🇨🇾 Cyprus vs 🇩🇪 Germany: e-money licensing compared
On paper, Cyprus's Electronic Money Institution (EMI) authorisation under The Electronic Money Laws of 2012-2018 and The Provision and Use of Payment Services and Access to Payment Systems Laws of 2018 to 2025 (transposing EMD2/PSD2); a Small EMI / exempt tier also exists under the same framework for issuers below EMD2 thresholds and Germany's E-Geld-Institut under the ZAG. answer the same question; in practice the detail decides it. The two regimes differ on 7 of 10 tracked decision dimensions, including timeline to authorisation and local substance. This page compares the two side by side: the identity columns are free, the decision figures are one pass away, and every cell shows when it was last checked.
Cyprus: verified 2026-07-03 · Germany: verified 2026-07-03
| Dimension |
🇨🇾 Cyprus
partly open
Verified 2026-07-03
|
🇩🇪 Germany
partly open
Verified 2026-07-03
|
|---|---|---|
| Licence type | Electronic Money Institution (EMI) authorisation under The Electronic Money Laws of 2012-2018 and The Provision and Use of Payment Services and Access to Payment Systems Laws of 2018 to 2025 (transposing EMD2/PSD2); a Small EMI / exempt tier also exists under the same framework for issuers below EMD2 thresholds | E-Geld-Institut under the ZAG. |
| Regulator | Central Bank of Cyprus (CBC) - Licensing Section | BaFin, with the Deutsche Bundesbank. |
| Capital requirement | Cyprus capital requirement is locked. Unlock with the £349 pass. | Germany capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Cyprus timeline to authorisation is locked. Unlock with the £349 pass. | Germany timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Cyprus local substance is locked. Unlock with the £349 pass. | Germany local substance is locked. Unlock with the £349 pass. |
| Application cost | Cyprus application cost is locked. Unlock with the £349 pass. | Germany application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Cyprus ongoing cost is locked. Unlock with the £349 pass. | Germany ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Cyprus passporting is locked. Unlock with the £349 pass. | Germany passporting is locked. Unlock with the £349 pass. |
| EMIs authorised | Cyprus emis authorised is locked. Unlock with the £349 pass. | Germany emis authorised is locked. Unlock with the £349 pass. |
| Key restrictions | Cyprus key restrictions is locked. Unlock with the £349 pass. | Germany key restrictions is locked. Unlock with the £349 pass. |
| Safeguarding | Cyprus safeguarding is locked. Unlock with the £349 pass. | Germany safeguarding is locked. Unlock with the £349 pass. |
| Recent changes | CBC issued three new directives effective 2025: the Electronic Money Institutions Directive 2025 (authorisation/prudential supervision), a Directive on Internal Organisation and Governance of EMIs, and a Directive on Assessment of Suitability of board/management members, materially tightening governance and fit-and-proper requirements ahead of PSD3/PSR. EU political agreement on PSD3/PSR was reached Nov 2025, texts published April 2026; EMD2 will be repealed and EMIs folded into the payment institution framework as a sub-category, with existing EMD2 licences remaining valid for up to 24 months post-entry-into-force (extendable to 30 months at national regulator discretion). | PSD3 and PSR merge the payment institution and EMI regimes into one payment institution licence that can issue e-money. Final texts published 23 Apr 2026, OJ expected mid to late 2026, PSR applies about 20 days after publication, PSD3 transposition within 18 months (applicability ~Q2/Q3 2028). Existing EMIs are grandfathered but must update their file. |
| Difficulty rating | Cyprus difficulty rating is locked. Unlock with the £349 pass. | Germany difficulty rating is locked. Unlock with the £349 pass. |
The two regimes differ on 7 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
🇨🇾 Cyprus (verified 2026-07-03): CBC issued three new directives effective 2025: the Electronic Money Institutions Directive 2025 (authorisation/prudential supervision), a Directive on Internal Organisation and Governance of EMIs, and a Directive on Assessment of Suitability of board/management members, materially tightening governance and fit-and-proper requirements ahead of PSD3/PSR. EU political agreement on PSD3/PSR was reached Nov 2025, texts published April 2026; EMD2 will be repealed and EMIs folded into the payment institution framework as a sub-category, with existing EMD2 licences remaining valid for up to 24 months post-entry-into-force (extendable to 30 months at national regulator discretion).
🇩🇪 Germany (verified 2026-07-03): PSD3 and PSR merge the payment institution and EMI regimes into one payment institution licence that can issue e-money. Final texts published 23 Apr 2026, OJ expected mid to late 2026, PSR applies about 20 days after publication, PSD3 transposition within 18 months (applicability ~Q2/Q3 2028). Existing EMIs are grandfathered but must update their file.
Quick answers
Who regulates e-money licensing in Cyprus and Germany?
Cyprus: Central Bank of Cyprus (CBC) - Licensing Section. Germany: BaFin, with the Deutsche Bundesbank..
What licence do you need in Cyprus compared with Germany?
In Cyprus the authorisation route is Electronic Money Institution (EMI) authorisation under The Electronic Money Laws of 2012-2018 and The Provision and Use of Payment Services and Access to Payment Systems Laws of 2018 to 2025 (transposing EMD2/PSD2); a Small EMI / exempt tier also exists under the same framework for issuers below EMD2 thresholds; in Germany it is E-Geld-Institut under the ZAG.. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Cyprus vs Germany 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/cyprus-vs-germany.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.