Regulatory changes
What has moved recently in each covered e-money and EMI regime, free to read; Pro subscribers get it pushed to their inbox the moment an entry is updated.
Change log
🇨🇭 Switzerland
The proposed FinTech licence abolition directly affects the e-money analogue route: consultation closed 6 February 2026, earliest entry into force 2027, existing licensees grandfathered.
🇭🇰 Hong Kong
The HKMA granted its first stablecoin licences (Anchorpoint and HSBC) in April 2026 under the Stablecoins Ordinance, a separate regime from the SVF analogue route.
🇬🇧 United Kingdom
Safeguarding entry now cites FCA PS25/12 (7 May 2026); the statutory-trust stage remains under review.
🇱🇹 Lithuania
Authorised EMI count corrected against the Bank of Lithuania register: 80.
🇧🇪 Belgium
Authorised EMI count corrected against the NBB register: 3 domestic EMIs.
🇭🇷 Croatia
Authorised EMI count corrected against the HNB register: 4.
🇧🇬 Bulgaria
Authorised EMI count corrected against the BNB register: 12.
🇸🇪 Sweden
Authorised EMI count corrected against the Finansinspektionen register: 5.
🇳🇱 Netherlands
Authorised EMI count corrected against the DNB public register: 26 domestic EMIs (EEA passporting in is counted separately).
Current position by jurisdiction
🇭🇰 Hong Kong
The separate Stablecoins Ordinance (Cap. 656) came into force 1 August 2025 and is administered by the HKMA. In April 2026 the HKMA granted the first stablecoin issuer licences, to Anchorpoint and HSBC, both for HKD-referenced stablecoins, requiring at least HK$25m paid-up capital and segregated reserve assets. SVF licensees under the Payment Systems and Stored Value Facilities Ordinance (Cap. 584, the analogue regime in this row) are recognised as permitted offerors under the Stablecoins Ordinance and have a clear pathway to stablecoin issuance, but SVF and stablecoin-issuer licences remain two distinct licence types.
🇬🇧 United Kingdom
FCA safeguarding reform live from 7 May 2026; HM Treasury payments-law reform expected later in 2026.
🇱🇹 Lithuania
PSD3 and PSR merge the payment institution and EMI regimes into one payment institution licence that can issue e-money. Final texts published 23 Apr 2026, OJ expected mid to late 2026, PSR applies about 20 days after publication, PSD3 transposition within 18 months (applicability ~Q2/Q3 2028). Existing EMIs are grandfathered but must update their file. Continued AML tightening.
🇵🇹 Portugal
PSD3 and PSR merge the payment institution and EMI regimes into one payment institution licence that can issue e-money. Final texts published 23 Apr 2026, OJ expected mid to late 2026, PSR applies about 20 days after publication, PSD3 transposition within 18 months (applicability ~Q2/Q3 2028). Existing EMIs are grandfathered but must update their file.
🇮🇪 Ireland
PSD3 and PSR merge the payment institution and EMI regimes into one payment institution licence that can issue e-money. Final texts published 23 Apr 2026, OJ expected mid to late 2026, PSR applies about 20 days after publication, PSD3 transposition within 18 months (applicability ~Q2/Q3 2028). Existing EMIs are grandfathered but must update their file.
🇲🇹 Malta
PSD3 and PSR merge the payment institution and EMI regimes into one payment institution licence that can issue e-money. Final texts published 23 Apr 2026, OJ expected mid to late 2026, PSR applies about 20 days after publication, PSD3 transposition within 18 months (applicability ~Q2/Q3 2028). Existing EMIs are grandfathered but must update their file. Ongoing reputational rebuild after FATF grey-listing (delisted 2022).
🇫🇷 France
PSD3 and PSR merge the payment institution and EMI regimes into one payment institution licence that can issue e-money. Final texts published 23 Apr 2026, OJ expected mid to late 2026, PSR applies about 20 days after publication, PSD3 transposition within 18 months (applicability ~Q2/Q3 2028). Existing EMIs are grandfathered but must update their file.
🇩🇪 Germany
PSD3 and PSR merge the payment institution and EMI regimes into one payment institution licence that can issue e-money. Final texts published 23 Apr 2026, OJ expected mid to late 2026, PSR applies about 20 days after publication, PSD3 transposition within 18 months (applicability ~Q2/Q3 2028). Existing EMIs are grandfathered but must update their file.
🇨🇭 Switzerland
Federal Council launched public consultation on 22 October 2025 on FinIA amendments to replace the FinTech licence with two new categories: a payment instrument institution licence (permitting stablecoin issuance, removing the CHF 100m deposit cap) and a crypto-institution licence. Consultation closed 6 February 2026. Entry into force expected in 2027 at the earliest, so the current FinTech licence and its CHF 100m cap remain in effect for now.
🇨🇾 Cyprus
CBC issued three new directives effective 2025: the Electronic Money Institutions Directive 2025 (authorisation/prudential supervision), a Directive on Internal Organisation and Governance of EMIs, and a Directive on Assessment of Suitability of board/management members, materially tightening governance and fit-and-proper requirements ahead of PSD3/PSR. EU political agreement on PSD3/PSR was reached Nov 2025, texts published April 2026; EMD2 will be repealed and EMIs folded into the payment institution framework as a sub-category, with existing EMD2 licences remaining valid for up to 24 months post-entry-into-force (extendable to 30 months at national regulator discretion).
🇦🇹 Austria
PSD3 and the PSR will merge the payment institution and EMI regimes into one licence that can issue e-money. Final texts published 23 April 2026, applicability targeted around 2028; existing EMIs are grandfathered but must update their file.
🇱🇮 Liechtenstein
PSD3 and the PSR will merge the payment institution and EMI regimes into one licence that can issue e-money. Final texts published 23 April 2026, applicability targeted around 2028; existing EMIs are grandfathered but must update their file.
🇱🇺 Luxembourg
PSD3/PSR: EU agreement reached Nov 2025, texts published April 2026, repealing EMD2 with EMIs becoming a 'payment institution authorised to issue e-money' sub-category; Luxembourg's payment services law will need amendment within the transposition window, with transitional relief (24 months, extendable to 30) for existing EMD2-authorised entities. CSSF also active on crypto/e-money-token overlap (MiCA e-money token issuer guidance).
🇪🇸 Spain
PSD3/PSR final texts published 23 April 2026, undergoing legal-linguistic review, OJ publication expected June/July 2026 (risk of slipping to September). Analysis flags that Spain's separate payment-institution and e-money statutes (despite an integrated supervisor) will likely require a more structural legislative overhaul than in peer states to merge into PSD3/PSR's single rulebook.
🇮🇹 Italy
PSD3/PSR final compromise texts agreed by Parliament and Council, published 23 April 2026; undergoing legal-linguistic review before Official Journal publication expected June/July 2026 (possible slip to September). As a Regulation, the PSR will apply directly in Italy without national transposition; PSD3 requires transposition within 18 months. No Italy-specific transposition law yet as of mid-2026.
🇵🇱 Poland
PSD3 and the PSR will merge the payment institution and EMI regimes into one licence that can issue e-money. Final texts published 23 April 2026, applicability targeted around 2028; existing EMIs are grandfathered but must update their file.
🇨🇿 Czechia
PSD3 and the PSR will merge the payment institution and EMI regimes into one licence that can issue e-money. Final texts published 23 April 2026, applicability targeted around 2028; existing EMIs are grandfathered but must update their file.
🇸🇪 Sweden
PSD3 and the PSR will merge the payment institution and EMI regimes into one licence that can issue e-money. Final texts published 23 April 2026, applicability targeted around 2028; existing EMIs are grandfathered but must update their file.
🇳🇴 Norway
Norway's 2026 Financial Market Report (Finansmarkedsmeldingen, Meld. St. 9 2025-2026) references incoming PSD3/PSR transposition work; Norway typically transposes EU payment services legislation with a lag via the EEA Agreement, so implementation timing is expected to trail the EU's own 2026 deadlines
🇩🇰 Denmark
PSD3 and the PSR will merge the payment institution and EMI regimes into one licence that can issue e-money. Final texts published 23 April 2026, applicability targeted around 2028; existing EMIs are grandfathered but must update their file.
🇫🇮 Finland
FIN-FSA introduced a new model for submitting financial information in payment institutions' authorisation applications during 2026, and a new processing fee schedule took effect 1 January 2026, signaling active modernisation of the authorisation pipeline. No Finland-specific PSD3/PSR transposition milestone found beyond the general EU timeline.
🇧🇬 Bulgaria
Bulgaria adopted the euro on 1 January 2026 at the fixed rate of 1 EUR = 1.95583 BGN. All registered company/institutional capital (including EMI capital) is automatically recalculated at this rate; entities must formalise euro-denominated capital in governing documents and file updates with the Commercial Register by 31 December 2026. This effectively converts the BGN 700,000 EMI minimum capital to a fixed EUR-equivalent (~EUR 357,946), though BNB may in time align the stated minimum to the EMD2/PSR EUR 350,000 figure directly now that Bulgaria is in the euro area.
🇭🇷 Croatia
PSD3 and the PSR will merge the payment institution and EMI regimes into one licence that can issue e-money. Final texts published 23 April 2026, applicability targeted around 2028; existing EMIs are grandfathered but must update their file.
🇪🇪 Estonia
PSD3 and the PSR will merge the payment institution and EMI regimes into one licence that can issue e-money. Final texts published 23 April 2026, applicability targeted around 2028; existing EMIs are grandfathered but must update their file.
🇬🇷 Greece
PSD3 and the PSR will merge the payment institution and EMI regimes into one licence that can issue e-money. Final texts published 23 April 2026, applicability targeted around 2028; existing EMIs are grandfathered but must update their file.
🇭🇺 Hungary
PSD3 and the PSR will merge the payment institution and EMI regimes into one licence that can issue e-money. Final texts published 23 April 2026, applicability targeted around 2028; existing EMIs are grandfathered but must update their file.
🇱🇻 Latvia
Latvijas Banka continues actively granting new EMI licences (e.g. NorthernTech SIA, AP Operations SIA, Fibonatix in 2025-2026); Latvia is increasingly featured on fintech shortlists. As of 2025, 3 new companies received EMI licences. PSD3/PSR (final texts April 2026, OJ publication expected mid-to-late 2026) will apply directly (PSR) and require transposition (PSD3) within 18 months.
🇷🇴 Romania
Romania has introduced a new 0.5% levy on operating revenues for crypto-asset service providers to fund ASF supervision under MiCA (2025 development); BNR remains the separate competent authority specifically for e-money token (EMT) issuance by credit institutions/EMIs, distinct from the ASF crypto-CASP levy, relevant context for PSD3/MiCA-adjacent regulatory change in Romania but not a direct change to core EMD2 EMI costs
🇸🇰 Slovakia
PSD3 and the PSR will merge the payment institution and EMI regimes into one licence that can issue e-money. Final texts published 23 April 2026, applicability targeted around 2028; existing EMIs are grandfathered but must update their file.
🇸🇮 Slovenia
PSD3 and the PSR will merge the payment institution and EMI regimes into one licence that can issue e-money. Final texts published 23 April 2026, applicability targeted around 2028; existing EMIs are grandfathered but must update their file.
🇮🇸 Iceland
Iceland's e-money institution Monerium EMI ehf received the world's first e-money licence explicitly for blockchain-based issuance (2019) under EU e-money rules, passportable across the EEA, illustrating Iceland's relatively crypto/blockchain-friendly EMI stance
🇲🇽 Mexico
Continuing CNBV and Banxico secondary rules.
🇦🇪 United Arab Emirates (Dubai - VARA)
Transition deadline 16 Sep 2026 for in-scope entities.
🇸🇬 Singapore
Continuing MAS refinements to the PSA.
🇬🇮 Gibraltar
Alignment with the UK market-access regime; separate DLT provider framework since 2018.
🇳🇱 Netherlands
EU-wide PSD3/PSR: agreement reached Nov 2025, texts published April 2026, repealing EMD2 and merging EMIs into the payment institution category ('payment institutions authorised to issue e-money'). Dutch Wft/DNB framework will need corresponding amendment during the transposition window, with existing Dutch EMD2 licences remaining valid on a transitional basis (up to 24-30 months).
🇧🇪 Belgium
PSD3 and the PSR will merge the payment institution and EMI regimes into one licence that can issue e-money. Final texts published 23 April 2026, applicability targeted around 2028; existing EMIs are grandfathered but must update their file.
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Informational only, not legal advice. Verify with the relevant regulator and qualified counsel before acting.