🇪🇪 Estonia vs 🇱🇻 Latvia: e-money licensing compared
Estonia and Latvia take recognisably different routes to e-money authorisation. In Estonia the route 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 overseen by Finantsinspektsioon (Estonian Financial Supervision and Resolution Authority, FSA); in Latvia it is 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) under Latvijas Banka (Bank of Latvia) - sole licensing/supervisory authority, having absorbed the former FCMC (Finansu un kapitala tirgus komisija) in 2023. The two regimes differ on 8 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.
Estonia: verified 2026-07-03 · Latvia: verified 2026-07-03
| Dimension |
🇪🇪 Estonia
partly open
Verified 2026-07-03
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🇱🇻 Latvia
partly open
Verified 2026-07-03
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|---|---|---|
| Licence type | 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 | 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 | Finantsinspektsioon (Estonian Financial Supervision and Resolution Authority, FSA) | Latvijas Banka (Bank of Latvia) - sole licensing/supervisory authority, having absorbed the former FCMC (Finansu un kapitala tirgus komisija) in 2023 |
| Capital requirement | Estonia capital requirement is locked. Unlock with the £349 pass. | Latvia capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Estonia timeline to authorisation is locked. Unlock with the £349 pass. | Latvia timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Estonia local substance is locked. Unlock with the £349 pass. | Latvia local substance is locked. Unlock with the £349 pass. |
| Application cost | Estonia application cost is locked. Unlock with the £349 pass. | Latvia application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Estonia ongoing cost is locked. Unlock with the £349 pass. | Latvia ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Estonia passporting is locked. Unlock with the £349 pass. | Latvia passporting is locked. Unlock with the £349 pass. |
| EMIs authorised | Estonia emis authorised is locked. Unlock with the £349 pass. | Latvia emis authorised is locked. Unlock with the £349 pass. |
| Key restrictions | Estonia key restrictions is locked. Unlock with the £349 pass. | Latvia key restrictions is locked. Unlock with the £349 pass. |
| Safeguarding | Estonia 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 | Estonia 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
🇪🇪 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.
🇱🇻 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 Estonia and Latvia?
Estonia: Finantsinspektsioon (Estonian Financial Supervision and Resolution Authority, 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 Estonia compared with Latvia?
In Estonia the authorisation route 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; 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 Estonia 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/estonia-vs-latvia.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.