🇫🇷 France vs 🇩🇪 Germany: e-money licensing compared

Choosing between France and Germany for a e-money licence starts with who you will answer to: ACPR (part of the Banque de France). Not the AMF, which handles markets and crypto. on one side, BaFin, with the Deutsche Bundesbank. on the other, via the Etablissement de monnaie electronique. and the E-Geld-Institut under the ZAG. respectively. The two regimes differ on 5 of 10 tracked decision dimensions, including timeline to authorisation and local substance. Every figure behind the comparison carries a last-verified date and a primary source.

France: verified 2026-07-03 · Germany: verified 2026-07-03

Dimension	🇫🇷 France partly open Verified 2026-07-03	🇩🇪 Germany partly open Verified 2026-07-03
Licence type	Etablissement de monnaie electronique. Verified 2026-07-02 Source: ACPR	E-Geld-Institut under the ZAG. Verified 2026-07-02 Source: BaFin
Regulator	ACPR (part of the Banque de France). Not the AMF, which handles markets and crypto. Verified 2026-07-02 Source: ACPR, https://acpr.banque-france.fr/fr/professionnels/lacpr-vous-accompagne/banque/creer-ma-societe/mes-procedures/etablissement-de-monnaie-electronique	BaFin, with the Deutsche Bundesbank. Verified 2026-07-02 Source: BaFin, https://www.bafin.de/DE/Aufsicht/ZahlungsdienstePSD2/ZahlungsdienstePSD2_node.html
Capital requirement	France capital requirement is locked. Unlock with the £349 pass.	Germany capital requirement is locked. Unlock with the £349 pass.
Timeline to authorisation	France timeline to authorisation is locked. Unlock with the £349 pass.	Germany timeline to authorisation is locked. Unlock with the £349 pass.
Local substance	France local substance is locked. Unlock with the £349 pass.	Germany local substance is locked. Unlock with the £349 pass.
Application cost	France application cost is locked. Unlock with the £349 pass.	Germany application cost is locked. Unlock with the £349 pass.
Ongoing cost	France ongoing cost is locked. Unlock with the £349 pass.	Germany ongoing cost is locked. Unlock with the £349 pass.
Passporting	France passporting is locked. Unlock with the £349 pass.	Germany passporting is locked. Unlock with the £349 pass.
EMIs authorised	France emis authorised is locked. Unlock with the £349 pass.	Germany emis authorised is locked. Unlock with the £349 pass.
Key restrictions	France key restrictions is locked. Unlock with the £349 pass.	Germany key restrictions is locked. Unlock with the £349 pass.
Safeguarding	France safeguarding is locked. Unlock with the £349 pass.	Germany safeguarding is locked. Unlock with the £349 pass.
Recent changes	PSD3 and PSR merge the payment institution and EMI regimes into one payment institution licence that can issue e-money. Final texts published 23 Apr 2026, OJ expected mid to late 2026, PSR applies about 20 days after publication, PSD3 transposition within 18 months (applicability ~Q2/Q3 2028). Existing EMIs are grandfathered but must update their file. Verified 2026-07-03 Source: EU	PSD3 and PSR merge the payment institution and EMI regimes into one payment institution licence that can issue e-money. Final texts published 23 Apr 2026, OJ expected mid to late 2026, PSR applies about 20 days after publication, PSD3 transposition within 18 months (applicability ~Q2/Q3 2028). Existing EMIs are grandfathered but must update their file. Verified 2026-07-03 Source: EU
Difficulty rating	France difficulty rating is locked. Unlock with the £349 pass.	Germany difficulty rating is locked. Unlock with the £349 pass.

The two regimes differ on 5 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

🇫🇷 France (verified 2026-07-03): PSD3 and PSR merge the payment institution and EMI regimes into one payment institution licence that can issue e-money. Final texts published 23 Apr 2026, OJ expected mid to late 2026, PSR applies about 20 days after publication, PSD3 transposition within 18 months (applicability ~Q2/Q3 2028). Existing EMIs are grandfathered but must update their file.

🇩🇪 Germany (verified 2026-07-03): PSD3 and PSR merge the payment institution and EMI regimes into one payment institution licence that can issue e-money. Final texts published 23 Apr 2026, OJ expected mid to late 2026, PSR applies about 20 days after publication, PSD3 transposition within 18 months (applicability ~Q2/Q3 2028). Existing EMIs are grandfathered but must update their file.

Quick answers

Who regulates e-money licensing in France and Germany?

France: ACPR (part of the Banque de France). Not the AMF, which handles markets and crypto.. Germany: BaFin, with the Deutsche Bundesbank..

What licence do you need in France compared with Germany?

In France the authorisation route is Etablissement de monnaie electronique.; in Germany it is E-Geld-Institut under the ZAG.. The comparison table on this page lines the two up dimension by dimension.

Where can I see the full France vs Germany 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/france-vs-germany.

Open this pair in the interactive benchmark Unlock every figure

Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.