🇨🇾 Cyprus vs 🇪🇸 Spain: e-money licensing compared
Decision context and regulator route
Cyprus and Spain are commonly considered side by side for 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 Spain it is the Entidad de Dinero Electronico (EDE), authorised under Ley 21/2011, de 26 de julio, de dinero electronico, and Real Decreto 778/2012 (as amended by Real Decreto 736/2019). Spain recognises 'entidades de dinero electronico hibridas' (hybrid EMIs) and an exemption/light regime under art. 14 of Real Decreto-ley 19/2018 for small-scale e-money issuers below activity thresholds, analogous to a 'small EMI' tier. under Banco de Espana (Bank of Spain). The public licence and regulator fields below are open to everyone; the complete sourced comparison is included with access.
Cyprus: verified 2026-08-15 · Spain: verified 2026-08-15
| Dimension |
🇨🇾 Cyprus
partly open
Verified 2026-08-15
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🇪🇸 Spain
partly open
Verified 2026-08-15
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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 | Entidad de Dinero Electronico (EDE), authorised under Ley 21/2011, de 26 de julio, de dinero electronico, and Real Decreto 778/2012 (as amended by Real Decreto 736/2019). Spain recognises 'entidades de dinero electronico hibridas' (hybrid EMIs) and an exemption/light regime under art. 14 of Real Decreto-ley 19/2018 for small-scale e-money issuers below activity thresholds, analogous to a 'small EMI' tier. |
| Regulator | Central Bank of Cyprus (CBC) - Licensing Section | Banco de Espana (Bank of Spain) |
| Capital requirement | Cyprus capital requirement is included in the £349 pass. | Spain capital requirement is included in the £349 pass. |
| Timeline to authorisation | Cyprus timeline to authorisation is included in the £349 pass. | Spain timeline to authorisation is included in the £349 pass. |
| Local substance | Cyprus local substance is included in the £349 pass. | Spain local substance is included in the £349 pass. |
| Application cost | Cyprus application cost is included in the £349 pass. | Spain application cost is included in the £349 pass. |
| Ongoing cost | Cyprus ongoing cost is included in the £349 pass. | Spain ongoing cost is included in the £349 pass. |
| Passporting | Cyprus passporting is included in the £349 pass. | Spain passporting is included in the £349 pass. |
| EMIs authorised | Cyprus emis authorised is included in the £349 pass. | Spain emis authorised is included in the £349 pass. |
| Key restrictions | Cyprus key restrictions is included in the £349 pass. | Spain key restrictions is included in the £349 pass. |
| Safeguarding | Cyprus safeguarding is included in the £349 pass. | Spain 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. | Spain will need to align its separate payment-institution and e-money statutes with the single PSD3 framework. 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. | Spain difficulty rating is included in the £349 pass. |
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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.
🇪🇸 Spain (verified 2026-08-15): Spain will need to align its separate payment-institution and e-money statutes with the single PSD3 framework. 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 Spain?
Cyprus: Central Bank of Cyprus (CBC) - Licensing Section. Spain: Banco de Espana (Bank of Spain).
What licence do you need in Cyprus compared with Spain?
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 Spain it is Entidad de Dinero Electronico (EDE), authorised under Ley 21/2011, de 26 de julio, de dinero electronico, and Real Decreto 778/2012 (as amended by Real Decreto 736/2019). Spain recognises 'entidades de dinero electronico hibridas' (hybrid EMIs) and an exemption/light regime under art. 14 of Real Decreto-ley 19/2018 for small-scale e-money issuers below activity thresholds, analogous to a 'small EMI' tier.. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Cyprus vs Spain 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-spain.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.