🇩🇪 Germany vs 🇳🇱 Netherlands: e-money licensing compared
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 two regimes differ on 6 of 10 tracked decision dimensions, including timeline to authorisation and local substance. Every figure behind the comparison carries a last-verified date and a primary source.
Germany: verified 2026-07-03 · Netherlands: verified 2026-07-03
| Dimension |
🇩🇪 Germany
partly open
Verified 2026-07-03
|
🇳🇱 Netherlands
partly open
Verified 2026-07-03
|
|---|---|---|
| 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 locked. Unlock with the £349 pass. | Netherlands capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Germany timeline to authorisation is locked. Unlock with the £349 pass. | Netherlands timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Germany local substance is locked. Unlock with the £349 pass. | Netherlands local substance is locked. Unlock with the £349 pass. |
| Application cost | Germany application cost is locked. Unlock with the £349 pass. | Netherlands application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Germany ongoing cost is locked. Unlock with the £349 pass. | Netherlands ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Germany passporting is locked. Unlock with the £349 pass. | Netherlands passporting is locked. Unlock with the £349 pass. |
| EMIs authorised | Germany emis authorised is locked. Unlock with the £349 pass. | Netherlands emis authorised is locked. Unlock with the £349 pass. |
| Key restrictions | Germany key restrictions is locked. Unlock with the £349 pass. | Netherlands key restrictions is locked. Unlock with the £349 pass. |
| Safeguarding | Germany safeguarding is locked. Unlock with the £349 pass. | Netherlands 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. | EU-wide PSD3/PSR: agreement reached Nov 2025, texts published April 2026, repealing EMD2 and merging EMIs into the payment institution category ('payment institutions authorised to issue e-money'). Dutch Wft/DNB framework will need corresponding amendment during the transposition window, with existing Dutch EMD2 licences remaining valid on a transitional basis (up to 24-30 months). |
| Difficulty rating | Germany difficulty rating is locked. Unlock with the £349 pass. | Netherlands 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.
🇳🇱 Netherlands (verified 2026-07-02): EU-wide PSD3/PSR: agreement reached Nov 2025, texts published April 2026, repealing EMD2 and merging EMIs into the payment institution category ('payment institutions authorised to issue e-money'). Dutch Wft/DNB framework will need corresponding amendment during the transposition window, with existing Dutch EMD2 licences remaining valid on a transitional basis (up to 24-30 months).
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.