🇦🇹 Austria vs 🇬🇧 United Kingdom: e-money licensing compared
Decision context and regulator route
Austria and United Kingdom take recognisably different routes to e-money authorisation. In Austria the route is 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 overseen by Financial Market Authority Austria (Finanzmarktaufsicht, FMA); in United Kingdom it is the Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011. under Financial Conduct Authority (FCA).. The two regimes differ on 9 of 10 tracked decision dimensions, including timeline to authorisation and local substance. The free columns below are open to everyone; the decision figures unlock with a pass, each one dated and sourced.
Austria: verified 2026-07-03 · United Kingdom: verified 2026-07-15
| Dimension |
🇦🇹 Austria
partly open
Verified 2026-07-03
|
🇬🇧 United Kingdom
Free in full
Verified 2026-07-15
|
|---|---|---|
| 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 | Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011. |
| Regulator | Financial Market Authority Austria (Finanzmarktaufsicht, FMA) | Financial Conduct Authority (FCA). |
| Capital requirement | Austria capital requirement is included in the £349 pass. | AEMI GBP 350,000 initial plus own funds 2% of average outstanding e-money. SEMI no initial capital, capped below EUR 5m outstanding. |
| Timeline to authorisation | Austria timeline to authorisation is included in the £349 pass. | About 6 to 12 months including pre-application (statutory 3 months from a complete application). |
| Local substance | Austria local substance is included in the £349 pass. | UK entity with UK mind and management, MLRO, adequate local staffing. |
| Application cost | Austria application cost is included in the £349 pass. | FCA application fee GBP 5,580 for an authorised EMI (Category 5) or GBP 1,120 for a small EMI (Category 3), plus roughly GBP 75k to 200k professional; representative all-in around GBP 145k (~EUR 168k at 1.16). |
| Ongoing cost | Austria ongoing cost is included in the £349 pass. | FCA periodic fees, annual safeguarding audit, compliance headcount. |
| Passporting | Austria passporting is included in the £349 pass. | None after Brexit, no EEA passport. |
| EMIs authorised | Austria emis authorised is included in the £349 pass. | Around 338 e-money firms on the FCA register including small EMIs, the largest EMI population in Europe. |
| Key restrictions | Austria key restrictions is included in the £349 pass. | No interest on e-money, no deposit-taking; a SEMI cannot provide AIS or PIS. |
| Safeguarding | Austria safeguarding is included in the £349 pass. | 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. |
| Recent changes | 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. | FCA safeguarding reform live from 7 May 2026; HM Treasury payments-law reform expected later in 2026. |
| Difficulty rating | Austria difficulty rating is included in the £349 pass. | 4. Rigorous on financial crime and safeguarding, very large market. |
The two regimes differ on 9 of 10 tracked decision dimensions, including timeline to authorisation and local substance. Unlock the pass to see each figure with its source and verification date.
What changed recently
🇦🇹 Austria (verified 2026-07-03): 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.
🇬🇧 United Kingdom (verified 2026-07-03): FCA safeguarding reform live from 7 May 2026; HM Treasury payments-law reform expected later in 2026.
Quick answers
Who regulates e-money licensing in Austria and United Kingdom?
Austria: Financial Market Authority Austria (Finanzmarktaufsicht, FMA). United Kingdom: Financial Conduct Authority (FCA)..
What licence do you need in Austria compared with United Kingdom?
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 United Kingdom it is Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011.. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Austria vs United Kingdom 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-united-kingdom.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.