🇨🇾 Cyprus vs 🇪🇸 Spain: e-money licensing compared
Cyprus and Spain 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 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 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 · Spain: verified 2026-07-03
| Dimension |
🇨🇾 Cyprus
partly open
Verified 2026-07-03
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🇪🇸 Spain
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 | 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 locked. Unlock with the £349 pass. | Spain capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Cyprus timeline to authorisation is locked. Unlock with the £349 pass. | Spain timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Cyprus local substance is locked. Unlock with the £349 pass. | Spain local substance is locked. Unlock with the £349 pass. |
| Application cost | Cyprus application cost is locked. Unlock with the £349 pass. | Spain application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Cyprus ongoing cost is locked. Unlock with the £349 pass. | Spain ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Cyprus passporting is locked. Unlock with the £349 pass. | Spain passporting is locked. Unlock with the £349 pass. |
| EMIs authorised | Cyprus emis authorised is locked. Unlock with the £349 pass. | Spain emis authorised is locked. Unlock with the £349 pass. |
| Key restrictions | Cyprus key restrictions is locked. Unlock with the £349 pass. | Spain key restrictions is locked. Unlock with the £349 pass. |
| Safeguarding | Cyprus safeguarding is locked. Unlock with the £349 pass. | Spain 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 final texts published 23 April 2026, undergoing legal-linguistic review, OJ publication expected June/July 2026 (risk of slipping to September). Analysis flags that Spain's separate payment-institution and e-money statutes (despite an integrated supervisor) will likely require a more structural legislative overhaul than in peer states to merge into PSD3/PSR's single rulebook. |
| Difficulty rating | Cyprus difficulty rating is locked. Unlock with the £349 pass. | Spain 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).
🇪🇸 Spain (verified 2026-07-03): PSD3/PSR final texts published 23 April 2026, undergoing legal-linguistic review, OJ publication expected June/July 2026 (risk of slipping to September). Analysis flags that Spain's separate payment-institution and e-money statutes (despite an integrated supervisor) will likely require a more structural legislative overhaul than in peer states to merge into PSD3/PSR's single rulebook.
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.