🇮🇪 Ireland vs 🇱🇺 Luxembourg: e-money licensing compared
Ireland and Luxembourg take recognisably different routes to e-money authorisation. In Ireland the route is the E-Money Institution or Small E-Money Institution under the European Communities (Electronic Money) Regulations 2011. overseen by Central Bank of Ireland (CBI).; in Luxembourg it is the Electronic Money Institution (EMI) authorisation under the Law of 10 November 2009 on payment services, as amended by the Law of 20 July 2018 (transposing PSD2); this same law also transposed EMD2's e-money provisions. No prominent separate small-EMI regime; EMIs are typically authorised as full EMIs given Luxembourg's fund/institutional client base. under Commission de Surveillance du Secteur Financier (CSSF). The two regimes differ on 7 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.
Ireland: verified 2026-07-03 · Luxembourg: verified 2026-07-03
| Dimension |
🇮🇪 Ireland
partly open
Verified 2026-07-03
|
🇱🇺 Luxembourg
partly open
Verified 2026-07-03
|
|---|---|---|
| Licence type | E-Money Institution or Small E-Money Institution under the European Communities (Electronic Money) Regulations 2011. | Electronic Money Institution (EMI) authorisation under the Law of 10 November 2009 on payment services, as amended by the Law of 20 July 2018 (transposing PSD2); this same law also transposed EMD2's e-money provisions. No prominent separate small-EMI regime; EMIs are typically authorised as full EMIs given Luxembourg's fund/institutional client base. |
| Regulator | Central Bank of Ireland (CBI). | Commission de Surveillance du Secteur Financier (CSSF) |
| Capital requirement | Ireland capital requirement is locked. Unlock with the £349 pass. | Luxembourg capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Ireland timeline to authorisation is locked. Unlock with the £349 pass. | Luxembourg timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Ireland local substance is locked. Unlock with the £349 pass. | Luxembourg local substance is locked. Unlock with the £349 pass. |
| Application cost | Ireland application cost is locked. Unlock with the £349 pass. | Luxembourg application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Ireland ongoing cost is locked. Unlock with the £349 pass. | Luxembourg ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Ireland passporting is locked. Unlock with the £349 pass. | Luxembourg passporting is locked. Unlock with the £349 pass. |
| EMIs authorised | Ireland emis authorised is locked. Unlock with the £349 pass. | Luxembourg emis authorised is locked. Unlock with the £349 pass. |
| Key restrictions | Ireland key restrictions is locked. Unlock with the £349 pass. | Luxembourg key restrictions is locked. Unlock with the £349 pass. |
| Safeguarding | Ireland safeguarding is locked. Unlock with the £349 pass. | Luxembourg 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/PSR: EU agreement reached Nov 2025, texts published April 2026, repealing EMD2 with EMIs becoming a 'payment institution authorised to issue e-money' sub-category; Luxembourg's payment services law will need amendment within the transposition window, with transitional relief (24 months, extendable to 30) for existing EMD2-authorised entities. CSSF also active on crypto/e-money-token overlap (MiCA e-money token issuer guidance). |
| Difficulty rating | Ireland difficulty rating is locked. Unlock with the £349 pass. | Luxembourg difficulty rating is locked. Unlock with the £349 pass. |
The two regimes differ on 7 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
🇮🇪 Ireland (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.
🇱🇺 Luxembourg (verified 2026-07-03): PSD3/PSR: EU agreement reached Nov 2025, texts published April 2026, repealing EMD2 with EMIs becoming a 'payment institution authorised to issue e-money' sub-category; Luxembourg's payment services law will need amendment within the transposition window, with transitional relief (24 months, extendable to 30) for existing EMD2-authorised entities. CSSF also active on crypto/e-money-token overlap (MiCA e-money token issuer guidance).
Quick answers
Who regulates e-money licensing in Ireland and Luxembourg?
Ireland: Central Bank of Ireland (CBI).. Luxembourg: Commission de Surveillance du Secteur Financier (CSSF).
What licence do you need in Ireland compared with Luxembourg?
In Ireland the authorisation route is E-Money Institution or Small E-Money Institution under the European Communities (Electronic Money) Regulations 2011.; in Luxembourg it is Electronic Money Institution (EMI) authorisation under the Law of 10 November 2009 on payment services, as amended by the Law of 20 July 2018 (transposing PSD2); this same law also transposed EMD2's e-money provisions. No prominent separate small-EMI regime; EMIs are typically authorised as full EMIs given Luxembourg's fund/institutional client base.. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Ireland vs Luxembourg 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/ireland-vs-luxembourg.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.