🇩🇰 Denmark vs 🇪🇪 Estonia: e-money licensing compared
Decision context and regulator route
Denmark and Estonia are commonly considered side by side for e-money authorisation. In Denmark the route is the Tilladelse som e-pengeinstitut under Lov om betalinger (Payment Services Act, LBK nr 1013 af 21/08/2024), transposing EMD2; a 'begraenset tilladelse til at udstede elektroniske penge' (limited/small e-money licence) exemption tier also exists for smaller-scale issuers overseen by Finanstilsynet (the Danish Financial Supervisory Authority / Danish FSA); in Estonia it is the Operating licence (tegevusluba) for e-money institutions under the Payment Institutions and E-money Institutions Act (Makse- ja e-raha asutuste seadus, MERAS), Estonia's EMD2 transposition under Finantsinspektsioon (Estonian Financial Supervision and Resolution Authority, FSA). The public licence and regulator fields below are open to everyone; the complete sourced comparison is included with access.
Denmark: verified 2026-08-15 · Estonia: verified 2026-08-15
| Dimension |
🇩🇰 Denmark
partly open
Verified 2026-08-15
|
🇪🇪 Estonia
partly open
Verified 2026-08-15
|
|---|---|---|
| Licence type | Tilladelse som e-pengeinstitut under Lov om betalinger (Payment Services Act, LBK nr 1013 af 21/08/2024), transposing EMD2; a 'begraenset tilladelse til at udstede elektroniske penge' (limited/small e-money licence) exemption tier also exists for smaller-scale issuers | Operating licence (tegevusluba) for e-money institutions under the Payment Institutions and E-money Institutions Act (Makse- ja e-raha asutuste seadus, MERAS), Estonia's EMD2 transposition |
| Regulator | Finanstilsynet (the Danish Financial Supervisory Authority / Danish FSA) | Finantsinspektsioon (Estonian Financial Supervision and Resolution Authority, FSA) |
| Capital requirement | Denmark capital requirement is included in the £349 pass. | Estonia capital requirement is included in the £349 pass. |
| Timeline to authorisation | Denmark timeline to authorisation is included in the £349 pass. | Estonia timeline to authorisation is included in the £349 pass. |
| Local substance | Denmark local substance is included in the £349 pass. | Estonia local substance is included in the £349 pass. |
| Application cost | Denmark application cost is included in the £349 pass. | Estonia application cost is included in the £349 pass. |
| Ongoing cost | Denmark ongoing cost is included in the £349 pass. | Estonia ongoing cost is included in the £349 pass. |
| Passporting | Denmark passporting is included in the £349 pass. | Estonia passporting is included in the £349 pass. |
| EMIs authorised | Denmark emis authorised is included in the £349 pass. | Estonia emis authorised is included in the £349 pass. |
| Key restrictions | Denmark key restrictions is included in the £349 pass. | Estonia key restrictions is included in the £349 pass. |
| Safeguarding | Denmark safeguarding is included in the £349 pass. | Estonia safeguarding is included in the £349 pass. |
| Recent changes | 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 | Denmark difficulty rating is included in the £349 pass. | Estonia difficulty rating is included in the £349 pass. |
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What changed recently
🇩🇰 Denmark (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.
🇪🇪 Estonia (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 Denmark and Estonia?
Denmark: Finanstilsynet (the Danish Financial Supervisory Authority / Danish FSA). Estonia: Finantsinspektsioon (Estonian Financial Supervision and Resolution Authority, FSA).
What licence do you need in Denmark compared with Estonia?
In Denmark the authorisation route is Tilladelse som e-pengeinstitut under Lov om betalinger (Payment Services Act, LBK nr 1013 af 21/08/2024), transposing EMD2; a 'begraenset tilladelse til at udstede elektroniske penge' (limited/small e-money licence) exemption tier also exists for smaller-scale issuers; in Estonia it is Operating licence (tegevusluba) for e-money institutions under the Payment Institutions and E-money Institutions Act (Makse- ja e-raha asutuste seadus, MERAS), Estonia's EMD2 transposition. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Denmark vs Estonia 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/denmark-vs-estonia.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.