🇩🇪 Germany vs 🇲🇹 Malta: e-money licensing compared
Germany and Malta take recognisably different routes to e-money authorisation. In Germany the route is the E-Geld-Institut under the ZAG. overseen by BaFin, with the Deutsche Bundesbank.; in Malta it is the Electronic Money Institution under the Financial Institutions Act (Cap. 376). under Malta Financial Services Authority (MFSA).. The two regimes differ on 6 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.
Germany: verified 2026-07-03 · Malta: verified 2026-07-03
| Dimension |
🇩🇪 Germany
partly open
Verified 2026-07-03
|
🇲🇹 Malta
partly open
Verified 2026-07-03
|
|---|---|---|
| Licence type | E-Geld-Institut under the ZAG. | Electronic Money Institution under the Financial Institutions Act (Cap. 376). |
| Regulator | BaFin, with the Deutsche Bundesbank. | Malta Financial Services Authority (MFSA). |
| Capital requirement | Germany capital requirement is locked. Unlock with the £349 pass. | Malta capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Germany timeline to authorisation is locked. Unlock with the £349 pass. | Malta timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Germany local substance is locked. Unlock with the £349 pass. | Malta local substance is locked. Unlock with the £349 pass. |
| Application cost | Germany application cost is locked. Unlock with the £349 pass. | Malta application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Germany ongoing cost is locked. Unlock with the £349 pass. | Malta ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Germany passporting is locked. Unlock with the £349 pass. | Malta passporting is locked. Unlock with the £349 pass. |
| EMIs authorised | Germany emis authorised is locked. Unlock with the £349 pass. | Malta emis authorised is locked. Unlock with the £349 pass. |
| Key restrictions | Germany key restrictions is locked. Unlock with the £349 pass. | Malta key restrictions is locked. Unlock with the £349 pass. |
| Safeguarding | Germany safeguarding is locked. Unlock with the £349 pass. | Malta 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 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. Ongoing reputational rebuild after FATF grey-listing (delisted 2022). |
| Difficulty rating | Germany difficulty rating is locked. Unlock with the £349 pass. | Malta difficulty rating is locked. Unlock with the £349 pass. |
The two regimes differ on 6 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
🇩🇪 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.
🇲🇹 Malta (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. Ongoing reputational rebuild after FATF grey-listing (delisted 2022).
Quick answers
Who regulates e-money licensing in Germany and Malta?
Germany: BaFin, with the Deutsche Bundesbank.. Malta: Malta Financial Services Authority (MFSA)..
What licence do you need in Germany compared with Malta?
In Germany the authorisation route is E-Geld-Institut under the ZAG.; in Malta it is Electronic Money Institution under the Financial Institutions Act (Cap. 376).. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Germany vs Malta 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-malta.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.