🇧🇪 Belgium vs 🇱🇻 Latvia: e-money licensing compared
Decision context and regulator route
Belgium and Latvia are commonly considered side by side for e-money authorisation. In Belgium the route is the 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 overseen by National Bank of Belgium (Banque Nationale de Belgique / Nationale Bank van Belgie, NBB/BNB); in Latvia it is the 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) under Latvijas Banka (Bank of Latvia) - sole licensing/supervisory authority, having absorbed the former FCMC (Finansu un kapitala tirgus komisija) in 2023. The public licence and regulator fields below are open to everyone; the complete sourced comparison is included with access.
Belgium: verified 2026-11-01 · Latvia: verified 2026-08-15
| Dimension |
🇧🇪 Belgium
partly open
Verified 2026-11-01
|
🇱🇻 Latvia
partly open
Verified 2026-08-15
|
|---|---|---|
| Licence type | 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 | 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) |
| Regulator | National Bank of Belgium (Banque Nationale de Belgique / Nationale Bank van Belgie, NBB/BNB) | Latvijas Banka (Bank of Latvia) - sole licensing/supervisory authority, having absorbed the former FCMC (Finansu un kapitala tirgus komisija) in 2023 |
| Capital requirement | Belgium capital requirement is included in the £349 pass. | Latvia capital requirement is included in the £349 pass. |
| Timeline to authorisation | Belgium timeline to authorisation is included in the £349 pass. | Latvia timeline to authorisation is included in the £349 pass. |
| Local substance | Belgium local substance is included in the £349 pass. | Latvia local substance is included in the £349 pass. |
| Application cost | Belgium application cost is included in the £349 pass. | Latvia application cost is included in the £349 pass. |
| Ongoing cost | Belgium ongoing cost is included in the £349 pass. | Latvia ongoing cost is included in the £349 pass. |
| Passporting | Belgium passporting is included in the £349 pass. | Latvia passporting is included in the £349 pass. |
| EMIs authorised | Belgium emis authorised is included in the £349 pass. | Latvia emis authorised is included in the £349 pass. |
| Key restrictions | Belgium key restrictions is included in the £349 pass. | Latvia key restrictions is included in the £349 pass. |
| Safeguarding | Belgium safeguarding is included in the £349 pass. | Latvia safeguarding is included in the £349 pass. |
| Recent changes | PSD3 and the Payment Services Regulation would merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. On 1 November 2026, both files were awaiting the Council's first-reading position, with an indicative European Parliament plenary sitting on 14 December 2026. No adopted act or Official Journal publication was identified. The negotiated Council text requires national transposition and application after 21 months, allows existing EMIs to continue until 27 months after entry into force, and permits an exceptional extension of no more than three months where the institution supplied the required information but the authority could not process it in time. | Latvijas Banka continued granting new EMI licences during 2025 and 2026. 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 | Belgium difficulty rating is included in the £349 pass. | Latvia difficulty rating is included in the £349 pass. |
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What changed recently
🇧🇪 Belgium (verified 2026-11-01): PSD3 and the Payment Services Regulation would merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. On 1 November 2026, both files were awaiting the Council's first-reading position, with an indicative European Parliament plenary sitting on 14 December 2026. No adopted act or Official Journal publication was identified. The negotiated Council text requires national transposition and application after 21 months, allows existing EMIs to continue until 27 months after entry into force, and permits an exceptional extension of no more than three months where the institution supplied the required information but the authority could not process it in time.
🇱🇻 Latvia (verified 2026-08-15): Latvijas Banka continued granting new EMI licences during 2025 and 2026. 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 Belgium and Latvia?
Belgium: National Bank of Belgium (Banque Nationale de Belgique / Nationale Bank van Belgie, NBB/BNB). Latvia: Latvijas Banka (Bank of Latvia) - sole licensing/supervisory authority, having absorbed the former FCMC (Finansu un kapitala tirgus komisija) in 2023.
What licence do you need in Belgium compared with Latvia?
In Belgium the authorisation route is 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; in Latvia it is 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). The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Belgium vs Latvia comparison?
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Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.