🇫🇷 France vs 🇪🇸 Spain: e-money licensing compared
Decision context and regulator route
France and Spain are commonly considered side by side for e-money authorisation. In France the route is the Etablissement de monnaie electronique. overseen by ACPR (part of the Banque de France). Not the AMF, which handles markets and crypto.; in Spain it is the Entidad de Dinero Electronico (EDE), authorised under Ley 21/2011, de 26 de julio, de dinero electronico, and Real Decreto 778/2012 (as amended by Real Decreto 736/2019). Spain recognises 'entidades de dinero electronico hibridas' (hybrid EMIs) and an exemption/light regime under art. 14 of Real Decreto-ley 19/2018 for small-scale e-money issuers below activity thresholds, analogous to a 'small EMI' tier. under Banco de Espana (Bank of Spain). The public licence and regulator fields below are open to everyone; the complete sourced comparison is included with access.
France: verified 2026-08-15 · Spain: verified 2026-08-15
| Dimension |
🇫🇷 France
partly open
Verified 2026-08-15
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🇪🇸 Spain
partly open
Verified 2026-08-15
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|---|---|---|
| Licence type | Etablissement de monnaie electronique. | Entidad de Dinero Electronico (EDE), authorised under Ley 21/2011, de 26 de julio, de dinero electronico, and Real Decreto 778/2012 (as amended by Real Decreto 736/2019). Spain recognises 'entidades de dinero electronico hibridas' (hybrid EMIs) and an exemption/light regime under art. 14 of Real Decreto-ley 19/2018 for small-scale e-money issuers below activity thresholds, analogous to a 'small EMI' tier. |
| Regulator | ACPR (part of the Banque de France). Not the AMF, which handles markets and crypto. | Banco de Espana (Bank of Spain) |
| Capital requirement | France capital requirement is included in the £349 pass. | Spain capital requirement is included in the £349 pass. |
| Timeline to authorisation | France timeline to authorisation is included in the £349 pass. | Spain timeline to authorisation is included in the £349 pass. |
| Local substance | France local substance is included in the £349 pass. | Spain local substance is included in the £349 pass. |
| Application cost | France application cost is included in the £349 pass. | Spain application cost is included in the £349 pass. |
| Ongoing cost | France ongoing cost is included in the £349 pass. | Spain ongoing cost is included in the £349 pass. |
| Passporting | France passporting is included in the £349 pass. | Spain passporting is included in the £349 pass. |
| EMIs authorised | France emis authorised is included in the £349 pass. | Spain emis authorised is included in the £349 pass. |
| Key restrictions | France key restrictions is included in the £349 pass. | Spain key restrictions is included in the £349 pass. |
| Safeguarding | France safeguarding is included in the £349 pass. | Spain safeguarding is included in the £349 pass. |
| Recent changes | 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. | Spain will need to align its separate payment-institution and e-money statutes with the single PSD3 framework. 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 | France difficulty rating is included in the £349 pass. | Spain difficulty rating is included in the £349 pass. |
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What changed recently
🇫🇷 France (verified 2026-08-15): 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.
🇪🇸 Spain (verified 2026-08-15): Spain will need to align its separate payment-institution and e-money statutes with the single PSD3 framework. 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 France and Spain?
France: ACPR (part of the Banque de France). Not the AMF, which handles markets and crypto.. Spain: Banco de Espana (Bank of Spain).
What licence do you need in France compared with Spain?
In France the authorisation route is Etablissement de monnaie electronique.; in Spain it is Entidad de Dinero Electronico (EDE), authorised under Ley 21/2011, de 26 de julio, de dinero electronico, and Real Decreto 778/2012 (as amended by Real Decreto 736/2019). Spain recognises 'entidades de dinero electronico hibridas' (hybrid EMIs) and an exemption/light regime under art. 14 of Real Decreto-ley 19/2018 for small-scale e-money issuers below activity thresholds, analogous to a 'small EMI' tier.. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full France vs Spain 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-spain.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.