EMI Registration in T&T: Some Key Considerations
Do you have plans to do EMI registration in Trinidad and Tobago? Whether you’re a startup, SME, or established business, understanding the legal and financial landscape is crucial to a smooth registration journey. Discover the key financial requirements, legal entity sizes, and support options for registering as an EMI in Trinidad & Tobago.
Some Core Financial Considerations
In addition to registration fees and operational costs, an entity applying to be an EMI has to give consideration to transactional limits and cater for capital requirements.
This can be especially challenging for micro, small, and medium enterprises (MSMEs), small, and medium enterprises (SMEs) or startups breaking into the fintech space.
Entity Sizes as Defined by Law
The E-Money Issuer (Amendment) Order, 2023 specifies the size categories for EMIs in Trinidad & Tobago:
| Enterprise | Employees
(including the owner/manager) |
Assets (TTD) | Annual Sales (TTD) |
| Micro | 1–5 | Up to $250,000 | Up to $250,000 |
| Small | 6–25 | Up to $1.5M | Up to $5M |
| Medium | 26–50 | Up to $5M | Up to $10M |
| Large | 51+ |
Capital Requirements & Transactional Thresholds
The E-Money Issuer (Amendment) Order 2023 outlines specific financial obligations for the above enterprises as well as for Government Employees. The classification helps to determine the capital requirements and transactional thresholds that these different sizes of EMIs need to meet. The various capital requirements and transactional thresholds are specified in Schedule 2 of the 2023 Order.
For many micro, small or medium enterprises, these costs can be significant and as a consequence, they can be challenging to meet. However, there may be legal workarounds or strategies that can be explored to overcome this challenge.
If this information resonates with you; or you need legal assistance navigating this area, feel free to reach out at info@tenorequelegalandconsulting.com. You can also explore these resources CBTT; Resources for EMIs in Trinidad & Tobago and How to Register an EMI in Trinidad & Tobago for further information.