🇨🇾 Cyprus vs 🇱🇺 Luxembourg: e-money licensing compared
Cyprus and Luxembourg take recognisably different routes to e-money authorisation. In Cyprus the route is the 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 overseen by Central Bank of Cyprus (CBC) - Licensing Section; in Luxembourg it is the Electronic Money Institution (EMI) authorisation under the Law of 10 November 2009 on payment services, as amended by the Law of 20 July 2018 (transposing PSD2); this same law also transposed EMD2's e-money provisions. No prominent separate small-EMI regime; EMIs are typically authorised as full EMIs given Luxembourg's fund/institutional client base. under Commission de Surveillance du Secteur Financier (CSSF). The two regimes differ on 7 of 10 tracked decision dimensions, including timeline to authorisation and local substance. The free columns below are open to everyone; the decision figures unlock with a pass, each one dated and sourced.
Cyprus: verified 2026-07-03 · Luxembourg: verified 2026-07-03
| Dimension |
🇨🇾 Cyprus
partly open
Verified 2026-07-03
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🇱🇺 Luxembourg
partly open
Verified 2026-07-03
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|---|---|---|
| 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 | Electronic Money Institution (EMI) authorisation under the Law of 10 November 2009 on payment services, as amended by the Law of 20 July 2018 (transposing PSD2); this same law also transposed EMD2's e-money provisions. No prominent separate small-EMI regime; EMIs are typically authorised as full EMIs given Luxembourg's fund/institutional client base. |
| Regulator | Central Bank of Cyprus (CBC) - Licensing Section | Commission de Surveillance du Secteur Financier (CSSF) |
| Capital requirement | Cyprus capital requirement is locked. Unlock with the £349 pass. | Luxembourg capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Cyprus timeline to authorisation is locked. Unlock with the £349 pass. | Luxembourg timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Cyprus local substance is locked. Unlock with the £349 pass. | Luxembourg local substance is locked. Unlock with the £349 pass. |
| Application cost | Cyprus application cost is locked. Unlock with the £349 pass. | Luxembourg application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Cyprus ongoing cost is locked. Unlock with the £349 pass. | Luxembourg ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Cyprus passporting is locked. Unlock with the £349 pass. | Luxembourg passporting is locked. Unlock with the £349 pass. |
| EMIs authorised | Cyprus emis authorised is locked. Unlock with the £349 pass. | Luxembourg emis authorised is locked. Unlock with the £349 pass. |
| Key restrictions | Cyprus key restrictions is locked. Unlock with the £349 pass. | Luxembourg key restrictions is locked. Unlock with the £349 pass. |
| Safeguarding | Cyprus safeguarding is locked. Unlock with the £349 pass. | Luxembourg 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/PSR: EU agreement reached Nov 2025, texts published April 2026, repealing EMD2 with EMIs becoming a 'payment institution authorised to issue e-money' sub-category; Luxembourg's payment services law will need amendment within the transposition window, with transitional relief (24 months, extendable to 30) for existing EMD2-authorised entities. CSSF also active on crypto/e-money-token overlap (MiCA e-money token issuer guidance). |
| Difficulty rating | Cyprus difficulty rating is locked. Unlock with the £349 pass. | Luxembourg 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).
🇱🇺 Luxembourg (verified 2026-07-03): PSD3/PSR: EU agreement reached Nov 2025, texts published April 2026, repealing EMD2 with EMIs becoming a 'payment institution authorised to issue e-money' sub-category; Luxembourg's payment services law will need amendment within the transposition window, with transitional relief (24 months, extendable to 30) for existing EMD2-authorised entities. CSSF also active on crypto/e-money-token overlap (MiCA e-money token issuer guidance).
Quick answers
Who regulates e-money licensing in Cyprus and Luxembourg?
Cyprus: Central Bank of Cyprus (CBC) - Licensing Section. Luxembourg: Commission de Surveillance du Secteur Financier (CSSF).
What licence do you need in Cyprus compared with Luxembourg?
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 Luxembourg it is Electronic Money Institution (EMI) authorisation under the Law of 10 November 2009 on payment services, as amended by the Law of 20 July 2018 (transposing PSD2); this same law also transposed EMD2's e-money provisions. No prominent separate small-EMI regime; EMIs are typically authorised as full EMIs given Luxembourg's fund/institutional client base.. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Cyprus vs Luxembourg 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-luxembourg.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.