation
• Fraud detection
• Transaction limits
• System availability
• Data protection
• Audit trails
• Reconciliation
• Access controls
• Incident management
• Backup and recovery

The current regulatory framework also addresses operational and cybersecurity standards within Namibia’s national payment system. The Bank of Namibia lists PSD-12 among its current determinations.

The applicant should therefore be prepared to explain how the technology supports the regulatory requirements rather than simply presenting screenshots of a mobile application.

7. Explain How Customer Funds Are Managed

An important part of an e-money model is the relationship between electronic value issued to customers and the underlying funds.

The applicant should document how funds are received, reconciled, safeguarded and made available for redemption.

The historical regulatory framework defined electronic money as value issued against received funds and redeemable for cash in Namibian Dollars. It also required e-money issuers to redeem electronic money at par upon demand.

The exact safeguarding and float-management requirements applicable to a new applicant should be confirmed against the current regulatory framework.

8. Consider Interoperability and Payment-System Integration

Modern e-money services increasingly need to interact with other payment systems.

The Bank’s regulatory framework defines interoperability as the ability of different payment systems, networks, applications and related infrastructure to connect or interface.

Applicants should therefore consider:

• Bank integrations
• Payment-system connectivity
• Merchant payments
• Transfers between wallets
• Interoperable transactions
• Settlement arrangements
• Reconciliation
• API security
• Transaction processing

The Bank has also issued a directive concerning e-money interoperability through the implementation of an instant payment switch in the national payment system.

Businesses expanding their regulated payment operations may also need to consider related applications such as opening a new bank branch or registering a foreign branch of a Namibian bank.

9. Pay the Applicable Application and Authorisation Fees

Fees form part of the regulatory application process.

An older Bank of Namibia e-money document listed an application fee of N$5,000 and an authorisation fee for issuing e-money. However, this figure should be treated as historical rather than automatically assumed to be the current fee.

This distinction matters because the Bank has subsequently revised its payment-system regulatory framework. Its 2025 annual reporting notes changes to licensing and renewal fees and updates to the Payment System Notice.

Therefore, before making payment, obtain confirmation of the applicable application fee, authorisation fee and any other charges that apply to the specific category of applicant.

10. Submit the Application to the Bank of Namibia

The application should be submitted through the process specified by the Bank for the relevant payment service.

The applicant should ensure that the application package is internally consistent. Information in the business plan should match the ownership structure, financial projections, technology architecture, governance framework and compliance documentation.

Missing or contradictory information can create unnecessary regulatory questions and delay the assessment.

The Bank has described its licensing and authorisation process for payment services as an assessment process. In a 2025 announcement, it explained that applicants may receive provisional authorisation with pre-authorisation conditions before receiving a full operational license once those conditions have been satisfied.

What Happens After Submission?

Submitting an e-money application does not necessarily mean that the business can immediately begin operating.

The regulator may assess areas such as:

1. Ownership and beneficial ownership
2. Governance
3. Management competence
4. Financial capacity
5. Business model
6. Risk management
7. AML/CFT controls
8. Technology
9. Cybersecurity
10. Consumer protection
11. Operational resilience
12. Payment-system arrangements
13. Safeguarding and reconciliation
14. Outsourcing and third-party arrangements

The applicant may need to provide additional information or address conditions before receiving full operational approval.

This is why preparation should be treated as a regulatory project rather than simply a license-form submission.

Is There a Separate Micro E-Money Issuer Category?

The regulatory framework also provides for a micro e-money issuer, described as a non-bank financial institution licensed to issue e-money on a limited scale and subject to applicable initial capital requirements.

Whether this category is suitable depends on the proposed business model, transaction scale and applicable regulatory requirements.

An applicant should establish the appropriate category before preparing its final financial model and application.

Common Mistakes to Avoid

Treating an E-Money License Like a Normal Business License

An e-money issuer operates within a regulated financial and payment environment. Registering a company does not by itself give the company permission to issue electronic money.

Using Outdated Requirements

Older e-money documents remain useful for understanding the development of the framework, but regulatory requirements can change. Namibia’s payment-system framework has undergone significant reform, including changes associated with the Payment System Management Act, 2023.

Submitting an Incomplete Application

A business plan without supporting governance, technology, compliance and financial documentation is unlikely to present the complete picture required for a regulated financial-services application.

Ignoring Cybersecurity

An electronic wallet is a technology-based financial service. Security, access controls, incident response, system resilience and transaction monitoring should be incorporated into the business model from the beginning.

Confusing NAMFISA and Bank of Namibia Requirements

The regulator depends on the activity being conducted. Payment service providers, including e-money issuers, fall under the Bank of Namibia’s payment-system licensing mandate.

E-Money Issuer License Checklist

Before submitting an application, an applicant should consider whether it has prepared:

• Namibian legal entity and ownership structure
• Beneficial ownership information
• Business plan
• Financial projections
• Capital and funding information
• Corporate governance framework
• Board and management information
• Risk-management framework
• AML/CFT framework
• Customer due diligence procedures
• Fraud-prevention controls
• Electronic money wallet design
• Technology architecture
• Cybersecurity controls
• Business continuity plan
• Disaster-recovery arrangements
• Transaction and wallet limits
• Reconciliation procedures
• Safeguarding and redemption arrangements
• Agent and outsourcing arrangements
• Consumer protection and complaints procedures
• Applicable supporting documents
• Applicable regulatory fees

Frequently Asked Questions

1. Who issues an e-money license in Namibia?

The Bank of Namibia is responsible for licensing and regulating payment service providers, including electronic money issuers.

2. How much is an e-money license in Namibia?

An older Bank of Namibia document listed an N$5,000 application fee for issuing e-money, together with an authorisation fee. However, applicants should not rely on that historical amount as the current fee because Namibia’s payment-system regulatory framework and fee structures have since been revised.

3. Can a non-bank company issue electronic money in Namibia?

Yes. Namibia’s framework provides for non-bank institutions to issue e-money subject to the applicable licensing or authorisation requirements. The Bank’s guidelines expressly address applications by non-bank institutions intending to issue electronic money.

Regulatory Resources for Applicants

Applicants should work from current primary regulatory material wherever possible. The Bank of Namibia’s current PSD-3 Determination on Issuing of Electronic Money should be reviewed alongside the applicable payment-service-provider licensing framework.

For historical legal requirements concerning electronic money, the Legal Assistance Centre’s General Notices provide additional background on requirements such as fraud prevention and redemption.

For comparison with another regulated financial-services framework, applicants can review the Namibia Financial Institutions Supervisory Authority licensing information, while businesses considering banking activities should consult the Bank’s separate banking-license guidance.

An e-money project can also involve payment infrastructure, wallets and regulated payment issuers. For an example of how an authorised Namibian financial-services business describes its digital money wallet and e-money services, see Nam-Mic Financial Services Holdings.

Third-party resources can provide additional context, but regulatory decisions should be based on the current Bank of Namibia framework. For example, information on the Namibia EMI licensing process discusses governance and compliance considerations, while PayAtlas’ Namibia regulator overview provides broader information about the regulatory environment.

Additional Business and Tax Registration Considerations

An e-money issuer will generally need an appropriate legal and tax structure in addition to its financial-services regulatory approvals. Businesses can review information on registering a business in Namibia and registering a company in Namibia as a foreigner when establishing the applicant.

The appropriate entity may be a close corporation or private limited company, depending on the proposed structure and applicable requirements. Applicants can also review company registration requirements and forms and fees for registering a private company.

Foreign investors can also review whether a foreigner can register a company in Namibia and the specific requirements for registering a company as a foreigner. Businesses operating remotely can consider remote business setup in Namibia and related virtual office services.

Once established, an applicant may need ongoing corporate administration through company secretarial services and should understand the broader business setup services available in Namibia.

Tax registration should also be addressed. Businesses can review NamRA registration in Namibia and the process for registering a business for income tax. Other relevant situations may include non-resident withholding tax on services, non-resident shareholders tax, or obtaining a NamRA certificate of good standing.

Where a company uses a trust structure, applicants can review trust registration for tax purposes with NamRA. Individuals involved in the business can also review individual taxpayer registration and, where applicable, PAYE employer registration.

Where representatives need authority to deal with tax matters, a special power of attorney for Namibian tax matters may be relevant.

Other Bank of Namibia Regulatory Activities

An e-money business may operate alongside other regulated financial or foreign-exchange activities, but each activity should be assessed separately.

Businesses involved in foreign exchange can review the requirements for an authorised forex dealer license or starting a bureau de change. Companies making international transactions may also need to understand BoN Form A for foreign exchange imports, BoN Form E for capital outflows and emigration, and approvals concerning outward foreign investment or foreign business loans.

Conclusion

Applying for an e-money issuer license in Namibia requires considerably more than registering a company and submitting an application form. The applicant needs a clearly defined business model, appropriate corporate governance, sufficient financial resources, strong compliance procedures, secure technology, operational controls and a credible approach to customer protection.

The Bank of Namibia is the key regulator for payment service providers and electronic money issuers. Because Namibia’s payment-system framework has been updated in recent years, applicants should verify the latest PSD-1, PSD-3, Payment System Notice, fees and other applicable requirements before submitting an application.