🇩🇰 Denmark vs 🇪🇪 Estonia: e-money licensing compared
Denmark and Estonia take recognisably different routes to 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 two regimes differ on 9 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.
Denmark: verified 2026-07-03 · Estonia: verified 2026-07-03
| Dimension |
🇩🇰 Denmark
partly open
Verified 2026-07-03
|
🇪🇪 Estonia
partly open
Verified 2026-07-03
|
|---|---|---|
| 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 locked. Unlock with the £349 pass. | Estonia capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Denmark timeline to authorisation is locked. Unlock with the £349 pass. | Estonia timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Denmark local substance is locked. Unlock with the £349 pass. | Estonia local substance is locked. Unlock with the £349 pass. |
| Application cost | Denmark application cost is locked. Unlock with the £349 pass. | Estonia application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Denmark ongoing cost is locked. Unlock with the £349 pass. | Estonia ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Denmark passporting is locked. Unlock with the £349 pass. | Estonia passporting is locked. Unlock with the £349 pass. |
| EMIs authorised | Denmark emis authorised is locked. Unlock with the £349 pass. | Estonia emis authorised is locked. Unlock with the £349 pass. |
| Key restrictions | Denmark key restrictions is locked. Unlock with the £349 pass. | Estonia key restrictions is locked. Unlock with the £349 pass. |
| Safeguarding | Denmark safeguarding is locked. Unlock with the £349 pass. | Estonia safeguarding is locked. Unlock with the £349 pass. |
| Recent changes | PSD3 and the PSR will merge the payment institution and EMI regimes into one licence that can issue e-money. Final texts published 23 April 2026, applicability targeted around 2028; existing EMIs are grandfathered but must update their file. | PSD3 and the PSR will merge the payment institution and EMI regimes into one licence that can issue e-money. Final texts published 23 April 2026, applicability targeted around 2028; existing EMIs are grandfathered but must update their file. |
| Difficulty rating | Denmark difficulty rating is locked. Unlock with the £349 pass. | Estonia difficulty rating is locked. Unlock with the £349 pass. |
The two regimes differ on 9 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
🇩🇰 Denmark (verified 2026-07-03): PSD3 and the PSR will merge the payment institution and EMI regimes into one licence that can issue e-money. Final texts published 23 April 2026, applicability targeted around 2028; existing EMIs are grandfathered but must update their file.
🇪🇪 Estonia (verified 2026-07-03): PSD3 and the PSR will merge the payment institution and EMI regimes into one licence that can issue e-money. Final texts published 23 April 2026, applicability targeted around 2028; existing EMIs are grandfathered but must update their file.
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.