🇱🇻 Latvia vs 🇸🇪 Sweden: e-money licensing compared
Latvia and Sweden take recognisably different routes to e-money authorisation. In Latvia the route is 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) overseen by Latvijas Banka (Bank of Latvia) - sole licensing/supervisory authority, having absorbed the former FCMC (Finansu un kapitala tirgus komisija) in 2023; in Sweden it is the Tillstand att ge ut elektroniska pengar (e-money institution licence) under lagen (2011:755) om elektroniska pengar, transposing EMD2; a lighter-touch registration tier ('registrerad utgivare av elektroniska pengar' for small-scale issuers below EMD2 thresholds) also exists under Finansinspektionen (FI, the Swedish Financial Supervisory Authority). 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.
Latvia: verified 2026-07-03 · Sweden: verified 2026-07-03
| Dimension |
🇱🇻 Latvia
partly open
Verified 2026-07-03
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🇸🇪 Sweden
partly open
Verified 2026-07-03
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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) | Tillstand att ge ut elektroniska pengar (e-money institution licence) under lagen (2011:755) om elektroniska pengar, transposing EMD2; a lighter-touch registration tier ('registrerad utgivare av elektroniska pengar' for small-scale issuers below EMD2 thresholds) also exists |
| Regulator | Latvijas Banka (Bank of Latvia) - sole licensing/supervisory authority, having absorbed the former FCMC (Finansu un kapitala tirgus komisija) in 2023 | Finansinspektionen (FI, the Swedish Financial Supervisory Authority) |
| Capital requirement | Latvia capital requirement is locked. Unlock with the £349 pass. | Sweden capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Latvia timeline to authorisation is locked. Unlock with the £349 pass. | Sweden timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Latvia local substance is locked. Unlock with the £349 pass. | Sweden local substance is locked. Unlock with the £349 pass. |
| Application cost | Latvia application cost is locked. Unlock with the £349 pass. | Sweden application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Latvia ongoing cost is locked. Unlock with the £349 pass. | Sweden ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Latvia passporting is locked. Unlock with the £349 pass. | Sweden passporting is locked. Unlock with the £349 pass. |
| EMIs authorised | Latvia emis authorised is locked. Unlock with the £349 pass. | Sweden emis authorised is locked. Unlock with the £349 pass. |
| Key restrictions | Latvia key restrictions is locked. Unlock with the £349 pass. | Sweden key restrictions is locked. Unlock with the £349 pass. |
| Safeguarding | Latvia safeguarding is locked. Unlock with the £349 pass. | Sweden safeguarding is locked. Unlock with the £349 pass. |
| Recent changes | Latvijas Banka continues actively granting new EMI licences (e.g. NorthernTech SIA, AP Operations SIA, Fibonatix in 2025-2026); Latvia is increasingly featured on fintech shortlists. As of 2025, 3 new companies received EMI licences. PSD3/PSR (final texts April 2026, OJ publication expected mid-to-late 2026) will apply directly (PSR) and require transposition (PSD3) within 18 months. | PSD3 and the PSR will merge the payment institution and EMI regimes into one licence that can issue e-money. Final texts published 23 April 2026, applicability targeted around 2028; existing EMIs are grandfathered but must update their file. |
| Difficulty rating | Latvia difficulty rating is locked. Unlock with the £349 pass. | Sweden 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
🇱🇻 Latvia (verified 2026-07-03): Latvijas Banka continues actively granting new EMI licences (e.g. NorthernTech SIA, AP Operations SIA, Fibonatix in 2025-2026); Latvia is increasingly featured on fintech shortlists. As of 2025, 3 new companies received EMI licences. PSD3/PSR (final texts April 2026, OJ publication expected mid-to-late 2026) will apply directly (PSR) and require transposition (PSD3) within 18 months.
🇸🇪 Sweden (verified 2026-07-03): PSD3 and the PSR will merge the payment institution and EMI regimes into one licence that can issue e-money. Final texts published 23 April 2026, applicability targeted around 2028; existing EMIs are grandfathered but must update their file.
Quick answers
Who regulates e-money licensing in Latvia and Sweden?
Latvia: Latvijas Banka (Bank of Latvia) - sole licensing/supervisory authority, having absorbed the former FCMC (Finansu un kapitala tirgus komisija) in 2023. Sweden: Finansinspektionen (FI, the Swedish Financial Supervisory Authority).
What licence do you need in Latvia compared with Sweden?
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 Sweden it is Tillstand att ge ut elektroniska pengar (e-money institution licence) under lagen (2011:755) om elektroniska pengar, transposing EMD2; a lighter-touch registration tier ('registrerad utgivare av elektroniska pengar' for small-scale issuers below EMD2 thresholds) also exists. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Latvia vs Sweden 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-sweden.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.