Service · Malta

High-risk merchant account for payment service providers and EMIs with a Maltese company

Yes, a Maltese company licensed as a payment service provider (PSP) or electronic money institution (EMI) can obtain a high-risk merchant account. Success depends on the risk profile of the underlying merchant portfolio, transparent fund flows and robust compliance policies. We prepare a complete underwriting file demonstrating your firm's regulatory standing and operational integrity, then introduce you to specialist acquirers licensed to handle your specific payment flows and support Maltese corporate structures.

Profile at a glance
Service
High-risk merchant account
Industry
PSP and EMI
Typical MCC
Varies; underwritten as a licensed or sponsored provider
Entity
Private limited liability company
Authorities
Malta Business Registry; MFSA; Malta Gaming Authority
Currencies
EUR
Prerequisite
Payment institution, EMI or equivalent licence
Reserves
Collateral or safeguarding requirements; indicative
Timeline
Typically 2 to 6 weeks from complete file to live processing

How we arrange merchant accounts for Maltese PSPs and EMIs

We arrange these accounts by presenting your Maltese PSP or EMI as a regulated, compliant partner to appropriate acquiring banks. Our process begins with a detailed review of your operations, focusing on your MFSA licence, your merchant portfolio's risk profile, recent processing history, and chargeback levels. We analyse your existing merchant onboarding and anti-money laundering policies to understand your risk appetite and control measures.

Next, we build a comprehensive underwriting file. This file includes your Maltese corporate documents, director and UBO KYC, a breakdown of your merchant portfolio by industry, and evidence of your safeguarding arrangements. We ensure your website and terms of service are fully compliant with card scheme rules. The goal is to anticipate and address every question an underwriter will have about your business model, particularly regarding nested or sponsored merchant activity.

With a complete file, we identify and approach suitable acquirers. These are typically EEA-licensed institutions with an established appetite for regulated payment intermediaries and specific experience with Maltese licensees. We manage the entire application process, from the initial warm introduction to handling detailed underwriting queries, ensuring a smooth path to approval and account activation.

What underwriters check for licensed Maltese payment firms

Underwriters and compliance teams focus on the legitimacy and operational soundness of a Maltese PSP or EMI. The first check is your regulatory status, so providing a copy of your MFSA licence is essential. They will then scrutinise at least six months of processing statements to assess transaction volumes, chargeback rates, and refund ratios. The stability and risk profile of your sub-merchant portfolio are critical; underwriters need assurance that you are not onboarding merchants that the acquirer itself would decline.

Compliance checks extend to your operational framework. Acquirers will request and review your merchant onboarding policies, anti-money laundering (AML) procedures, and details of your safeguarding bank accounts. They need to see that you have a robust system for vetting and monitoring your own clients. Your website, platform, and payment checkout flow will be examined for transparency and adherence to card scheme regulations.

Finally, they perform detailed Know Your Business (KYB) checks on the Maltese entity and Know Your Customer (KYC) checks on all ultimate beneficial owners (UBOs) and directors. This confirms the individuals behind the company are credible and not associated with previous failed payment ventures.

How we run it

  1. 1.Profile review of MCC, processing history, chargeback ratios and ownership
  2. 2.Underwriting file built: website compliance, refund policy, descriptor, KYB pack
  3. 3.Matched to acquirer types licensed for the MCC and the entity's jurisdiction
  4. 4.Warm introduction and underwriting Q&A handled with the acquirer
  5. 5.Post-approval: reserve, rolling limits and chargeback monitoring set up

Documents to prepare

  • Certificate of registration
  • Memorandum and articles
  • Beneficial ownership extract
  • Licence
  • Safeguarding arrangements
  • Merchant onboarding policy
  • Portfolio breakdown
  • Passport and proof of address for each UBO and director

How a Maltese entity changes the application

Using a Maltese company provides a credible, EU-based framework for a licensed payments business, which is a significant advantage. The Malta Financial Services Authority (MFSA) is a respected regulator, and holding one of its licences gives acquirers confidence in your compliance standards. We highlight this regulatory oversight in the file.

The Malta Business Registry provides clear and accessible corporate documentation, including the certificate of registration, memorandum and articles, and beneficial ownership details, which simplifies the KYB process. As a Maltese entity, your primary operating currency will be EUR, and applications will be directed towards EEA-licensed acquirers that settle in EUR.

A key consideration for Malta is substance. While a company can be incorporated quickly, the MFSA expects licensed firms to have a genuine local presence, including qualified staff and operational functions within Malta. Acquirers are aware of this and may ask for evidence of your Maltese operations. Unlike some jurisdictions with minimal physical presence requirements, a Maltese licensee must demonstrate it is managed and controlled from Malta, a factor we prepare you to substantiate.

Why merchant accounts for PSPs are declined or closed

Merchant accounts for PSPs and EMIs are often declined because of portfolio risk. If the applying PSP serves industries that the acquirer considers too high-risk or prohibited, the application will be rejected. This is why a transparent breakdown of your merchant portfolio is essential. We ensure this is presented clearly from the start to align your profile only with acquirers that accept your specific merchant types.

Closure of a live account is frequently triggered by a spike in chargebacks or by suspicious transaction patterns from sub-merchants. Acquirers will terminate relationships if they believe the PSP has lost control of its portfolio. Another major red flag is any ambiguity around fund flows, especially with nested or sponsored merchant models. If the acquirer cannot clearly see where funds are coming from and going to, they will close the account to mitigate their own regulatory risk.

Our file preparation directly prevents these issues. By providing full transparency on your merchant base, demonstrating robust onboarding and monitoring controls, and clearly mapping your payment flows, we build the acquirer's trust. We help you establish clear reporting and communication lines with the acquirer post-approval to maintain a stable, long-term processing relationship.

Timeline, onboarding and maintaining the account

For a Maltese-licensed PSP or EMI with a complete file, the typical timeline to secure a live merchant account is between two and six weeks. The process starts once we have received all necessary documentation from you, including corporate records, KYC for owners, processing history, and compliance policies. Our file preparation takes a few days, after which we make the formal introduction to the selected acquirer.

The acquirer's underwriting review is the longest phase, often involving detailed questions about your merchant portfolio and risk management. Our handling of these queries ensures the process moves efficiently. Once approved, you will sign the merchant agreement and begin technical integration. We assist in setting up initial parameters, such as the billing descriptor and any rolling reserve requirements, which are standard for this sector.

To keep the account in good standing, you must maintain low chargeback and refund rates across your portfolio. It is vital to adhere to the operational procedures outlined in your application, especially your merchant vetting and monitoring processes. Proactive communication with the acquirer about any significant changes in your business model or merchant base is crucial for a lasting partnership.

Malta compared for payment service providers and EMIs

JurisdictionEntityCurrenciesBanking reality
MaltaPrivate limited liability companyEURLocal banks are conservative; licensed gaming and fintech operators often bank with EU EMIs and specialists
UK LtdPrivate company limited by sharesGBP, EUR, USDStrong EMI market; high street banks are conservative with non-resident directors and high-risk sectors
UAEFree zone company or mainland LLCAED, USD, EURLocal banks want visible UAE substance; EMIs and international banks fill gaps for newer companies
SingaporePrivate limited company (Pte Ltd)SGD, USD, multi-currencyBanks are rigorous and slow for non-resident founders; licensed payment institutions onboard faster

General information, not legal or tax advice. Requirements change; confirm with your counsel.

What we will not do

  • Support nested flows without transparency
  • Open accounts for unlicensed activity where a licence is required
  • Help conceal beneficial ownership or source of funds
  • Work with sanctioned persons, countries or goods
  • Promise approval: every institution makes its own decision

Xavion Capital is not a bank, acquirer or payment institution. We prepare files and introduce lawful, properly licensed businesses to regulated institutions.

Frequently asked
Can we get a merchant account for our Maltese EMI without processing history?
It is very challenging. Acquirers rely on at least six months of processing statements to evaluate risk, volume, and chargeback ratios. For a new, licensed Maltese EMI without any history, an acquirer must underwrite based purely on projections and the strength of your compliance framework. The application would need an exceptionally strong business plan, detailed financial forecasts, and evidence of significant director experience in payments. Approval is not impossible, but the file must be flawless and you should expect a higher rolling reserve.
What are the safeguarding requirements for a Maltese PSP merchant account?
The acquirer will need to see that your safeguarding arrangements comply with MFSA rules. This means demonstrating that you hold client funds in a segregated account at an authorised credit institution or EMI, completely separate from your own operational funds. During underwriting, you will need to provide details of your safeguarding institution and the procedures you follow to protect merchant and consumer money. This is a non-negotiable compliance check to ensure you are meeting your regulatory obligations as a licensed entity.
Do acquirers accept Maltese gaming companies through a PSP?
Yes, but only with full transparency and through specialist acquirers. If your Maltese PSP processes for MGA-licensed gaming operators, this must be declared. The acquirer will assess the risk based on the gaming merchants' licences, target markets, and compliance controls. Hiding gaming traffic within a general e-commerce flow will lead to immediate account termination. We connect you with acquirers that have the specific licences and appetite to support payment intermediaries serving the regulated gaming industry.
Is a UK Ltd a better option than a Maltese company for a PSP?
It depends on your strategic goals. A UK Limited company regulated by the FCA is a strong alternative, particularly if your primary market is the UK. Both are reputable jurisdictions. Malta offers a solid EU base with access to the single market and EUR processing. The choice often comes down to where your management team has more substance, your target client base, and specific regulatory advantages relevant to your business model. We can arrange accounts for PSPs in either jurisdiction.
What is a typical rolling reserve for a high-risk Maltese EMI?
A typical rolling reserve for a high-risk Maltese EMI or PSP is often 10% for 180 days, but this is indicative and varies significantly. The final figure depends on the acquirer's risk assessment of your sub-merchant portfolio. Factors like the industries you serve, average transaction value, chargeback history, and length of your operating history all influence the decision. A well-prepared file demonstrating strong risk controls and a stable processing history can help in negotiating a lower reserve from the outset.
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