🇪🇪 Estonia vs 🇸🇪 Sweden: e-money licensing compared
Decision context and regulator route
Estonia's public 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 and Sweden's public 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 are set out side by side. Licence type, regulator and public recent-change notes are open; the full dated and sourced comparison is included with access.
Estonia: verified 2026-08-15 · Sweden: verified 2026-08-15
| Dimension |
🇪🇪 Estonia
partly open
Verified 2026-08-15
|
🇸🇪 Sweden
partly open
Verified 2026-08-15
|
|---|---|---|
| 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 | 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 | Finantsinspektsioon (Estonian Financial Supervision and Resolution Authority, FSA) | Finansinspektionen (FI, the Swedish Financial Supervisory Authority) |
| Capital requirement | Estonia capital requirement is included in the £349 pass. | Sweden capital requirement is included in the £349 pass. |
| Timeline to authorisation | Estonia timeline to authorisation is included in the £349 pass. | Sweden timeline to authorisation is included in the £349 pass. |
| Local substance | Estonia local substance is included in the £349 pass. | Sweden local substance is included in the £349 pass. |
| Application cost | Estonia application cost is included in the £349 pass. | Sweden application cost is included in the £349 pass. |
| Ongoing cost | Estonia ongoing cost is included in the £349 pass. | Sweden ongoing cost is included in the £349 pass. |
| Passporting | Estonia passporting is included in the £349 pass. | Sweden passporting is included in the £349 pass. |
| EMIs authorised | Estonia emis authorised is included in the £349 pass. | Sweden emis authorised is included in the £349 pass. |
| Key restrictions | Estonia key restrictions is included in the £349 pass. | Sweden key restrictions is included in the £349 pass. |
| Safeguarding | Estonia 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 | Estonia difficulty rating is included in the £349 pass. | Sweden difficulty rating is included in the £349 pass. |
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What changed recently
🇪🇪 Estonia (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 Estonia and Sweden?
Estonia: Finantsinspektsioon (Estonian Financial Supervision and Resolution Authority, FSA). Sweden: Finansinspektionen (FI, the Swedish Financial Supervisory Authority).
What licence do you need in Estonia compared with Sweden?
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 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 Estonia 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/estonia-vs-sweden.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.