🇱🇺 Luxembourg vs 🇳🇱 Netherlands: e-money licensing compared
Decision context and regulator route
Choosing between Luxembourg and Netherlands for a e-money licence starts with who you will answer to: Commission de Surveillance du Secteur Financier (CSSF) on one side, De Nederlandsche Bank (DNB), acting as prudential supervisor under the Wft (with AFM as conduct supervisor) 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 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.
Luxembourg: verified 2026-08-15 · Netherlands: verified 2026-08-15
| Dimension |
🇱🇺 Luxembourg
partly open
Verified 2026-08-15
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🇳🇱 Netherlands
partly open
Verified 2026-08-15
|
|---|---|---|
| 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 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 | Commission de Surveillance du Secteur Financier (CSSF) | De Nederlandsche Bank (DNB), acting as prudential supervisor under the Wft (with AFM as conduct supervisor) |
| Capital requirement | Luxembourg capital requirement is included in the £349 pass. | Netherlands capital requirement is included in the £349 pass. |
| Timeline to authorisation | Luxembourg timeline to authorisation is included in the £349 pass. | Netherlands timeline to authorisation is included in the £349 pass. |
| Local substance | Luxembourg local substance is included in the £349 pass. | Netherlands local substance is included in the £349 pass. |
| Application cost | Luxembourg application cost is included in the £349 pass. | Netherlands application cost is included in the £349 pass. |
| Ongoing cost | Luxembourg ongoing cost is included in the £349 pass. | Netherlands ongoing cost is included in the £349 pass. |
| Passporting | Luxembourg passporting is included in the £349 pass. | Netherlands passporting is included in the £349 pass. |
| EMIs authorised | Luxembourg emis authorised is included in the £349 pass. | Netherlands emis authorised is included in the £349 pass. |
| Key restrictions | Luxembourg key restrictions is included in the £349 pass. | Netherlands key restrictions is included in the £349 pass. |
| Safeguarding | Luxembourg safeguarding is included in the £349 pass. | Netherlands safeguarding is included in the £349 pass. |
| Recent changes | 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 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. |
| Difficulty rating | Luxembourg difficulty rating is included in the £349 pass. | Netherlands difficulty rating is included in the £349 pass. |
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What changed recently
🇱🇺 Luxembourg (verified 2026-08-15): 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 2026-08-15): 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.
Quick answers
Who regulates e-money licensing in Luxembourg and Netherlands?
Luxembourg: Commission de Surveillance du Secteur Financier (CSSF). Netherlands: De Nederlandsche Bank (DNB), acting as prudential supervisor under the Wft (with AFM as conduct supervisor).
What licence do you need in Luxembourg compared with Netherlands?
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 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 Luxembourg 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/luxembourg-vs-netherlands.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.