🇦🇹 Austria vs 🇱🇮 Liechtenstein: e-money licensing compared
Decision context and regulator route
Choosing between Austria and Liechtenstein for a e-money licence starts with who you will answer to: Financial Market Authority Austria (Finanzmarktaufsicht, FMA) on one side, Financial Market Authority Liechtenstein (Finanzmarktaufsicht, FMA) 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 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 respectively. The public fields are shown below, with the full dated and sourced comparison included with access.
Austria: verified 2026-09-01 · Liechtenstein: verified 2026-08-15
| Dimension |
🇦🇹 Austria
partly open
Verified 2026-09-01
|
🇱🇮 Liechtenstein
partly open
Verified 2026-08-15
|
|---|---|---|
| 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 | 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 |
| Regulator | Financial Market Authority Austria (Finanzmarktaufsicht, FMA) | Financial Market Authority Liechtenstein (Finanzmarktaufsicht, FMA) |
| Capital requirement | Austria capital requirement is included in the £349 pass. | Liechtenstein capital requirement is included in the £349 pass. |
| Timeline to authorisation | Austria timeline to authorisation is included in the £349 pass. | Liechtenstein timeline to authorisation is included in the £349 pass. |
| Local substance | Austria local substance is included in the £349 pass. | Liechtenstein local substance is included in the £349 pass. |
| Application cost | Austria application cost is included in the £349 pass. | Liechtenstein application cost is included in the £349 pass. |
| Ongoing cost | Austria ongoing cost is included in the £349 pass. | Liechtenstein ongoing cost is included in the £349 pass. |
| Passporting | Austria passporting is included in the £349 pass. | Liechtenstein passporting is included in the £349 pass. |
| EMIs authorised | Austria emis authorised is included in the £349 pass. | Liechtenstein emis authorised is included in the £349 pass. |
| Key restrictions | Austria key restrictions is included in the £349 pass. | Liechtenstein key restrictions is included in the £349 pass. |
| Safeguarding | Austria safeguarding is included in the £349 pass. | Liechtenstein 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. | Liechtenstein's EEA implementation timing also depends on incorporation through the EEA Agreement. 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 15 August 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. | Liechtenstein 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.
🇱🇮 Liechtenstein (verified 2026-08-15): Liechtenstein's EEA implementation timing also depends on incorporation through the EEA Agreement. 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 15 August 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 Liechtenstein?
Austria: Financial Market Authority Austria (Finanzmarktaufsicht, FMA). Liechtenstein: Financial Market Authority Liechtenstein (Finanzmarktaufsicht, FMA).
What licence do you need in Austria compared with Liechtenstein?
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 Liechtenstein it is 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. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Austria vs Liechtenstein 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-liechtenstein.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.