🇦🇹 Austria vs 🇭🇷 Croatia: e-money licensing compared
Decision context and regulator route
Choosing between Austria and Croatia for a e-money licence starts with who you will answer to: Financial Market Authority Austria (Finanzmarktaufsicht, FMA) on one side, Croatian National Bank (Hrvatska narodna banka, HNB) on the other, via the 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 and the 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 respectively. The public fields are shown below, with the full dated and sourced comparison included with access.
Austria: verified 2026-09-01 · Croatia: verified 2026-09-01
| Dimension |
🇦🇹 Austria
partly open
Verified 2026-09-01
|
🇭🇷 Croatia
partly open
Verified 2026-09-01
|
|---|---|---|
| Licence type | 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 | 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 |
| Regulator | Financial Market Authority Austria (Finanzmarktaufsicht, FMA) | Croatian National Bank (Hrvatska narodna banka, HNB) |
| Capital requirement | Austria capital requirement is included in the £349 pass. | Croatia capital requirement is included in the £349 pass. |
| Timeline to authorisation | Austria timeline to authorisation is included in the £349 pass. | Croatia timeline to authorisation is included in the £349 pass. |
| Local substance | Austria local substance is included in the £349 pass. | Croatia local substance is included in the £349 pass. |
| Application cost | Austria application cost is included in the £349 pass. | Croatia application cost is included in the £349 pass. |
| Ongoing cost | Austria ongoing cost is included in the £349 pass. | Croatia ongoing cost is included in the £349 pass. |
| Passporting | Austria passporting is included in the £349 pass. | Croatia passporting is included in the £349 pass. |
| EMIs authorised | Austria emis authorised is included in the £349 pass. | Croatia emis authorised is included in the £349 pass. |
| Key restrictions | Austria key restrictions is included in the £349 pass. | Croatia key restrictions is included in the £349 pass. |
| Safeguarding | Austria safeguarding is included in the £349 pass. | Croatia safeguarding is included in the £349 pass. |
| Recent changes | PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 1 September 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension. | PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 1 September 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension. |
| Difficulty rating | Austria difficulty rating is included in the £349 pass. | Croatia difficulty rating is included in the £349 pass. |
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What changed recently
🇦🇹 Austria (verified 2026-09-01): PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 1 September 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.
🇭🇷 Croatia (verified 2026-09-01): PSD3 and the PSR merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. The final compromise texts remain awaiting formal adoption and Official Journal publication as of 1 September 2026, with an indicative European Parliament plenary on 14 December 2026. After entry into force, Member States have 21 months to transpose and apply PSD3, and the PSR generally applies after 21 months. Existing EMIs may continue for 27 months, with an exceptional further three-month extension.
Quick answers
Who regulates e-money licensing in Austria and Croatia?
Austria: Financial Market Authority Austria (Finanzmarktaufsicht, FMA). Croatia: Croatian National Bank (Hrvatska narodna banka, HNB).
What licence do you need in Austria compared with Croatia?
In Austria the authorisation route is 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; in Croatia it is 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. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Austria vs Croatia comparison?
The interactive benchmark lets you pin either jurisdiction and add up to five peers; a Founder Pass or Pro subscription unlocks every gated figure with its source and verification date. This page stays free at /e-money/compare/austria-vs-croatia.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.