🇱🇹 Lithuania vs 🇪🇸 Spain: e-money licensing compared
Lithuania and Spain take recognisably different routes to e-money authorisation. In Lithuania the route is the EMI licence (unrestricted) or Restricted EMI, via the Bank of Lithuania. overseen by Bank of Lithuania (Lietuvos bankas).; in Spain it is the Entidad de Dinero Electronico (EDE), authorised under Ley 21/2011, de 26 de julio, de dinero electronico, and Real Decreto 778/2012 (as amended by Real Decreto 736/2019). Spain recognises 'entidades de dinero electronico hibridas' (hybrid EMIs) and an exemption/light regime under art. 14 of Real Decreto-ley 19/2018 for small-scale e-money issuers below activity thresholds, analogous to a 'small EMI' tier. under Banco de Espana (Bank of Spain). The two regimes differ on 8 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.
Lithuania: verified 2026-07-03 · Spain: verified 2026-07-03
| Dimension |
🇱🇹 Lithuania
partly open
Verified 2026-07-03
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🇪🇸 Spain
partly open
Verified 2026-07-03
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|---|---|---|
| Licence type | EMI licence (unrestricted) or Restricted EMI, via the Bank of Lithuania. | Entidad de Dinero Electronico (EDE), authorised under Ley 21/2011, de 26 de julio, de dinero electronico, and Real Decreto 778/2012 (as amended by Real Decreto 736/2019). Spain recognises 'entidades de dinero electronico hibridas' (hybrid EMIs) and an exemption/light regime under art. 14 of Real Decreto-ley 19/2018 for small-scale e-money issuers below activity thresholds, analogous to a 'small EMI' tier. |
| Regulator | Bank of Lithuania (Lietuvos bankas). | Banco de Espana (Bank of Spain) |
| Capital requirement | Lithuania capital requirement is locked. Unlock with the £349 pass. | Spain capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Lithuania timeline to authorisation is locked. Unlock with the £349 pass. | Spain timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Lithuania local substance is locked. Unlock with the £349 pass. | Spain local substance is locked. Unlock with the £349 pass. |
| Application cost | Lithuania application cost is locked. Unlock with the £349 pass. | Spain application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Lithuania ongoing cost is locked. Unlock with the £349 pass. | Spain ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Lithuania passporting is locked. Unlock with the £349 pass. | Spain passporting is locked. Unlock with the £349 pass. |
| EMIs authorised | Lithuania emis authorised is locked. Unlock with the £349 pass. | Spain emis authorised is locked. Unlock with the £349 pass. |
| Key restrictions | Lithuania key restrictions is locked. Unlock with the £349 pass. | Spain key restrictions is locked. Unlock with the £349 pass. |
| Safeguarding | Lithuania safeguarding is locked. Unlock with the £349 pass. | Spain 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. Continued AML tightening. | PSD3/PSR final texts published 23 April 2026, undergoing legal-linguistic review, OJ publication expected June/July 2026 (risk of slipping to September). Analysis flags that Spain's separate payment-institution and e-money statutes (despite an integrated supervisor) will likely require a more structural legislative overhaul than in peer states to merge into PSD3/PSR's single rulebook. |
| Difficulty rating | Lithuania difficulty rating is locked. Unlock with the £349 pass. | Spain difficulty rating is locked. Unlock with the £349 pass. |
The two regimes differ on 8 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
🇱🇹 Lithuania (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. Continued AML tightening.
🇪🇸 Spain (verified 2026-07-03): PSD3/PSR final texts published 23 April 2026, undergoing legal-linguistic review, OJ publication expected June/July 2026 (risk of slipping to September). Analysis flags that Spain's separate payment-institution and e-money statutes (despite an integrated supervisor) will likely require a more structural legislative overhaul than in peer states to merge into PSD3/PSR's single rulebook.
Quick answers
Who regulates e-money licensing in Lithuania and Spain?
Lithuania: Bank of Lithuania (Lietuvos bankas).. Spain: Banco de Espana (Bank of Spain).
What licence do you need in Lithuania compared with Spain?
In Lithuania the authorisation route is EMI licence (unrestricted) or Restricted EMI, via the Bank of Lithuania.; in Spain it is Entidad de Dinero Electronico (EDE), authorised under Ley 21/2011, de 26 de julio, de dinero electronico, and Real Decreto 778/2012 (as amended by Real Decreto 736/2019). Spain recognises 'entidades de dinero electronico hibridas' (hybrid EMIs) and an exemption/light regime under art. 14 of Real Decreto-ley 19/2018 for small-scale e-money issuers below activity thresholds, analogous to a 'small EMI' tier.. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Lithuania vs Spain 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/lithuania-vs-spain.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.