🇫🇮 Finland vs 🇱🇻 Latvia: e-money licensing compared
Decision context and regulator route
Finland and Latvia are commonly considered side by side for e-money authorisation. In Finland the route is 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) overseen by Finanssivalvonta (Financial Supervisory Authority, FIN-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 public licence and regulator fields below are open to everyone; the complete sourced comparison is included with access.
Finland: verified 2026-08-15 · Latvia: verified 2026-08-15
| Dimension |
🇫🇮 Finland
partly open
Verified 2026-08-15
|
🇱🇻 Latvia
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) | 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 | Finanssivalvonta (Financial Supervisory Authority, FIN-FSA) | Latvijas Banka (Bank of Latvia) - sole licensing/supervisory authority, having absorbed the former FCMC (Finansu un kapitala tirgus komisija) in 2023 |
| Capital requirement | Finland capital requirement is included in the £349 pass. | Latvia capital requirement is included in the £349 pass. |
| Timeline to authorisation | Finland timeline to authorisation is included in the £349 pass. | Latvia timeline to authorisation is included in the £349 pass. |
| Local substance | Finland local substance is included in the £349 pass. | Latvia local substance is included in the £349 pass. |
| Application cost | Finland application cost is included in the £349 pass. | Latvia application cost is included in the £349 pass. |
| Ongoing cost | Finland ongoing cost is included in the £349 pass. | Latvia ongoing cost is included in the £349 pass. |
| Passporting | Finland passporting is included in the £349 pass. | Latvia passporting is included in the £349 pass. |
| EMIs authorised | Finland emis authorised is included in the £349 pass. | Latvia emis authorised is included in the £349 pass. |
| Key restrictions | Finland key restrictions is included in the £349 pass. | Latvia key restrictions is included in the £349 pass. |
| Safeguarding | Finland safeguarding is included in the £349 pass. | Latvia 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. | Latvijas Banka continued granting new EMI licences during 2025 and 2026. 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 | Finland difficulty rating is included in the £349 pass. | Latvia difficulty rating is included in the £349 pass. |
Unlock the pass to see each gated 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.
🇱🇻 Latvia (verified 2026-08-15): Latvijas Banka continued granting new EMI licences during 2025 and 2026. 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 Finland and Latvia?
Finland: Finanssivalvonta (Financial Supervisory Authority, FIN-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 Finland compared with Latvia?
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 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 Finland 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/finland-vs-latvia.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.