The licensing matrix

Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011.

Financial Conduct Authority (FCA).

AEMI GBP 350,000 initial plus own funds 2% of average outstanding e-money. SEMI no initial capital, capped below EUR 5m outstanding.

About 6 to 12 months including pre-application (statutory 3 months from a complete application).

UK entity with UK mind and management, MLRO, adequate local staffing.

FCA application fee (order of GBP 5,000 for AEMI) plus roughly GBP 75k to 200k professional.

FCA periodic fees, annual safeguarding audit, compliance headcount.

None after Brexit, no EEA passport.

Around 338 e-money firms on the FCA register including small EMIs, the largest EMI population in Europe.

No interest on e-money, no deposit-taking; a SEMI cannot provide AIS or PIS.

Segregation or insurance or comparable guarantee. FCA Supplementary safeguarding regime (Policy Statement PS25/12, published 7 August 2025) in force from 7 May 2026: daily reconciliations, monthly regulatory reporting, annual safeguarding audit by a qualified auditor, resolution pack, third-party due diligence; audit exemption below GBP 100k. Stage 2 CASS-style statutory trust (Post-Repeal Regime) still under FCA review, not yet confirmed.

FCA safeguarding reform live from 7 May 2026; HM Treasury payments-law reform expected later in 2026.

4. Rigorous on financial crime and safeguarding, very large market.

EMI licence (unrestricted) or Restricted EMI, via the Bank of Lithuania.

Bank of Lithuania (Lietuvos bankas).

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.

Instituicao de Moeda Eletronica under the RJSPME (Decree-Law 91/2018).

Banco de 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.

No EMI. IFPE (Institucion de Fondos de Pago Electronico) under the Ley Fintech.

CNBV together with Banco de Mexico (Banxico).

Continuing CNBV and Banxico secondary rules.

E-Money Institution or Small E-Money Institution under the European Communities (Electronic Money) Regulations 2011.

Central Bank of Ireland (CBI).

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.

Electronic Money Institution under the Financial Institutions Act (Cap. 376).

Malta Financial Services Authority (MFSA).

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).

Etablissement de monnaie electronique.

ACPR (part of the Banque de France). Not the AMF, which handles markets and crypto.

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.

E-Geld-Institut under the ZAG.

BaFin, with the Deutsche Bundesbank.

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.

No EMI. Closest is the FINMA FinTech licence (Banking Act Art. 1b), deposits up to CHF 100m, no interest, no lending. Larger operations need a banking licence.

FINMA.

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.

No EMI. Stored Value Facility (SVF) licence and Retail Payment Services under the Retail Payment Services and Card Schemes Regulation, federal.

Central Bank of the UAE (CBUAE). Separate from Dubai VARA, which regulates crypto.

Transition deadline 16 Sep 2026 for in-scope entities.

No EMI. Major Payment Institution (MPI) licence under the Payment Services Act, covering e-money issuance and account issuance. Standard PI for smaller volumes.

Monetary Authority of Singapore (MAS).

Continuing MAS refinements to the PSA.

No EMI. Stored Value Facility (SVF) licence under the Payment Systems and Stored Value Facilities Ordinance (Cap. 584).

Hong Kong Monetary Authority (HKMA). Not the SFC, which handles the crypto VATP regime.

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.

Authorised EMI or Registered EMI under the Financial Services (Electronic Money) Regulations 2011. A real EMI regime, unlike the pure analogues.

Gibraltar Financial Services Commission (GFSC).

Alignment with the UK market-access regime; separate DLT provider framework since 2018.

Electronic Money Institution licence under the Dutch Financial Supervision Act (Wet op het financieel toezicht - Wft), implementing EMD2; an exempted/excepted EMI status also exists for smaller issuers who do not need a full DNB licence

De Nederlandsche Bank (DNB), acting as prudential supervisor under the Wft (with AFM as conduct supervisor)

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).

Electronic Money Institution (EMI) authorisation under The Electronic Money Laws of 2012-2018 and The Provision and Use of Payment Services and Access to Payment Systems Laws of 2018 to 2025 (transposing EMD2/PSD2); a Small EMI / exempt tier also exists under the same framework for issuers below EMD2 thresholds

Central Bank of Cyprus (CBC) - Licensing Section

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).

E-money institution licence (Konzession) under the E-Geldgesetz 2010 (E-Money Act 2010), Austria's EMD2 transposition; credit institutions licensed under the Banking Act (BWG) may also issue e-money without a separate EMI licence

Financial Market Authority Austria (Finanzmarktaufsicht, FMA)

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.

E-money institution licence under the E-Geldgesetz (EGG, E-Money Act of 17 March 2011), Liechtenstein's EMD2 transposition; FMA-Guidance 2018/18 sets out the licensing process

Financial Market Authority Liechtenstein (Finanzmarktaufsicht, FMA)

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.

Electronic Money Institution (EMI) authorisation under the Law of 10 November 2009 on payment services, as amended by the Law of 20 July 2018 (transposing PSD2); this same law also transposed EMD2's e-money provisions. No prominent separate small-EMI regime; EMIs are typically authorised as full EMIs given Luxembourg's fund/institutional client base.

Commission de Surveillance du Secteur Financier (CSSF)

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).

Entidad de Dinero Electronico (EDE), authorised under Ley 21/2011, de 26 de julio, de dinero electronico, and Real Decreto 778/2012 (as amended by Real Decreto 736/2019). Spain recognises 'entidades de dinero electronico hibridas' (hybrid EMIs) and an exemption/light regime under art. 14 of Real Decreto-ley 19/2018 for small-scale e-money issuers below activity thresholds, analogous to a 'small EMI' tier.

Banco de Espana (Bank of 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.

Istituto di Moneta Elettronica (IMEL), authorised under Legislative Decree 11/2010 / TUB (Testo Unico Bancario) implementing EMD2, per Banca d'Italia's 'Disposizioni di vigilanza per gli Istituti di Pagamento e gli IMEL'. No separate branded 'small IMEL' tier distinct from general PSD2 exemption thresholds was confirmed; Italy's framework centers on the full IMEL authorisation.

Banca d'Italia (Bank of Italy) - Vigilanza (Supervision) function

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.

Etablissement de monnaie electronique (EME) under the Law of 11 March 2018 on the status and supervision of payment institutions and electronic money institutions (transposing EMD2/PSD2); a 'limited' e-money institution exemption tier (etablissement de monnaie electronique limite) also exists for small-scale issuers under Art. 111 of the same law

National Bank of Belgium (Banque Nationale de Belgique / Nationale Bank van Belgie, NBB/BNB)

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.

Authorisation as a national electronic money institution (krajowa instytucja pieniądza elektronicznego), Poland's EMD2 transposition, granted and supervised by KNF, with entry into KNF's public register of payment service providers and e-money issuers (e-rup.knf.gov.pl)

Polish Financial Supervision Authority (Komisja Nadzoru Finansowego, KNF)

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.

Electronic money institution licence under Act No. 370/2017 Coll. on Payment System (transposing EMD2); a separate 'small-scale electronic money issuer' (malý vydavatel elektronických peněz) exemption tier also exists for issuers below the EMD2 activity threshold

Czech National Bank (Česká národní banka, ČNB)

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.

Tillstand att ge ut elektroniska pengar (e-money institution licence) under lagen (2011:755) om elektroniska pengar, transposing EMD2; a lighter-touch registration tier ('registrerad utgivare av elektroniska pengar' for small-scale issuers below EMD2 thresholds) also exists

Finansinspektionen (FI, the Swedish Financial Supervisory Authority)

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.

Operating licence for electronic money institutions under Iceland's Act No. 114/2021 on Payment Services (EMD2/PSD2 transposition, as an EEA EFTA state)

Central Bank of Iceland (Seðlabanki Íslands), Financial Supervisory Authority functions merged into the Central Bank of Iceland from 1 January 2020 (formerly Fjármálaeftirlitið / FME, a standalone authority 1999-2019)

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

E-pengeforetak (e-money institution) licence under Lov om e-pengeforetak (Act on E-Money Institutions, 2002) and Forskrift om e-pengeforetak (Regulation on E-Money Institutions, 2011), transposing EMD2; no separate small/exempt e-money tier (unlike the limited-authorisation option available to payment institutions for low-volume money transfer only)

Finanstilsynet (The Financial Supervisory Authority of 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

Tilladelse som e-pengeinstitut under Lov om betalinger (Payment Services Act, LBK nr 1013 af 21/08/2024), transposing EMD2; a 'begraenset tilladelse til at udstede elektroniske penge' (limited/small e-money licence) exemption tier also exists for smaller-scale issuers

Finanstilsynet (the Danish Financial Supervisory Authority / Danish FSA)

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.

Toimilupa (authorisation) as an e-money institution under the Act on Payment Institutions (Laki maksulaitoksista, 297/2010), transposing EMD2; a lighter registration-only regime exists for issuers whose average outstanding e-money does not exceed EUR 5 million (exempt/small e-money issuer tier)

Finanssivalvonta (Financial Supervisory Authority, FIN-FSA)

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.

Electronic Money Institution licence under the Law on Payment Services and Payment Systems (Zakon za platezhnite uslugi i platezhnite sistemi), transposing EMD2; a small/exempt EMI registration tier also exists for issuers below EMD2 activity thresholds

Bulgarian National Bank (BNB) - Balgarska narodna banka

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.

Authorisation to issue electronic money under Croatia's Electronic Money Act (transposing EMD2); a distinct 'small electronic money institution' (mala institucija za elektronički novac) exemption tier exists for issuers below the EMD2 threshold, with its own HNB registration track

Croatian National Bank (Hrvatska narodna banka, HNB)

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.

Operating licence (tegevusluba) for e-money institutions under the Payment Institutions and E-money Institutions Act (Makse- ja e-raha asutuste seadus, MERAS), Estonia's EMD2 transposition

Finantsinspektsioon (Estonian Financial Supervision and Resolution Authority, FSA)

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.

Electronic money institution licence under Law 4021/2011 (Articles 9-30, Greece's EMD2 transposition) as updated by Law 4537/2018 (PSD2 transposition); Bank of Greece maintains a public register of Greek EMIs and of foreign EMIs passporting into Greece

Bank of Greece (Τράπεζα της Ελλάδος)

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.

Authorisation for e-money issuing institutions (elektronikuspénz-kibocsátó intézmény) per MNB's dedicated licensing guide, Hungary's EMD2 transposition track, separate from payment institution licensing

Magyar Nemzeti Bank (MNB, Hungarian central bank, acting as financial supervisor)

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.

Two tiers: (1) Licensed electronic money institution (full EMI licence) and (2) Registered electronic money institution (lighter-touch registration tier for smaller issuers, restricted to issuing e-money and providing only payment instrument issuance or money remittance) - both under the Law on Payment Services and Electronic Money (transposing EMD2)

Latvijas Banka (Bank of Latvia) - sole licensing/supervisory authority, having absorbed the former FCMC (Finansu un kapitala tirgus komisija) in 2023

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.

Authorisation as an electronic money issuing institution (instituție emitentă de monedă electronică) granted by BNR, Romania's EMD2 transposition track; BNR is also the designated competent authority for MiCA electronic money tokens (EMTs) issued by credit institutions and e-money institutions under its supervision

National Bank of Romania (Banca Națională a României, BNR)

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

Permit (povolenie) to issue electronic money granted by NBS on the basis of a written application, Slovakia's EMD2 transposition; NBS maintains and supervises a register of licensed electronic money institutions

National Bank of Slovakia (Národná banka Slovenska, NBS)

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.

Approval (dovoljenje) to operate as an electronic money institution under the Payment Services, Electronic Money Issuing Services and Payment Systems Act (ZPlaSSIED), Slovenia's EMD2/PSD2 transposition; a 'hybrid' e-money institution designation exists for firms combining e-money issuance with other payment services or business activities

Bank of Slovenia (Banka Slovenije)

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.