🇩🇪 Germany vs 🇬🇧 United Kingdom: e-money licensing compared
Germany and United Kingdom 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 United Kingdom it is the Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011. under Financial Conduct Authority (FCA).. The two regimes differ on 8 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 · United Kingdom: verified 2026-07-03
| Dimension |
🇩🇪 Germany
partly open
Verified 2026-07-03
|
🇬🇧 United Kingdom
Free in full
Verified 2026-07-03
|
|---|---|---|
| Licence type | E-Geld-Institut under the ZAG. | Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011. |
| Regulator | BaFin, with the Deutsche Bundesbank. | Financial Conduct Authority (FCA). |
| Capital requirement | Germany capital requirement is locked. Unlock with the £349 pass. | AEMI GBP 350,000 initial plus own funds 2% of average outstanding e-money. SEMI no initial capital, capped below EUR 5m outstanding. |
| Timeline to authorisation | Germany timeline to authorisation is locked. Unlock with the £349 pass. | About 6 to 12 months including pre-application (statutory 3 months from a complete application). |
| Local substance | Germany local substance is locked. Unlock with the £349 pass. | UK entity with UK mind and management, MLRO, adequate local staffing. |
| Application cost | Germany application cost is locked. Unlock with the £349 pass. | FCA application fee (order of GBP 5,000 for AEMI) plus roughly GBP 75k to 200k professional. |
| Ongoing cost | Germany ongoing cost is locked. Unlock with the £349 pass. | FCA periodic fees, annual safeguarding audit, compliance headcount. |
| Passporting | Germany passporting is locked. Unlock with the £349 pass. | None after Brexit, no EEA passport. |
| EMIs authorised | Germany emis authorised is locked. Unlock with the £349 pass. | Around 338 e-money firms on the FCA register including small EMIs, the largest EMI population in Europe. |
| Key restrictions | Germany key restrictions is locked. Unlock with the £349 pass. | No interest on e-money, no deposit-taking; a SEMI cannot provide AIS or PIS. |
| Safeguarding | Germany safeguarding is locked. Unlock with the £349 pass. | Segregation or insurance or comparable guarantee. FCA Supplementary safeguarding regime (Policy Statement PS25/12, published 7 August 2025) in force from 7 May 2026: daily reconciliations, monthly regulatory reporting, annual safeguarding audit by a qualified auditor, resolution pack, third-party due diligence; audit exemption below GBP 100k. Stage 2 CASS-style statutory trust (Post-Repeal Regime) still under FCA review, not yet confirmed. |
| 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. | FCA safeguarding reform live from 7 May 2026; HM Treasury payments-law reform expected later in 2026. |
| Difficulty rating | Germany difficulty rating is locked. Unlock with the £349 pass. | 4. Rigorous on financial crime and safeguarding, very large market. |
The two regimes differ on 8 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.
🇬🇧 United Kingdom (verified 2026-07-03): FCA safeguarding reform live from 7 May 2026; HM Treasury payments-law reform expected later in 2026.
Quick answers
Who regulates e-money licensing in Germany and United Kingdom?
Germany: BaFin, with the Deutsche Bundesbank.. United Kingdom: Financial Conduct Authority (FCA)..
What licence do you need in Germany compared with United Kingdom?
In Germany the authorisation route is E-Geld-Institut under the ZAG.; in United Kingdom it is Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011.. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Germany vs United Kingdom 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-united-kingdom.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.