🇫🇮 Finland vs 🇬🇧 United Kingdom: e-money licensing compared
Decision context and regulator route
Finland and United Kingdom take recognisably different routes to 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 United Kingdom it is the Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011. under Financial Conduct Authority (FCA).. The two regimes differ on 9 of 10 tracked decision dimensions, including timeline to authorisation and local substance. The free columns below are open to everyone; the decision figures unlock with a pass, each one dated and sourced.
Finland: verified 2026-07-15 · United Kingdom: verified 2026-08-01
| Dimension |
🇫🇮 Finland
partly open
Verified 2026-07-15
|
🇬🇧 United Kingdom
Free in full
Verified 2026-08-01
|
|---|---|---|
| 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) | Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011. |
| Regulator | Finanssivalvonta (Financial Supervisory Authority, FIN-FSA) | Financial Conduct Authority (FCA). |
| Capital requirement | Finland 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 | Finland 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 | Finland local substance is included in the £349 pass. | UK entity with UK mind and management, MLRO, adequate local staffing. |
| Application cost | Finland application cost is included in the £349 pass. | FCA application fee GBP 5,580 for an authorised EMI (Category 5) or GBP 1,120 for a small EMI (Category 3), plus roughly GBP 75k to 200k professional; representative all-in around GBP 145k (~EUR 168k at 1.16). |
| Ongoing cost | Finland ongoing cost is included in the £349 pass. | FCA periodic fees, annual safeguarding audit, compliance headcount. |
| Passporting | Finland passporting is included in the £349 pass. | None after Brexit, no EEA passport. |
| EMIs authorised | Finland 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 | Finland key restrictions is included in the £349 pass. | No interest on e-money, no deposit-taking; a SEMI cannot provide AIS or PIS. |
| Safeguarding | Finland 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 | FIN-FSA introduced a new model for submitting financial information in payment institutions' authorisation applications during 2026, and a new processing fee schedule took effect 1 January 2026, signaling active modernisation of the authorisation pipeline. No Finland-specific PSD3/PSR transposition milestone found beyond the general EU timeline. | FCA safeguarding reform live from 7 May 2026 (first monthly REP027 return fell due 21 July 2026). HM Treasury's Modernising Payment Services Regulation consultation, published 14 July 2026, proposes rebuilding the PSRs 2017 and EMRs 2011 into a single FCA-rulebook framework spanning fiat, tokenised deposits and UK qualifying stablecoins; it closes 6 October 2026. |
| Difficulty rating | Finland difficulty rating is included in the £349 pass. | 4. Rigorous on financial crime and safeguarding, very large market. |
The two regimes differ on 9 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
🇫🇮 Finland (verified 2026-07-03): FIN-FSA introduced a new model for submitting financial information in payment institutions' authorisation applications during 2026, and a new processing fee schedule took effect 1 January 2026, signaling active modernisation of the authorisation pipeline. No Finland-specific PSD3/PSR transposition milestone found beyond the general EU timeline.
🇬🇧 United Kingdom (verified 2026-08-01): FCA safeguarding reform live from 7 May 2026 (first monthly REP027 return fell due 21 July 2026). HM Treasury's Modernising Payment Services Regulation consultation, published 14 July 2026, proposes rebuilding the PSRs 2017 and EMRs 2011 into a single FCA-rulebook framework spanning fiat, tokenised deposits and UK qualifying stablecoins; it closes 6 October 2026.
Quick answers
Who regulates e-money licensing in Finland and United Kingdom?
Finland: Finanssivalvonta (Financial Supervisory Authority, FIN-FSA). United Kingdom: Financial Conduct Authority (FCA)..
What licence do you need in Finland compared with United Kingdom?
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 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 Finland 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/finland-vs-united-kingdom.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.