🇩🇰 Denmark vs 🇸🇪 Sweden: e-money licensing compared
Choosing between Denmark and Sweden for a e-money licence starts with who you will answer to: Finanstilsynet (the Danish Financial Supervisory Authority / Danish FSA) on one side, Finansinspektionen (FI, the Swedish Financial Supervisory Authority) 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 Tillstand att ge ut elektroniska pengar (e-money institution licence) under lagen (2011:755) om elektroniska pengar, transposing EMD2; a lighter-touch registration tier ('registrerad utgivare av elektroniska pengar' for small-scale issuers below EMD2 thresholds) also exists 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 · Sweden: verified 2026-07-03
| Dimension |
🇩🇰 Denmark
partly open
Verified 2026-07-03
|
🇸🇪 Sweden
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 | Tillstand att ge ut elektroniska pengar (e-money institution licence) under lagen (2011:755) om elektroniska pengar, transposing EMD2; a lighter-touch registration tier ('registrerad utgivare av elektroniska pengar' for small-scale issuers below EMD2 thresholds) also exists |
| Regulator | Finanstilsynet (the Danish Financial Supervisory Authority / Danish FSA) | Finansinspektionen (FI, the Swedish Financial Supervisory Authority) |
| Capital requirement | Denmark capital requirement is locked. Unlock with the £349 pass. | Sweden capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Denmark timeline to authorisation is locked. Unlock with the £349 pass. | Sweden timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Denmark local substance is locked. Unlock with the £349 pass. | Sweden local substance is locked. Unlock with the £349 pass. |
| Application cost | Denmark application cost is locked. Unlock with the £349 pass. | Sweden application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Denmark ongoing cost is locked. Unlock with the £349 pass. | Sweden ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Denmark passporting is locked. Unlock with the £349 pass. | Sweden passporting is locked. Unlock with the £349 pass. |
| EMIs authorised | Denmark emis authorised is locked. Unlock with the £349 pass. | Sweden emis authorised is locked. Unlock with the £349 pass. |
| Key restrictions | Denmark key restrictions is locked. Unlock with the £349 pass. | Sweden key restrictions is locked. Unlock with the £349 pass. |
| Safeguarding | Denmark safeguarding is locked. Unlock with the £349 pass. | Sweden 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. | Sweden 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.
🇸🇪 Sweden (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 Sweden?
Denmark: Finanstilsynet (the Danish Financial Supervisory Authority / Danish FSA). Sweden: Finansinspektionen (FI, the Swedish Financial Supervisory Authority).
What licence do you need in Denmark compared with Sweden?
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 Sweden it is Tillstand att ge ut elektroniska pengar (e-money institution licence) under lagen (2011:755) om elektroniska pengar, transposing EMD2; a lighter-touch registration tier ('registrerad utgivare av elektroniska pengar' for small-scale issuers below EMD2 thresholds) also exists. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Denmark vs Sweden 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-sweden.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.