🇩🇰 Denmark vs 🇸🇪 Sweden: e-money licensing compared
Decision context and regulator route
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 public fields are shown below, with the full dated and sourced comparison included with access.
Denmark: verified 2026-08-15 · Sweden: verified 2026-08-15
| Dimension |
🇩🇰 Denmark
partly open
Verified 2026-08-15
|
🇸🇪 Sweden
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 | 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 included in the £349 pass. | Sweden capital requirement is included in the £349 pass. |
| Timeline to authorisation | Denmark timeline to authorisation is included in the £349 pass. | Sweden timeline to authorisation is included in the £349 pass. |
| Local substance | Denmark local substance is included in the £349 pass. | Sweden local substance is included in the £349 pass. |
| Application cost | Denmark application cost is included in the £349 pass. | Sweden application cost is included in the £349 pass. |
| Ongoing cost | Denmark ongoing cost is included in the £349 pass. | Sweden ongoing cost is included in the £349 pass. |
| Passporting | Denmark passporting is included in the £349 pass. | Sweden passporting is included in the £349 pass. |
| EMIs authorised | Denmark emis authorised is included in the £349 pass. | Sweden emis authorised is included in the £349 pass. |
| Key restrictions | Denmark key restrictions is included in the £349 pass. | Sweden key restrictions is included in the £349 pass. |
| Safeguarding | Denmark safeguarding is included in the £349 pass. | Sweden 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. | Sweden 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.
🇸🇪 Sweden (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 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.