🇩🇰 Denmark vs 🇱🇻 Latvia: e-money licensing compared
Choosing between Denmark and Latvia for a e-money licence starts with who you will answer to: Finanstilsynet (the Danish Financial Supervisory Authority / Danish FSA) on one side, Latvijas Banka (Bank of Latvia) - sole licensing/supervisory authority, having absorbed the former FCMC (Finansu un kapitala tirgus komisija) in 2023 on the other, via 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 and the Two tiers: (1) Licensed electronic money institution (full EMI licence) and (2) Registered electronic money institution (lighter-touch registration tier for smaller issuers, restricted to issuing e-money and providing only payment instrument issuance or money remittance) - both under the Law on Payment Services and Electronic Money (transposing EMD2) respectively. The two regimes differ on 8 of 10 tracked decision dimensions, including timeline to authorisation and local substance. Every figure behind the comparison carries a last-verified date and a primary source.
Denmark: verified 2026-07-03 · Latvia: verified 2026-07-03
| Dimension |
🇩🇰 Denmark
partly open
Verified 2026-07-03
|
🇱🇻 Latvia
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 | Two tiers: (1) Licensed electronic money institution (full EMI licence) and (2) Registered electronic money institution (lighter-touch registration tier for smaller issuers, restricted to issuing e-money and providing only payment instrument issuance or money remittance) - both under the Law on Payment Services and Electronic Money (transposing EMD2) |
| Regulator | Finanstilsynet (the Danish Financial Supervisory Authority / Danish FSA) | Latvijas Banka (Bank of Latvia) - sole licensing/supervisory authority, having absorbed the former FCMC (Finansu un kapitala tirgus komisija) in 2023 |
| Capital requirement | Denmark capital requirement is locked. Unlock with the £349 pass. | Latvia capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Denmark timeline to authorisation is locked. Unlock with the £349 pass. | Latvia timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Denmark local substance is locked. Unlock with the £349 pass. | Latvia local substance is locked. Unlock with the £349 pass. |
| Application cost | Denmark application cost is locked. Unlock with the £349 pass. | Latvia application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Denmark ongoing cost is locked. Unlock with the £349 pass. | Latvia ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Denmark passporting is locked. Unlock with the £349 pass. | Latvia passporting is locked. Unlock with the £349 pass. |
| EMIs authorised | Denmark emis authorised is locked. Unlock with the £349 pass. | Latvia emis authorised is locked. Unlock with the £349 pass. |
| Key restrictions | Denmark key restrictions is locked. Unlock with the £349 pass. | Latvia key restrictions is locked. Unlock with the £349 pass. |
| Safeguarding | Denmark safeguarding is locked. Unlock with the £349 pass. | Latvia 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. | Latvijas Banka continues actively granting new EMI licences (e.g. NorthernTech SIA, AP Operations SIA, Fibonatix in 2025-2026); Latvia is increasingly featured on fintech shortlists. As of 2025, 3 new companies received EMI licences. PSD3/PSR (final texts April 2026, OJ publication expected mid-to-late 2026) will apply directly (PSR) and require transposition (PSD3) within 18 months. |
| Difficulty rating | Denmark difficulty rating is locked. Unlock with the £349 pass. | Latvia difficulty rating is locked. Unlock with the £349 pass. |
The two regimes differ on 8 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.
🇱🇻 Latvia (verified 2026-07-03): Latvijas Banka continues actively granting new EMI licences (e.g. NorthernTech SIA, AP Operations SIA, Fibonatix in 2025-2026); Latvia is increasingly featured on fintech shortlists. As of 2025, 3 new companies received EMI licences. PSD3/PSR (final texts April 2026, OJ publication expected mid-to-late 2026) will apply directly (PSR) and require transposition (PSD3) within 18 months.
Quick answers
Who regulates e-money licensing in Denmark and Latvia?
Denmark: Finanstilsynet (the Danish Financial Supervisory Authority / Danish FSA). Latvia: Latvijas Banka (Bank of Latvia) - sole licensing/supervisory authority, having absorbed the former FCMC (Finansu un kapitala tirgus komisija) in 2023.
What licence do you need in Denmark compared with Latvia?
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 Latvia it is Two tiers: (1) Licensed electronic money institution (full EMI licence) and (2) Registered electronic money institution (lighter-touch registration tier for smaller issuers, restricted to issuing e-money and providing only payment instrument issuance or money remittance) - both under the Law on Payment Services and Electronic Money (transposing EMD2). The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Denmark vs Latvia 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-latvia.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.