🇮🇪 Ireland vs 🇳🇱 Netherlands: e-money licensing compared
On paper, Ireland's E-Money Institution or Small E-Money Institution under the European Communities (Electronic Money) Regulations 2011. and Netherlands's 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 answer the same question; in practice the detail decides it. The two regimes differ on 6 of 10 tracked decision dimensions, including timeline to authorisation and local substance. This page compares the two side by side: the identity columns are free, the decision figures are one pass away, and every cell shows when it was last checked.
Ireland: verified 2026-07-03 · Netherlands: verified 2026-07-03
| Dimension |
🇮🇪 Ireland
partly open
Verified 2026-07-03
|
🇳🇱 Netherlands
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 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 | Central Bank of Ireland (CBI). | De Nederlandsche Bank (DNB), acting as prudential supervisor under the Wft (with AFM as conduct supervisor) |
| Capital requirement | Ireland capital requirement is locked. Unlock with the £349 pass. | Netherlands capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Ireland timeline to authorisation is locked. Unlock with the £349 pass. | Netherlands timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Ireland local substance is locked. Unlock with the £349 pass. | Netherlands local substance is locked. Unlock with the £349 pass. |
| Application cost | Ireland application cost is locked. Unlock with the £349 pass. | Netherlands application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Ireland ongoing cost is locked. Unlock with the £349 pass. | Netherlands ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Ireland passporting is locked. Unlock with the £349 pass. | Netherlands passporting is locked. Unlock with the £349 pass. |
| EMIs authorised | Ireland emis authorised is locked. Unlock with the £349 pass. | Netherlands emis authorised is locked. Unlock with the £349 pass. |
| Key restrictions | Ireland key restrictions is locked. Unlock with the £349 pass. | Netherlands key restrictions is locked. Unlock with the £349 pass. |
| Safeguarding | Ireland 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 | Ireland 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
🇮🇪 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.
🇳🇱 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 Ireland and Netherlands?
Ireland: Central Bank of Ireland (CBI).. Netherlands: De Nederlandsche Bank (DNB), acting as prudential supervisor under the Wft (with AFM as conduct supervisor).
What licence do you need in Ireland compared with Netherlands?
In Ireland the authorisation route is E-Money Institution or Small E-Money Institution under the European Communities (Electronic Money) Regulations 2011.; 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 Ireland 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/ireland-vs-netherlands.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.