# How to open a currency exchange office, a payment company or a bank in Moldova

A bank, a payment company, a currency exchange office and a savings and loan association are four different doors to the same authority. One opens with a hundred million lei, another with five hundred thousand, and between them sit capital thresholds, deadlines and documents in the management’s names — at an exchange office, the criminal records and sworn statements are filed again every year.

## In brief

- **CAEM codes:** Divisions 64 and 66
- **Authority:** The National Bank, for all four (no licence comes from the PSA)
- **Minimum capital:** From 350,000 lei (paid in full, in cash)
- **Permit term:** Unlimited, for all four

## Currency exchange office: 500,000 lei and no other line of business

A currency exchange office is defined in law as a company whose sole activity is cash currency exchange with individuals. Cash contributions to its share capital must be at least 500,000 lei, and the same amount is required again for each branch. The National Bank decides within 30 working days at most.

| Code | Activity | What it means in practice |
| --- | --- | --- |
| 66.12 | Security and commodity contracts brokerage | Brokering financial transactions on someone else’s account. The code does not decide the licence: for currency exchange, the National Bank licenses the operation with individuals, whatever code you declared at registration. |

- **Licence: Licence for cash currency exchange with individuals** — National Bank of Moldova, valid for Unlimited. Cash currency exchange with individuals, at counters or through machines. The fee is 12,000 lei for an exchange office and 6,000 for a hotel; an authorised copy for a branch costs 585 lei. Cash contributions to share capital of at least 500,000 lei are required, separately for each branch, together with a cash register at every counter, a banknote authentication device, security, real-time video surveillance kept for at least 15 days and premises with a proven right of use. The licence is valid only at the addresses entered in it. The decision comes within 30 working days at most.

**Who buys it:** The customer is the individual at the counter, and demand follows the routes by which money enters the country: remittances, tourism, cross-border trade. That is why location outweighs brand — an exchange office wins or loses on the distance between its window and the flow of people, not on reputation, because nobody compares two exchange offices before walking into one.

**What is different about the money:** This is the only branch on the page where capital is not a balance-sheet formality: the 500,000 lei is working cash, it must be held on the premises, in accounts at licensed banks or in exchange machines, and it must be topped up within 30 calendar days if exchange-rate losses take it below the threshold. The margin is the spread between buying and selling rates, so income depends on turnover, not on the number of customers.

## Payment company and e-money issuer: three capital thresholds

A payment company can be set up as an LLC (SRL) or a joint-stock company. The own funds required when applying are 350,000 lei for money remittance, 900,000 for payment initiation and 2,200,000 for the other services. Issuing electronic money requires 6,000,000 lei. The National Bank decides within 60 working days.

| Code | Activity | What it means in practice |
| --- | --- | --- |
| 66.19 | Other activities auxiliary to financial services, except insurance and pension funding | Processing and settling payments, card transactions included. The code does not decide the licence: a payment company and an e-money issuer are licensed according to the services they provide. |

- **Licence: Licence for the activity of a payment company** — National Bank of Moldova, valid for Indefinite. Providing payment services as a payment company. Own funds at the time of application: 350,000 lei for money remittance, 900,000 for payment initiation services, 2,200,000 for executing payment transactions, issuing and acquiring payment instruments or the full package. The fee is 8,000 lei at the first two thresholds and 12,000 at the third. The decision comes within 60 working days. The account information service, provided on its own, needs only registration, not a licence.
- **Licence: Licence to issue electronic money** — National Bank of Moldova, valid for Indefinite. Issuing electronic money. Own funds at the time of application are at least 6,000,000 lei, paid in full in cash. While operating, for issuing electronic money, regulated capital may not fall below the higher of two amounts: 6,000,000 lei or 2% of the average electronic money outstanding over the last six months; payment services unrelated to electronic money carry a separate capital requirement. The licence fee is 30,000 lei.

**Who buys it:** Online merchants and businesses with small, repeated receipts, plus end users in the case of e-wallets. The product sells on integration and on transaction success rate, not on commission — a lower fee does not make up for a checkout that fails. Contracts with large retailers are hard to sign and hard to lose, which makes the first ten clients half the value of the company.

**What is different about the money:** Users’ funds are not your money and may not be mixed with it: the law makes safeguarding them a licensing condition that is checked continuously, not just on file. Capital contributions are paid in full in cash and may not come from loans, other borrowed funds or users’ advances.

## Savings and loan association: not a commercial company

A savings and loan association is not an LLC and has no shareholders: it is a non-commercial organisation with a special legal status that works only with its own members. A category A licence costs 1,625 lei, allows no savings deposits and is valid only in the village (commune) or town (municipality) of registration. Category B requires a year under a category A licence, assets of 1,500,000 lei and at least 200 members.

| Code | Activity | What it means in practice |
| --- | --- | --- |
| 64.92 | Other credit granting | The code of a category A association, which lends without taking deposits. A category B association, which also takes savings deposits, is closer to 64.19, where the classifier’s notes place credit unions. |

- **Licence: Licence for the activity of a savings and loan association** — National Bank of Moldova, valid for Unlimited. Lending to members and, in category B, accepting term savings deposits. The association is registered with the National Bank’s endorsement (aviz), and the licence decision comes within 15 working days. Category A costs 1,625 lei, takes only individuals as members, accepts no savings deposits, is valid within the first-level administrative-territorial unit where the association is registered and gives no right to open branches. Category B costs 3,250 lei and requires at least a year of activity under category A, assets of at least 1,500,000 lei and at least 200 members, individuals and legal entities. Directors of a category B association take up their duties only once the National Bank confirms them in office, within 30 calendar days.

**Who buys it:** Members — and only members. An association has no customers in the usual sense, because the right to deposit savings and take a loan comes from membership, not from a sales contract. In practice associations cover villages and small towns where a bank branch does not pay for itself, and growth comes from the neighbourhood, not from advertising.

**What is different about the money:** The model is closed: in category B, members’ deposits fund members’ loans, and the association must build up and hold an institutional reserve measured against its assets. There is no dividend, because there is no shareholder. Category A may not open branches, not even in the administrative-territorial unit where it is registered.

## Bank: 100 million lei, and the company is registered after approval

A bank must be a joint-stock company, with initial capital of at least 100 million lei paid in full in cash. The order is the reverse of any other company: the Public Services Agency registers the bank only once it is shown the National Bank’s decision granting prior approval of its constitution.

| Code | Activity | What it means in practice |
| --- | --- | --- |
| 64.11 | Central banking | The central bank’s code. It is in the classifier but no private company declares it — it is listed here so it is not picked by mistake instead of 64.19. |
| 64.19 | Other monetary intermediation | The code of a commercial bank: taking deposits and lending from them. |
| 64.20 | Activities of holding companies | An ordinary holding declares it freely. A holding whose subsidiaries are mainly banks is something else — banking law defines it as a financial holding company and brings it inside the scope of supervision. |

- **Licence: Licence for the activity of a bank** — National Bank of Moldova, valid for Indefinite. Carrying on the activities permitted to banks. Initial capital may not be less than 100 million lei, and share capital is paid in full in cash at subscription. The bank is formed as a joint-stock company and must have at least three individuals running its day-to-day business. Prior approval of constitution comes within 5 months at most; after it the applicant has 5 months to file the licensing application, and the decision on the licence comes within 2 months at most. The licence fee is 50,000 lei.

**Who buys it:** The whole spectrum, from the employee to the state, which is exactly why the entry threshold is so high: the law requires the National Bank to be fully satisfied that the bank can protect depositors and the proper functioning of the banking system. Whoever opens a bank is not looking for customers but for shareholders — the customers come after the licence.

**What is different about the money:** The licence fee is 50,000 lei, a trivial sum next to the capital and the years spent preparing the file. Shares are paid for in full in cash at subscription, and initial capital is share capital minus formation costs — so the amount paid in has to be higher than the threshold, not equal to it.

## How the sector got here

- **1 July 2023 — Transfer of supervision of the non-bank financial sector.** Supervision of insurance, non-bank lending organisations and savings and loan associations passes from the National Commission for Financial Markets to the National Bank of Moldova. For a savings and loan association, the authority that issues the licence and confirms the directors has been the National Bank ever since.
- **1 January 2026 — Regulation on licensing currency exchange units.** The current wording of the National Bank’s regulation on licensing currency exchange units takes effect. The premises requirements and the annual 1 April deadline for criminal records and statements are read from this act, not only from the law.
- **10 July 2026 — Law no. 114/2012 on payment services and electronic money.** Amendments on the control of qualifying holdings in payment companies take effect: the National Bank’s prior permission, the licensing condition tied to the holders, and withdrawal of the licence when they no longer qualify.

## What the sector pays and who the companies are

Division 64 — banks and the rest of financial intermediation — paid around 32,600 lei gross a month at the end of 2025, almost twice the national average of about 16,400. Software pays more still, at around 45,700 lei.

But that figure covers only part of this page. Division 66, home to auxiliary services — payments, processing, currency exchange — paid around 15,600, below the national average. The gap between the two halves of the same statistical section is more than twofold. If you open an exchange office, your payroll looks like a shop’s, not a bank’s.

Headcount follows the same line. On 31 December 2025, division 64 employed almost 13,000 people and division 66 around 1,600. The entire auxiliary side of Moldova’s financial system — currency exchange, payments, brokerage, insurance intermediation — would fit inside one mid-sized bank.

One ratio shows where the open door really is. On 1 September 2026, the National Bank listed 267 licensed currency exchange offices, operating 415 points including branches, plus seven hotels with their own exchange point. In the registers read the same month, the list of payment companies and postal service providers held three companies with a licence in force, and the list of electronic money issuers six. That is almost thirty to one, and it describes exactly where someone starting from scratch gets in.

## Why these four trades are kept apart

All four need a licence from the same authority, and that is where what they have in common ends.

The capital threshold runs from 350,000 lei for a payment company doing only money remittance to 100 million for a bank — a ratio of almost three hundred to one on a single page. The legal form differs too: a payment company can be an LLC, a bank must be a joint-stock company, and a savings and loan association is not a commercial company at all. Decision deadlines range from 15 working days for a savings and loan association to about a year of successive stages for a bank.

What does not vary is the authority. None of these four licences comes from the Public Services Agency, because the permissive-acts law says of itself, in the article on its scope, that it does not apply to the financial sector. The currency law repeats this explicitly for exchange offices, to leave no doubt.

That sets the natural order of decisions. First you choose the branch, because it determines the capital and the legal form. Only then do you register the company — except for a bank and a savings and loan association: the bank is registered after the National Bank’s prior approval, and the association with its endorsement.

## What it costs to open

Licence fees are the small, predictable part: 12,000 lei for an exchange office, 8,000 or 12,000 for a payment company depending on the services in the package, 30,000 for an electronic money issuer, 1,625 or 3,250 lei for a savings and loan association, 50,000 for a bank. All licences are issued for an unlimited term, so the fee is paid once.

The real cost is capital, and it is not a balance-sheet figure. For an exchange office, the 500,000 lei is working money that has to physically exist on the premises, in an account at a licensed bank or in the machine, every business day. For a payment company and an e-money issuer, contributions are paid in full in cash and may not come from loans, other borrowed funds or users’ advances. For a bank, shares are paid in full in cash at subscription.

Equipment comes on top of capital. An exchange office needs a cash register at every counter, a banknote authentication device at every counter, a foreign currency guide, security and a video surveillance and recording system running in real time throughout opening hours. Recordings are kept for at least 15 calendar days.

The tax regime is chosen as for any other company, according to turnover and headcount. It is worth deciding in the first month.

## What to know before you start

### The director’s documents are not filed only once

For an exchange office, the licensing file contains the criminal record certificates of the shareholders, the beneficial owners, the director, the deputy director and the chief accountant; sworn statements by the last three that no penalty bars them from managing a commercial company or keeping accounts; their personal files, drawn up on the National Bank’s template, with copies of their identity documents; and a copy of the chief accountant’s degree in economics.

The part few people read is the paragraph at the end of the same article: the criminal record certificates and the statements are submitted to the National Bank every year, and the National Bank’s regulation sets the deadline at 1 April. This is not an opening file, it is a recurring obligation. And when the director, the deputy or the chief accountant changes, the new person’s documents are filed within 10 working days of the change.

### At a bank, people are approved before they take office

Every member of the management body and every key function holder must be approved by the National Bank before starting to exercise their responsibilities or — where the regulations allow — notified after appointment, in which case the National Bank may object afterwards.

The approval application is decided within 45 working days of the complete file, extendable by another 30 working days if further examination is needed. For board members there is a separate deadline of 60 working days from election within which the bank must file the application; if it does not, the board is deemed reduced by the persons whose documents did not arrive in time.

The planning consequence is simple: a change of chief executive is not an internal decision with immediate effect but a procedure with a two-month horizon.

### Sole activity means exactly that

Three of the four branches on this page narrow the company’s object by law, and the strictest wording is for currency exchange: an exchange office is defined as a legal entity whose sole activity is cash currency exchange with individuals.

That rules out adding a counter to an existing company, however convenient the location. It also rules out keeping a trading activity in the same company to cover the rent in the first months. The only similar form is a hotel’s exchange point, which is licensed separately, costs 6,000 lei and may only buy currency from individuals, not sell it.

### The licence is tied to the address

Currency exchange may be carried on only at the addresses stated in the licence and in its authorised copies. A move is not an administrative formality handled after the fact: it is a reissue, and the premises must meet the minimum requirements set by the National Bank and may not be used at the same time by another exchange office.

For a company building a network, this rule changes the order of things. The lease is signed before the file, because proof of the right of use is attached to the application, and each branch needs its own 500,000 lei of working cash on top.

### Non-bank supervision moved to the National Bank

Until 1 July 2023, savings and loan associations, non-bank lending organisations and insurers were supervised by the National Commission for Financial Markets. Since that date the supervisory authority for all three has been the National Bank of Moldova.

For anyone opening an association now, the change matters in practice: the licence, the confirmation of directors and the prudential rules come from the National Bank. Guides, forms and articles older than 2023 point to a different authority, and the difference is not one of name — it is one of procedure and deadlines.

## Which legal form to choose: LLC, JSC or something else

Here the answer is not yours to give; the branch gives it.

A bank must be formed as a joint-stock company, under joint-stock company law and banking law. There is no LLC option, however few shareholders you have.

A payment company and an e-money issuer may be either an LLC or a joint-stock company. For a company with two or three founders, the LLC is the natural form and stays that way until an investor arrives who wants shares.

A currency exchange office may be an LLC or a joint-stock company, but with its object narrowed to a single activity — which makes the choice of form matter less than usual, because the company will do nothing else.

A savings and loan association is not a commercial company and does not compare with the others. It is a non-commercial organisation with a special legal status, formed voluntarily by individuals and legal entities, and its name must contain the phrase “Asociația de Economii și Împrumut” or the abbreviation “A.E.Î.”.

## Frequently asked questions

### How much capital do you need for a currency exchange office?

At least 500,000 lei in cash contributions to share capital, and another 500,000 for each branch. The money is not locked away: it is the working cash you trade with, and it has to be held on the premises, in accounts at licensed banks or in the exchange machines. If exchange-rate losses take it below the threshold, you have 30 calendar days to top it up.

### Can you add a currency exchange counter to a company you already own?

No. The law defines a currency exchange office as a legal entity whose sole activity is cash currency exchange with individuals, so you need a new, clean company with that single object. There is one exception, and it is narrow: a hotel can be licensed for its own exchange point, but only to buy foreign currency from individuals.

### Which payment service can be provided without a licence?

Only one: the account information service, provided on its own, requires registration with the National Bank rather than a licence. The moment you add any other service on top of it, you enter the ordinary licensing regime, with the capital threshold that matches the package you will provide.

### How does a savings and loan association differ from a lending company?

In who is allowed to be a customer. The association is a non-commercial organisation and works exclusively with its members — deposits come from members, loans go to members, and the directors, with a few exceptions, must be members themselves. A non-bank lending organisation has no members, it has customers, and it falls under a different regime, with a different minimum capital and entry in a different register.

### In what order is a bank registered?

The reverse of an ordinary company. First you apply to the National Bank and wait for the decision granting prior approval of constitution, which comes within 5 months at most. Only with that decision in hand does the Public Services Agency register the bank. You then have 5 months to file the licensing application, and the decision on the licence comes within 2 months at most. Miss the 5-month deadline and the prior approval lapses.

### Why does none of these licences appear on the Public Services Agency list?

Because the law that keeps the nomenclature of permissive acts says of itself that it does not apply to activities licensed, authorised or certified in the financial, banking and non-bank sector. In practice that means no one-stop shop, no tacit approval and no standard 3,250 lei fee: each regime has its own law, its own deadlines and its own fee. A founder who checks the licence list and finds nothing draws the wrong conclusion.

### What documents are required in the director’s name?

It depends on the branch, but it is never just a signature. For an exchange office you file the criminal record certificates of the director, the deputy and the chief accountant, their sworn statements that no penalty bars them from managing, their personal files with copies of their identity documents and a copy of the chief accountant’s degree in economics, and the criminal records and statements are filed again every year, by 1 April. At a bank, every member of the management body and every key function holder must be approved by the National Bank before taking up their duties or, where the National Bank’s rules allow, notified after appointment.

Choosing the CAEM codes, drafting the constitutive documents and filing with the Public Services Agency are part of the registration service.