🇪🇪 Estonia vs 🇬🇧 United Kingdom: 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 United Kingdom's public Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011. 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 2026-10-01 · United Kingdom: verified 2026-10-01
| Dimension |
🇪🇪 Estonia
partly open
Verified 2026-10-01
|
🇬🇧 United Kingdom
Free in full
Verified 2026-10-01
|
|---|---|---|
| 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 | Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011. |
| Regulator | Finantsinspektsioon (Estonian Financial Supervision and Resolution Authority, FSA) | Financial Conduct Authority (FCA). |
| Capital requirement | Estonia capital requirement is included in the £349 pass. | AEMI GBP 350,000 initial plus own funds 2% of average outstanding e-money. SEMI no initial capital, capped below EUR 5m outstanding. |
| Timeline to authorisation | Estonia timeline to authorisation is included in the £349 pass. | About 6 to 12 months including pre-application (statutory 3 months from a complete application). |
| Local substance | Estonia local substance is included in the £349 pass. | UK entity with UK mind and management, MLRO, adequate local staffing. |
| Application cost | Estonia application cost is included in the £349 pass. | FCA application fee GBP 5,640 for an authorised EMI (Category 5) or GBP 1,130 for a small EMI (Category 3). Professional and implementation costs are project-specific. |
| Ongoing cost | Estonia ongoing cost is included in the £349 pass. | FCA periodic fees, annual safeguarding audit, compliance headcount. |
| Passporting | Estonia passporting is included in the £349 pass. | None after Brexit, no EEA passport. |
| EMIs authorised | Estonia emis authorised is included in the £349 pass. | Around 338 e-money firms on the FCA register including small EMIs, the largest EMI population in Europe. |
| Key restrictions | Estonia key restrictions is included in the £349 pass. | No interest on e-money, no deposit-taking; a SEMI cannot provide AIS or PIS. |
| Safeguarding | Estonia safeguarding is included in the £349 pass. | Segregation or insurance or comparable guarantee. FCA Supplementary safeguarding regime (Policy Statement PS25/12, published 7 August 2025) in force from 7 May 2026: daily reconciliations, monthly regulatory reporting, annual safeguarding audit by a qualified auditor, resolution pack, third-party due diligence; audit exemption below GBP 100k. Stage 2 CASS-style statutory trust (Post-Repeal Regime) still under FCA review, not yet confirmed. |
| 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 1 October 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. | HM Treasury's Modernising Payment Services Regulation consultation, published 14 July 2026 and open until 6 October 2026, proposes modernising the Payment Services Regulations 2017 and Electronic Money Regulations 2011, including moving detailed firm-facing requirements into the FCA rulebook and adapting the framework for tokenised deposits and UK qualifying stablecoins. |
| Difficulty rating | Estonia difficulty rating is included in the £349 pass. | 4. Rigorous on financial crime and safeguarding, very large market. |
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What changed recently
🇪🇪 Estonia (verified 2026-10-01): 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 1 October 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.
🇬🇧 United Kingdom (verified 2026-10-01): HM Treasury's Modernising Payment Services Regulation consultation, published 14 July 2026 and open until 6 October 2026, proposes modernising the Payment Services Regulations 2017 and Electronic Money Regulations 2011, including moving detailed firm-facing requirements into the FCA rulebook and adapting the framework for tokenised deposits and UK qualifying stablecoins.
Quick answers
Who regulates e-money licensing in Estonia and United Kingdom?
Estonia: Finantsinspektsioon (Estonian Financial Supervision and Resolution Authority, FSA). United Kingdom: Financial Conduct Authority (FCA)..
What licence do you need in Estonia compared with United Kingdom?
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 United Kingdom it is Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011.. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Estonia vs United Kingdom 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-united-kingdom.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.