🇩🇪 Germany vs 🇱🇻 Latvia: e-money licensing compared
Decision context and regulator route
Germany and Latvia are commonly considered side by side for e-money authorisation. In Germany the route is the E-Geld-Institut under the ZAG. overseen by BaFin, with the Deutsche Bundesbank.; 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.
Germany: verified 2026-10-16 · Latvia: verified 2026-08-15
| Dimension |
🇩🇪 Germany
partly open
Verified 2026-10-16
|
🇱🇻 Latvia
partly open
Verified 2026-08-15
|
|---|---|---|
| Licence type | E-Geld-Institut under the ZAG. | 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 | BaFin, with the Deutsche Bundesbank. | Latvijas Banka (Bank of Latvia) - sole licensing/supervisory authority, having absorbed the former FCMC (Finansu un kapitala tirgus komisija) in 2023 |
| Capital requirement | Germany capital requirement is included in the £349 pass. | Latvia capital requirement is included in the £349 pass. |
| Timeline to authorisation | Germany timeline to authorisation is included in the £349 pass. | Latvia timeline to authorisation is included in the £349 pass. |
| Local substance | Germany local substance is included in the £349 pass. | Latvia local substance is included in the £349 pass. |
| Application cost | Germany application cost is included in the £349 pass. | Latvia application cost is included in the £349 pass. |
| Ongoing cost | Germany ongoing cost is included in the £349 pass. | Latvia ongoing cost is included in the £349 pass. |
| Passporting | Germany passporting is included in the £349 pass. | Latvia passporting is included in the £349 pass. |
| EMIs authorised | Germany emis authorised is included in the £349 pass. | Latvia emis authorised is included in the £349 pass. |
| Key restrictions | Germany key restrictions is included in the £349 pass. | Latvia key restrictions is included in the £349 pass. |
| Safeguarding | Germany safeguarding is included in the £349 pass. | Latvia 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 16 October 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 | Germany difficulty rating is included in the £349 pass. | Latvia difficulty rating is included in the £349 pass. |
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What changed recently
🇩🇪 Germany (verified 2026-10-16): 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 16 October 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 Germany and Latvia?
Germany: BaFin, with the Deutsche Bundesbank.. 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 Germany compared with Latvia?
In Germany the authorisation route is E-Geld-Institut under the ZAG.; 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 Germany 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/germany-vs-latvia.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.