🇨🇾 Cyprus vs 🇩🇪 Germany: e-money licensing compared
Decision context and regulator route
Cyprus's public 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 public E-Geld-Institut under the ZAG. are set out side by side. Licence type, regulator and public recent-change notes are open; the full dated and sourced comparison is included with access.
Cyprus: verified 2026-08-15 · Germany: verified 2026-08-15
| Dimension |
🇨🇾 Cyprus
partly open
Verified 2026-08-15
|
🇩🇪 Germany
partly open
Verified 2026-08-15
|
|---|---|---|
| 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 included in the £349 pass. | Germany capital requirement is included in the £349 pass. |
| Timeline to authorisation | Cyprus timeline to authorisation is included in the £349 pass. | Germany timeline to authorisation is included in the £349 pass. |
| Local substance | Cyprus local substance is included in the £349 pass. | Germany local substance is included in the £349 pass. |
| Application cost | Cyprus application cost is included in the £349 pass. | Germany application cost is included in the £349 pass. |
| Ongoing cost | Cyprus ongoing cost is included in the £349 pass. | Germany ongoing cost is included in the £349 pass. |
| Passporting | Cyprus passporting is included in the £349 pass. | Germany passporting is included in the £349 pass. |
| EMIs authorised | Cyprus emis authorised is included in the £349 pass. | Germany emis authorised is included in the £349 pass. |
| Key restrictions | Cyprus key restrictions is included in the £349 pass. | Germany key restrictions is included in the £349 pass. |
| Safeguarding | Cyprus safeguarding is included in the £349 pass. | Germany safeguarding is included in the £349 pass. |
| Recent changes | The Central Bank of Cyprus issued new 2025 EMI authorisation, governance and suitability directives. 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. | 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 | Cyprus difficulty rating is included in the £349 pass. | Germany difficulty rating is included in the £349 pass. |
Unlock the pass to see each gated figure with its source and verification date.
What changed recently
🇨🇾 Cyprus (verified 2026-08-15): The Central Bank of Cyprus issued new 2025 EMI authorisation, governance and suitability directives. 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.
🇩🇪 Germany (verified 2026-08-15): 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 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.