🇧🇪 Belgium vs 🇬🇧 United Kingdom: e-money licensing compared
Decision context and regulator route
Belgium and United Kingdom 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 United Kingdom it is the Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011. under Financial Conduct Authority (FCA).. The public licence and regulator fields below are open to everyone; the complete sourced comparison is included with access.
Belgium: verified 2026-10-01 · United Kingdom: verified 2026-10-01
| Dimension |
🇧🇪 Belgium
partly open
Verified 2026-10-01
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🇬🇧 United Kingdom
Free in full
Verified 2026-10-01
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|---|---|---|
| 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 | Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011. |
| Regulator | National Bank of Belgium (Banque Nationale de Belgique / Nationale Bank van Belgie, NBB/BNB) | Financial Conduct Authority (FCA). |
| Capital requirement | Belgium 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 | Belgium 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 | Belgium local substance is included in the £349 pass. | UK entity with UK mind and management, MLRO, adequate local staffing. |
| Application cost | Belgium application cost is included in the £349 pass. | FCA application fee GBP 5,640 for an authorised EMI (Category 5) or GBP 1,130 for a small EMI (Category 3). Professional and implementation costs are project-specific. |
| Ongoing cost | Belgium ongoing cost is included in the £349 pass. | FCA periodic fees, annual safeguarding audit, compliance headcount. |
| Passporting | Belgium passporting is included in the £349 pass. | None after Brexit, no EEA passport. |
| EMIs authorised | Belgium 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 | Belgium key restrictions is included in the £349 pass. | No interest on e-money, no deposit-taking; a SEMI cannot provide AIS or PIS. |
| Safeguarding | Belgium 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 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 October 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. | HM Treasury's Modernising Payment Services Regulation consultation, published 14 July 2026 and open until 6 October 2026, proposes modernising the Payment Services Regulations 2017 and Electronic Money Regulations 2011, including moving detailed firm-facing requirements into the FCA rulebook and adapting the framework for tokenised deposits and UK qualifying stablecoins. |
| Difficulty rating | Belgium difficulty rating is included in the £349 pass. | 4. Rigorous on financial crime and safeguarding, very large market. |
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What changed recently
🇧🇪 Belgium (verified 2026-10-01): 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 October 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.
🇬🇧 United Kingdom (verified 2026-10-01): HM Treasury's Modernising Payment Services Regulation consultation, published 14 July 2026 and open until 6 October 2026, proposes modernising the Payment Services Regulations 2017 and Electronic Money Regulations 2011, including moving detailed firm-facing requirements into the FCA rulebook and adapting the framework for tokenised deposits and UK qualifying stablecoins.
Quick answers
Who regulates e-money licensing in Belgium and United Kingdom?
Belgium: National Bank of Belgium (Banque Nationale de Belgique / Nationale Bank van Belgie, NBB/BNB). United Kingdom: Financial Conduct Authority (FCA)..
What licence do you need in Belgium compared with United Kingdom?
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 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 Belgium 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/belgium-vs-united-kingdom.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.