If you run an EU e-money institution, PSD3 is the first rewrite in years that changes your licence itself, not just your conduct rules. The deal on the new payments package was struck on 27 November 2025, and the plan is to fold the E-Money Directive into a single payment institution framework. Our view: do not wait for the Official Journal before deciding where your next authorisation sits.
The practical point for a licensing decision is timing. Under the transitional provisions tracked by the European Parliament, existing payment and e-money institution licences stay valid for 30 months after the directive enters into force, but only if the firm applies for authorisation under the new directive within 24 months. That is a conditional grandfathering, and the application window is the part that bites.
What does PSD3 change for e-money institutions?
Three things matter most for an EMI founder or compliance lead.
One licence family instead of two
PSD3 merges the e-money regime, currently in Directive 2009/110/EC, into the payment institution framework. A payment institution can be authorised to issue e-money, with specific rules attached. For firms that chose an EMI licence mainly for issuance, expect a re-papering exercise rather than a fresh start, and watch how each national authority treats the conversion.
A simpler authorisation route, with prudential teeth
Parliament's summary of the deal says the procedure for payment institutions is simplified while strong prudential and capital requirements are kept, with initial capital scaled to risk. Crypto-asset service providers already authorised under MiCA get a streamlined route, limited to the services named in their application. For hybrid crypto and payments groups, that makes the order of licences a real strategic choice.
Fraud liability moves onto the provider
The accompanying Payment Services Regulation makes providers liable where they lack appropriate fraud prevention. Payee name checks are mandatory, impersonation fraud triggers a full refund when the customer reports to police and to their provider, and receiving providers must freeze suspicious transactions. These rules reach onboarding and transaction monitoring, so they connect directly to the onboarding and monitoring themes supervisors already press on.
Legislative status on 8 October 2026
On 8 October 2026 we found no Official Journal publication of either text. The Parliament legislative tracker records the provisional agreement of 27 November 2025 and says formal adoption by Parliament and the Council is still needed. Law-firm commentary expects most rules to apply roughly 21 months after publication, which would put general application in 2028 at the earliest. Treat that as an estimate, not a date.
What to do now
Choose your home jurisdiction with the transition in mind. National authorities will run the new authorisations, and speed and capacity differ. Compare the Lithuania and Ireland profiles, or set the United Kingdom route, which is moving on a separate track, against the EEA options on the e-money comparison tool. If you are weighing a new EEA licence before PSD3 applies, ask each regulator how it will treat applications made now when the new authorisation window opens.
Our reports track the licensing impact as national transposition plans appear.
This post is informational only and is not legal advice.
Sources
- European Parliament press release: payment services deal
- European Parliament Legislative Train: payment services and electronic money services (directive))
- Council document ST-8220-2026 (COREPER endorsement of the agreed texts, 22 April 2026)
- Freshfields commentary on timing and the e-money merger (corroboration)