🇫🇷 France vs 🇱🇺 Luxembourg: e-money licensing compared
On paper, France's Etablissement de monnaie electronique. and Luxembourg's Electronic Money Institution (EMI) authorisation under the Law of 10 November 2009 on payment services, as amended by the Law of 20 July 2018 (transposing PSD2); this same law also transposed EMD2's e-money provisions. No prominent separate small-EMI regime; EMIs are typically authorised as full EMIs given Luxembourg's fund/institutional client base. answer the same question; in practice the detail decides it. The two regimes differ on 7 of 10 tracked decision dimensions, including timeline to authorisation and local substance. This page compares the two side by side: the identity columns are free, the decision figures are one pass away, and every cell shows when it was last checked.
France: verified 2026-07-03 · Luxembourg: verified 2026-07-03
| Dimension |
🇫🇷 France
partly open
Verified 2026-07-03
|
🇱🇺 Luxembourg
partly open
Verified 2026-07-03
|
|---|---|---|
| Licence type | Etablissement de monnaie electronique. | Electronic Money Institution (EMI) authorisation under the Law of 10 November 2009 on payment services, as amended by the Law of 20 July 2018 (transposing PSD2); this same law also transposed EMD2's e-money provisions. No prominent separate small-EMI regime; EMIs are typically authorised as full EMIs given Luxembourg's fund/institutional client base. |
| Regulator | ACPR (part of the Banque de France). Not the AMF, which handles markets and crypto. | Commission de Surveillance du Secteur Financier (CSSF) |
| Capital requirement | France capital requirement is locked. Unlock with the £349 pass. | Luxembourg capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | France timeline to authorisation is locked. Unlock with the £349 pass. | Luxembourg timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | France local substance is locked. Unlock with the £349 pass. | Luxembourg local substance is locked. Unlock with the £349 pass. |
| Application cost | France application cost is locked. Unlock with the £349 pass. | Luxembourg application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | France ongoing cost is locked. Unlock with the £349 pass. | Luxembourg ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | France passporting is locked. Unlock with the £349 pass. | Luxembourg passporting is locked. Unlock with the £349 pass. |
| EMIs authorised | France emis authorised is locked. Unlock with the £349 pass. | Luxembourg emis authorised is locked. Unlock with the £349 pass. |
| Key restrictions | France key restrictions is locked. Unlock with the £349 pass. | Luxembourg key restrictions is locked. Unlock with the £349 pass. |
| Safeguarding | France safeguarding is locked. Unlock with the £349 pass. | Luxembourg 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. | PSD3/PSR: EU agreement reached Nov 2025, texts published April 2026, repealing EMD2 with EMIs becoming a 'payment institution authorised to issue e-money' sub-category; Luxembourg's payment services law will need amendment within the transposition window, with transitional relief (24 months, extendable to 30) for existing EMD2-authorised entities. CSSF also active on crypto/e-money-token overlap (MiCA e-money token issuer guidance). |
| Difficulty rating | France difficulty rating is locked. Unlock with the £349 pass. | Luxembourg difficulty rating is locked. Unlock with the £349 pass. |
The two regimes differ on 7 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.
🇱🇺 Luxembourg (verified 2026-07-03): PSD3/PSR: EU agreement reached Nov 2025, texts published April 2026, repealing EMD2 with EMIs becoming a 'payment institution authorised to issue e-money' sub-category; Luxembourg's payment services law will need amendment within the transposition window, with transitional relief (24 months, extendable to 30) for existing EMD2-authorised entities. CSSF also active on crypto/e-money-token overlap (MiCA e-money token issuer guidance).
Quick answers
Who regulates e-money licensing in France and Luxembourg?
France: ACPR (part of the Banque de France). Not the AMF, which handles markets and crypto.. Luxembourg: Commission de Surveillance du Secteur Financier (CSSF).
What licence do you need in France compared with Luxembourg?
In France the authorisation route is Etablissement de monnaie electronique.; in Luxembourg it is Electronic Money Institution (EMI) authorisation under the Law of 10 November 2009 on payment services, as amended by the Law of 20 July 2018 (transposing PSD2); this same law also transposed EMD2's e-money provisions. No prominent separate small-EMI regime; EMIs are typically authorised as full EMIs given Luxembourg's fund/institutional client base.. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full France vs Luxembourg 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-luxembourg.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.