🇫🇮 Finland vs 🇭🇰 Hong Kong: e-money licensing compared
Decision context and regulator route
Choosing between Finland and Hong Kong for a e-money licence starts with who you will answer to: Finanssivalvonta (Financial Supervisory Authority, FIN-FSA) on one side, Hong Kong Monetary Authority (HKMA). Not the SFC, which handles the crypto VATP regime. on the other, via the Toimilupa (authorisation) as an e-money institution under the Act on Payment Institutions (Laki maksulaitoksista, 297/2010), transposing EMD2; a lighter registration-only regime exists for issuers whose average outstanding e-money does not exceed EUR 5 million (exempt/small e-money issuer tier) and the No EMI. Stored Value Facility (SVF) licence under the Payment Systems and Stored Value Facilities Ordinance (Cap. 584). respectively. The two regimes differ on 10 of 10 tracked decision dimensions, including capital requirement and timeline to authorisation. Every figure behind the comparison carries a last-verified date and a primary source.
Finland: verified 2026-08-15 · Hong Kong: verified 2026-08-15
| Dimension |
🇫🇮 Finland
partly open
Verified 2026-08-15
|
🇭🇰 Hong Kong
analogue
partly open
Verified 2026-08-15
|
|---|---|---|
| Licence type | Toimilupa (authorisation) as an e-money institution under the Act on Payment Institutions (Laki maksulaitoksista, 297/2010), transposing EMD2; a lighter registration-only regime exists for issuers whose average outstanding e-money does not exceed EUR 5 million (exempt/small e-money issuer tier) | No EMI. Stored Value Facility (SVF) licence under the Payment Systems and Stored Value Facilities Ordinance (Cap. 584). |
| Regulator | Finanssivalvonta (Financial Supervisory Authority, FIN-FSA) | Hong Kong Monetary Authority (HKMA). Not the SFC, which handles the crypto VATP regime. |
| Capital requirement | Finland capital requirement is included in the £349 pass. | Hong Kong capital requirement is included in the £349 pass. |
| Timeline to authorisation | Finland timeline to authorisation is included in the £349 pass. | Hong Kong timeline to authorisation is included in the £349 pass. |
| Local substance | Finland local substance is included in the £349 pass. | Hong Kong local substance is included in the £349 pass. |
| Application cost | Finland application cost is included in the £349 pass. | Hong Kong application cost is included in the £349 pass. |
| Ongoing cost | Finland ongoing cost is included in the £349 pass. | Hong Kong ongoing cost is included in the £349 pass. |
| Passporting | Finland passporting is included in the £349 pass. | Hong Kong passporting is included in the £349 pass. |
| EMIs authorised | Finland emis authorised is included in the £349 pass. | Hong Kong emis authorised is included in the £349 pass. |
| Key restrictions | Finland key restrictions is included in the £349 pass. | Hong Kong key restrictions is included in the £349 pass. |
| Safeguarding | Finland safeguarding is included in the £349 pass. | Hong Kong safeguarding is included in the £349 pass. |
| Recent changes | FIN-FSA introduced a new 2026 payment-institution application model and fee schedule. 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. | The separate Stablecoins Ordinance (Cap. 656) came into force 1 August 2025 and is administered by the HKMA. In April 2026 the HKMA granted the first stablecoin issuer licences, to Anchorpoint and HSBC, both for HKD-referenced stablecoins, requiring at least HK$25m paid-up capital and segregated reserve assets. SVF licensees under the Payment Systems and Stored Value Facilities Ordinance (Cap. 584, the analogue regime in this row) are recognised as permitted offerors under the Stablecoins Ordinance and have a clear pathway to stablecoin issuance, but SVF and stablecoin-issuer licences remain two distinct licence types. |
| Difficulty rating | Finland difficulty rating is included in the £349 pass. | Hong Kong difficulty rating is included in the £349 pass. |
The two regimes differ on 10 of 10 tracked decision dimensions, including capital requirement and timeline to authorisation. Unlock the pass to see each figure with its source and verification date.
What changed recently
🇫🇮 Finland (verified 2026-08-15): FIN-FSA introduced a new 2026 payment-institution application model and fee schedule. 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.
🇭🇰 Hong Kong (verified 2026-08-15): The separate Stablecoins Ordinance (Cap. 656) came into force 1 August 2025 and is administered by the HKMA. In April 2026 the HKMA granted the first stablecoin issuer licences, to Anchorpoint and HSBC, both for HKD-referenced stablecoins, requiring at least HK$25m paid-up capital and segregated reserve assets. SVF licensees under the Payment Systems and Stored Value Facilities Ordinance (Cap. 584, the analogue regime in this row) are recognised as permitted offerors under the Stablecoins Ordinance and have a clear pathway to stablecoin issuance, but SVF and stablecoin-issuer licences remain two distinct licence types.
Quick answers
Who regulates e-money licensing in Finland and Hong Kong?
Finland: Finanssivalvonta (Financial Supervisory Authority, FIN-FSA). Hong Kong: Hong Kong Monetary Authority (HKMA). Not the SFC, which handles the crypto VATP regime..
What licence do you need in Finland compared with Hong Kong?
In Finland the authorisation route is Toimilupa (authorisation) as an e-money institution under the Act on Payment Institutions (Laki maksulaitoksista, 297/2010), transposing EMD2; a lighter registration-only regime exists for issuers whose average outstanding e-money does not exceed EUR 5 million (exempt/small e-money issuer tier); in Hong Kong it is No EMI. Stored Value Facility (SVF) licence under the Payment Systems and Stored Value Facilities Ordinance (Cap. 584).. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Finland vs Hong Kong 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/finland-vs-hong-kong.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.