🇭🇷 Croatia vs 🇱🇮 Liechtenstein: e-money licensing compared
Decision context and regulator route
Croatia and Liechtenstein are commonly considered side by side for e-money authorisation. In Croatia the route is 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 overseen by Croatian National Bank (Hrvatska narodna banka, HNB); in Liechtenstein it is 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 under Financial Market Authority Liechtenstein (Finanzmarktaufsicht, FMA). The public licence and regulator fields below are open to everyone; the complete sourced comparison is included with access.
Croatia: verified 2026-09-01 · Liechtenstein: verified 2026-08-15
| Dimension |
🇭🇷 Croatia
partly open
Verified 2026-09-01
|
🇱🇮 Liechtenstein
partly open
Verified 2026-08-15
|
|---|---|---|
| Licence type | 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 | 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 | Croatian National Bank (Hrvatska narodna banka, HNB) | Financial Market Authority Liechtenstein (Finanzmarktaufsicht, FMA) |
| Capital requirement | Croatia capital requirement is included in the £349 pass. | Liechtenstein capital requirement is included in the £349 pass. |
| Timeline to authorisation | Croatia timeline to authorisation is included in the £349 pass. | Liechtenstein timeline to authorisation is included in the £349 pass. |
| Local substance | Croatia local substance is included in the £349 pass. | Liechtenstein local substance is included in the £349 pass. |
| Application cost | Croatia application cost is included in the £349 pass. | Liechtenstein application cost is included in the £349 pass. |
| Ongoing cost | Croatia ongoing cost is included in the £349 pass. | Liechtenstein ongoing cost is included in the £349 pass. |
| Passporting | Croatia passporting is included in the £349 pass. | Liechtenstein passporting is included in the £349 pass. |
| EMIs authorised | Croatia emis authorised is included in the £349 pass. | Liechtenstein emis authorised is included in the £349 pass. |
| Key restrictions | Croatia key restrictions is included in the £349 pass. | Liechtenstein key restrictions is included in the £349 pass. |
| Safeguarding | Croatia 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 | Croatia difficulty rating is included in the £349 pass. | Liechtenstein difficulty rating is included in the £349 pass. |
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What changed recently
🇭🇷 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.
🇱🇮 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 Croatia and Liechtenstein?
Croatia: Croatian National Bank (Hrvatska narodna banka, HNB). Liechtenstein: Financial Market Authority Liechtenstein (Finanzmarktaufsicht, FMA).
What licence do you need in Croatia compared with Liechtenstein?
In Croatia the authorisation route 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; 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 Croatia 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/croatia-vs-liechtenstein.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.