🇱🇺 Luxembourg vs 🇲🇹 Malta: e-money licensing compared
Choosing between Luxembourg and Malta for a e-money licence starts with who you will answer to: Commission de Surveillance du Secteur Financier (CSSF) on one side, Malta Financial Services Authority (MFSA). on the other, via the Electronic Money Institution (EMI) authorisation under the Law of 10 November 2009 on payment services, as amended by the Law of 20 July 2018 (transposing PSD2); this same law also transposed EMD2's e-money provisions. No prominent separate small-EMI regime; EMIs are typically authorised as full EMIs given Luxembourg's fund/institutional client base. and the Electronic Money Institution under the Financial Institutions Act (Cap. 376). respectively. The two regimes differ on 8 of 10 tracked decision dimensions, including timeline to authorisation and local substance. Every figure behind the comparison carries a last-verified date and a primary source.
Luxembourg: verified 2026-07-03 · Malta: verified 2026-07-03
| Dimension |
🇱🇺 Luxembourg
partly open
Verified 2026-07-03
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🇲🇹 Malta
partly open
Verified 2026-07-03
|
|---|---|---|
| Licence type | Electronic Money Institution (EMI) authorisation under the Law of 10 November 2009 on payment services, as amended by the Law of 20 July 2018 (transposing PSD2); this same law also transposed EMD2's e-money provisions. No prominent separate small-EMI regime; EMIs are typically authorised as full EMIs given Luxembourg's fund/institutional client base. | Electronic Money Institution under the Financial Institutions Act (Cap. 376). |
| Regulator | Commission de Surveillance du Secteur Financier (CSSF) | Malta Financial Services Authority (MFSA). |
| Capital requirement | Luxembourg capital requirement is locked. Unlock with the £349 pass. | Malta capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Luxembourg timeline to authorisation is locked. Unlock with the £349 pass. | Malta timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Luxembourg local substance is locked. Unlock with the £349 pass. | Malta local substance is locked. Unlock with the £349 pass. |
| Application cost | Luxembourg application cost is locked. Unlock with the £349 pass. | Malta application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Luxembourg ongoing cost is locked. Unlock with the £349 pass. | Malta ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Luxembourg passporting is locked. Unlock with the £349 pass. | Malta passporting is locked. Unlock with the £349 pass. |
| EMIs authorised | Luxembourg emis authorised is locked. Unlock with the £349 pass. | Malta emis authorised is locked. Unlock with the £349 pass. |
| Key restrictions | Luxembourg key restrictions is locked. Unlock with the £349 pass. | Malta key restrictions is locked. Unlock with the £349 pass. |
| Safeguarding | Luxembourg safeguarding is locked. Unlock with the £349 pass. | Malta safeguarding is locked. Unlock with the £349 pass. |
| Recent changes | PSD3/PSR: EU agreement reached Nov 2025, texts published April 2026, repealing EMD2 with EMIs becoming a 'payment institution authorised to issue e-money' sub-category; Luxembourg's payment services law will need amendment within the transposition window, with transitional relief (24 months, extendable to 30) for existing EMD2-authorised entities. CSSF also active on crypto/e-money-token overlap (MiCA e-money token issuer guidance). | 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. Ongoing reputational rebuild after FATF grey-listing (delisted 2022). |
| Difficulty rating | Luxembourg difficulty rating is locked. Unlock with the £349 pass. | Malta 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
🇱🇺 Luxembourg (verified 2026-07-03): PSD3/PSR: EU agreement reached Nov 2025, texts published April 2026, repealing EMD2 with EMIs becoming a 'payment institution authorised to issue e-money' sub-category; Luxembourg's payment services law will need amendment within the transposition window, with transitional relief (24 months, extendable to 30) for existing EMD2-authorised entities. CSSF also active on crypto/e-money-token overlap (MiCA e-money token issuer guidance).
🇲🇹 Malta (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. Ongoing reputational rebuild after FATF grey-listing (delisted 2022).
Quick answers
Who regulates e-money licensing in Luxembourg and Malta?
Luxembourg: Commission de Surveillance du Secteur Financier (CSSF). Malta: Malta Financial Services Authority (MFSA)..
What licence do you need in Luxembourg compared with Malta?
In Luxembourg the authorisation route is Electronic Money Institution (EMI) authorisation under the Law of 10 November 2009 on payment services, as amended by the Law of 20 July 2018 (transposing PSD2); this same law also transposed EMD2's e-money provisions. No prominent separate small-EMI regime; EMIs are typically authorised as full EMIs given Luxembourg's fund/institutional client base.; in Malta it is Electronic Money Institution under the Financial Institutions Act (Cap. 376).. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Luxembourg vs Malta 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/luxembourg-vs-malta.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.