🇱🇻 Latvia vs 🇨🇭 Switzerland: e-money licensing compared
Decision context and regulator route
Choosing between Latvia and Switzerland 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, FINMA. 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 No EMI. Closest is the FINMA FinTech licence (Banking Act Art. 1b), deposits up to CHF 100m, no interest, no lending. Larger operations need a banking licence. respectively. The public fields are shown below, with the full dated and sourced comparison included with access.
Latvia: verified 2026-08-15 · Switzerland: verified 2026-10-16
| Dimension |
🇱🇻 Latvia
partly open
Verified 2026-08-15
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🇨🇭 Switzerland
analogue
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) | No EMI. Closest is the FINMA FinTech licence (Banking Act Art. 1b), deposits up to CHF 100m, no interest, no lending. Larger operations need a banking licence. |
| Regulator | Latvijas Banka (Bank of Latvia) - sole licensing/supervisory authority, having absorbed the former FCMC (Finansu un kapitala tirgus komisija) in 2023 | FINMA. |
| Capital requirement | Latvia capital requirement is included in the £349 pass. | Switzerland capital requirement is included in the £349 pass. |
| Timeline to authorisation | Latvia timeline to authorisation is included in the £349 pass. | Switzerland timeline to authorisation is included in the £349 pass. |
| Local substance | Latvia local substance is included in the £349 pass. | Switzerland local substance is included in the £349 pass. |
| Application cost | Latvia application cost is included in the £349 pass. | Switzerland application cost is included in the £349 pass. |
| Ongoing cost | Latvia ongoing cost is included in the £349 pass. | Switzerland ongoing cost is included in the £349 pass. |
| Passporting | Latvia passporting is included in the £349 pass. | Switzerland passporting is included in the £349 pass. |
| EMIs authorised | Latvia emis authorised is included in the £349 pass. | Switzerland emis authorised is included in the £349 pass. |
| Key restrictions | Latvia key restrictions is included in the £349 pass. | Switzerland key restrictions is included in the £349 pass. |
| Safeguarding | Latvia safeguarding is included in the £349 pass. | Switzerland 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. | The Federal Council launched consultation on 22 October 2025 on Financial Institutions Act amendments that would replace the FinTech licence with payment instrument institution and crypto-institution categories. The consultation closed on 6 February 2026. The proposal would remove the CHF 100 million client-deposit cap and allow payment instrument institutions to issue specified stablecoins. The current FINMA FinTech licence and its CHF 100 million cap remain in force pending legislation. |
| Difficulty rating | Latvia difficulty rating is included in the £349 pass. | Switzerland 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.
🇨🇭 Switzerland (verified 2026-10-16): The Federal Council launched consultation on 22 October 2025 on Financial Institutions Act amendments that would replace the FinTech licence with payment instrument institution and crypto-institution categories. The consultation closed on 6 February 2026. The proposal would remove the CHF 100 million client-deposit cap and allow payment instrument institutions to issue specified stablecoins. The current FINMA FinTech licence and its CHF 100 million cap remain in force pending legislation.
Quick answers
Who regulates e-money licensing in Latvia and Switzerland?
Latvia: Latvijas Banka (Bank of Latvia) - sole licensing/supervisory authority, having absorbed the former FCMC (Finansu un kapitala tirgus komisija) in 2023. Switzerland: FINMA..
What licence do you need in Latvia compared with Switzerland?
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 Switzerland it is No EMI. Closest is the FINMA FinTech licence (Banking Act Art. 1b), deposits up to CHF 100m, no interest, no lending. Larger operations need a banking licence.. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Latvia vs Switzerland 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-switzerland.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.