🇩🇪 Germany vs 🇳🇱 Netherlands: e-money licensing compared
Decision context and regulator route
Choosing between Germany and Netherlands for a e-money licence starts with who you will answer to: BaFin, with the Deutsche Bundesbank. on one side, De Nederlandsche Bank (DNB), acting as prudential supervisor under the Wft (with AFM as conduct supervisor) on the other, via the E-Geld-Institut under the ZAG. and the Electronic Money Institution licence under the Dutch Financial Supervision Act (Wet op het financieel toezicht - Wft), implementing EMD2; an exempted/excepted EMI status also exists for smaller issuers who do not need a full DNB licence respectively. The public fields are shown below, with the full dated and sourced comparison included with access.
Germany: verified 2026-08-15 · Netherlands: verified 2026-08-15
| Dimension |
🇩🇪 Germany
partly open
Verified 2026-08-15
|
🇳🇱 Netherlands
partly open
Verified 2026-08-15
|
|---|---|---|
| Licence type | E-Geld-Institut under the ZAG. | Electronic Money Institution licence under the Dutch Financial Supervision Act (Wet op het financieel toezicht - Wft), implementing EMD2; an exempted/excepted EMI status also exists for smaller issuers who do not need a full DNB licence |
| Regulator | BaFin, with the Deutsche Bundesbank. | De Nederlandsche Bank (DNB), acting as prudential supervisor under the Wft (with AFM as conduct supervisor) |
| Capital requirement | Germany capital requirement is included in the £349 pass. | Netherlands capital requirement is included in the £349 pass. |
| Timeline to authorisation | Germany timeline to authorisation is included in the £349 pass. | Netherlands timeline to authorisation is included in the £349 pass. |
| Local substance | Germany local substance is included in the £349 pass. | Netherlands local substance is included in the £349 pass. |
| Application cost | Germany application cost is included in the £349 pass. | Netherlands application cost is included in the £349 pass. |
| Ongoing cost | Germany ongoing cost is included in the £349 pass. | Netherlands ongoing cost is included in the £349 pass. |
| Passporting | Germany passporting is included in the £349 pass. | Netherlands passporting is included in the £349 pass. |
| EMIs authorised | Germany emis authorised is included in the £349 pass. | Netherlands emis authorised is included in the £349 pass. |
| Key restrictions | Germany key restrictions is included in the £349 pass. | Netherlands key restrictions is included in the £349 pass. |
| Safeguarding | Germany safeguarding is included in the £349 pass. | Netherlands 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. | 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. | Netherlands difficulty rating is included in the £349 pass. |
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What changed recently
🇩🇪 Germany (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.
🇳🇱 Netherlands (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.
Quick answers
Who regulates e-money licensing in Germany and Netherlands?
Germany: BaFin, with the Deutsche Bundesbank.. Netherlands: De Nederlandsche Bank (DNB), acting as prudential supervisor under the Wft (with AFM as conduct supervisor).
What licence do you need in Germany compared with Netherlands?
In Germany the authorisation route is E-Geld-Institut under the ZAG.; in Netherlands it is Electronic Money Institution licence under the Dutch Financial Supervision Act (Wet op het financieel toezicht - Wft), implementing EMD2; an exempted/excepted EMI status also exists for smaller issuers who do not need a full DNB licence. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Germany vs Netherlands 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-netherlands.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.