🇱🇻 Latvia vs 🇱🇮 Liechtenstein: e-money licensing compared
Decision context and regulator route
Choosing between Latvia and Liechtenstein for a e-money licence starts with who you will answer to: Latvijas Banka (Bank of Latvia) - sole licensing/supervisory authority, having absorbed the former FCMC (Finansu un kapitala tirgus komisija) in 2023 on one side, Financial Market Authority Liechtenstein (Finanzmarktaufsicht, FMA) on the other, via the Two tiers: (1) Licensed electronic money institution (full EMI licence) and (2) Registered electronic money institution (lighter-touch registration tier for smaller issuers, restricted to issuing e-money and providing only payment instrument issuance or money remittance) - both under the Law on Payment Services and Electronic Money (transposing EMD2) and the E-money institution licence under the E-Geldgesetz (EGG, E-Money Act of 17 March 2011), Liechtenstein's EMD2 transposition; FMA-Guidance 2018/18 sets out the licensing process respectively. The public fields are shown below, with the full dated and sourced comparison included with access.
Latvia: verified 2026-08-15 · Liechtenstein: verified 2026-08-15
| Dimension |
🇱🇻 Latvia
partly open
Verified 2026-08-15
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🇱🇮 Liechtenstein
partly open
Verified 2026-08-15
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|---|---|---|
| Licence type | Two tiers: (1) Licensed electronic money institution (full EMI licence) and (2) Registered electronic money institution (lighter-touch registration tier for smaller issuers, restricted to issuing e-money and providing only payment instrument issuance or money remittance) - both under the Law on Payment Services and Electronic Money (transposing EMD2) | E-money institution licence under the E-Geldgesetz (EGG, E-Money Act of 17 March 2011), Liechtenstein's EMD2 transposition; FMA-Guidance 2018/18 sets out the licensing process |
| Regulator | Latvijas Banka (Bank of Latvia) - sole licensing/supervisory authority, having absorbed the former FCMC (Finansu un kapitala tirgus komisija) in 2023 | Financial Market Authority Liechtenstein (Finanzmarktaufsicht, FMA) |
| Capital requirement | Latvia capital requirement is included in the £349 pass. | Liechtenstein capital requirement is included in the £349 pass. |
| Timeline to authorisation | Latvia timeline to authorisation is included in the £349 pass. | Liechtenstein timeline to authorisation is included in the £349 pass. |
| Local substance | Latvia local substance is included in the £349 pass. | Liechtenstein local substance is included in the £349 pass. |
| Application cost | Latvia application cost is included in the £349 pass. | Liechtenstein application cost is included in the £349 pass. |
| Ongoing cost | Latvia ongoing cost is included in the £349 pass. | Liechtenstein ongoing cost is included in the £349 pass. |
| Passporting | Latvia passporting is included in the £349 pass. | Liechtenstein passporting is included in the £349 pass. |
| EMIs authorised | Latvia emis authorised is included in the £349 pass. | Liechtenstein emis authorised is included in the £349 pass. |
| Key restrictions | Latvia key restrictions is included in the £349 pass. | Liechtenstein key restrictions is included in the £349 pass. |
| Safeguarding | Latvia safeguarding is included in the £349 pass. | Liechtenstein safeguarding is included in the £349 pass. |
| Recent changes | Latvijas Banka continued granting new EMI licences during 2025 and 2026. 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. | Liechtenstein's EEA implementation timing also depends on incorporation through the EEA Agreement. 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 | Latvia difficulty rating is included in the £349 pass. | Liechtenstein difficulty rating is included in the £349 pass. |
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What changed recently
🇱🇻 Latvia (verified 2026-08-15): Latvijas Banka continued granting new EMI licences during 2025 and 2026. 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.
🇱🇮 Liechtenstein (verified 2026-08-15): Liechtenstein's EEA implementation timing also depends on incorporation through the EEA Agreement. 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 Latvia and Liechtenstein?
Latvia: Latvijas Banka (Bank of Latvia) - sole licensing/supervisory authority, having absorbed the former FCMC (Finansu un kapitala tirgus komisija) in 2023. Liechtenstein: Financial Market Authority Liechtenstein (Finanzmarktaufsicht, FMA).
What licence do you need in Latvia compared with Liechtenstein?
In Latvia the authorisation route is Two tiers: (1) Licensed electronic money institution (full EMI licence) and (2) Registered electronic money institution (lighter-touch registration tier for smaller issuers, restricted to issuing e-money and providing only payment instrument issuance or money remittance) - both under the Law on Payment Services and Electronic Money (transposing EMD2); in Liechtenstein it is E-money institution licence under the E-Geldgesetz (EGG, E-Money Act of 17 March 2011), Liechtenstein's EMD2 transposition; FMA-Guidance 2018/18 sets out the licensing process. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Latvia vs Liechtenstein 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/latvia-vs-liechtenstein.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.