🇱🇻 Latvia vs 🇳🇱 Netherlands: e-money licensing compared
Decision context and regulator route
Choosing between Latvia and Netherlands 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, De Nederlandsche Bank (DNB), acting as prudential supervisor under the Wft (with AFM as conduct supervisor) 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 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 public fields are shown below, with the full dated and sourced comparison included with access.
Latvia: verified 2026-08-15 · Netherlands: verified 2026-10-16
| Dimension |
🇱🇻 Latvia
partly open
Verified 2026-08-15
|
🇳🇱 Netherlands
partly open
Verified 2026-10-16
|
|---|---|---|
| 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) | 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 | Latvijas Banka (Bank of Latvia) - sole licensing/supervisory authority, having absorbed the former FCMC (Finansu un kapitala tirgus komisija) in 2023 | De Nederlandsche Bank (DNB), acting as prudential supervisor under the Wft (with AFM as conduct supervisor) |
| Capital requirement | Latvia capital requirement is included in the £349 pass. | Netherlands capital requirement is included in the £349 pass. |
| Timeline to authorisation | Latvia timeline to authorisation is included in the £349 pass. | Netherlands timeline to authorisation is included in the £349 pass. |
| Local substance | Latvia local substance is included in the £349 pass. | Netherlands local substance is included in the £349 pass. |
| Application cost | Latvia application cost is included in the £349 pass. | Netherlands application cost is included in the £349 pass. |
| Ongoing cost | Latvia ongoing cost is included in the £349 pass. | Netherlands ongoing cost is included in the £349 pass. |
| Passporting | Latvia passporting is included in the £349 pass. | Netherlands passporting is included in the £349 pass. |
| EMIs authorised | Latvia emis authorised is included in the £349 pass. | Netherlands emis authorised is included in the £349 pass. |
| Key restrictions | Latvia key restrictions is included in the £349 pass. | Netherlands key restrictions is included in the £349 pass. |
| Safeguarding | Latvia safeguarding is included in the £349 pass. | Netherlands 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. | 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 16 October 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. | Netherlands 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.
🇳🇱 Netherlands (verified 2026-10-16): 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 16 October 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 Netherlands?
Latvia: Latvijas Banka (Bank of Latvia) - sole licensing/supervisory authority, having absorbed the former FCMC (Finansu un kapitala tirgus komisija) in 2023. Netherlands: De Nederlandsche Bank (DNB), acting as prudential supervisor under the Wft (with AFM as conduct supervisor).
What licence do you need in Latvia compared with Netherlands?
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 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 Latvia 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/latvia-vs-netherlands.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.