🇪🇪 Estonia vs 🇸🇪 Sweden: e-money licensing compared
On paper, Estonia's 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 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 answer the same question; in practice the detail decides it. The two regimes differ on 8 of 10 tracked decision dimensions, including timeline to authorisation and local substance. This page compares the two side by side: the identity columns are free, the decision figures are one pass away, and every cell shows when it was last checked.
Estonia: verified 2026-07-03 · Sweden: verified 2026-07-03
| Dimension |
🇪🇪 Estonia
partly open
Verified 2026-07-03
|
🇸🇪 Sweden
partly open
Verified 2026-07-03
|
|---|---|---|
| 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 locked. Unlock with the £349 pass. | Sweden capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Estonia timeline to authorisation is locked. Unlock with the £349 pass. | Sweden timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Estonia local substance is locked. Unlock with the £349 pass. | Sweden local substance is locked. Unlock with the £349 pass. |
| Application cost | Estonia application cost is locked. Unlock with the £349 pass. | Sweden application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Estonia ongoing cost is locked. Unlock with the £349 pass. | Sweden ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Estonia passporting is locked. Unlock with the £349 pass. | Sweden passporting is locked. Unlock with the £349 pass. |
| EMIs authorised | Estonia emis authorised is locked. Unlock with the £349 pass. | Sweden emis authorised is locked. Unlock with the £349 pass. |
| Key restrictions | Estonia key restrictions is locked. Unlock with the £349 pass. | Sweden key restrictions is locked. Unlock with the £349 pass. |
| Safeguarding | Estonia 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 | Estonia 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
🇪🇪 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.
🇸🇪 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 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.