🇱🇺 Luxembourg vs 🇳🇱 Netherlands: e-money licensing compared
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 two regimes differ on 7 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 · Netherlands: verified 2026-07-03
| Dimension |
🇱🇺 Luxembourg
partly open
Verified 2026-07-03
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🇳🇱 Netherlands
partly open
Verified 2026-07-03
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|---|---|---|
| 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 locked. Unlock with the £349 pass. | Netherlands capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Luxembourg timeline to authorisation is locked. Unlock with the £349 pass. | Netherlands timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Luxembourg local substance is locked. Unlock with the £349 pass. | Netherlands local substance is locked. Unlock with the £349 pass. |
| Application cost | Luxembourg application cost is locked. Unlock with the £349 pass. | Netherlands application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Luxembourg ongoing cost is locked. Unlock with the £349 pass. | Netherlands ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Luxembourg passporting is locked. Unlock with the £349 pass. | Netherlands passporting is locked. Unlock with the £349 pass. |
| EMIs authorised | Luxembourg emis authorised is locked. Unlock with the £349 pass. | Netherlands emis authorised is locked. Unlock with the £349 pass. |
| Key restrictions | Luxembourg key restrictions is locked. Unlock with the £349 pass. | Netherlands key restrictions is locked. Unlock with the £349 pass. |
| Safeguarding | Luxembourg safeguarding is locked. Unlock with the £349 pass. | Netherlands 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). | EU-wide PSD3/PSR: agreement reached Nov 2025, texts published April 2026, repealing EMD2 and merging EMIs into the payment institution category ('payment institutions authorised to issue e-money'). Dutch Wft/DNB framework will need corresponding amendment during the transposition window, with existing Dutch EMD2 licences remaining valid on a transitional basis (up to 24-30 months). |
| Difficulty rating | Luxembourg difficulty rating is locked. Unlock with the £349 pass. | Netherlands 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
🇱🇺 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).
🇳🇱 Netherlands (verified 2026-07-02): EU-wide PSD3/PSR: agreement reached Nov 2025, texts published April 2026, repealing EMD2 and merging EMIs into the payment institution category ('payment institutions authorised to issue e-money'). Dutch Wft/DNB framework will need corresponding amendment during the transposition window, with existing Dutch EMD2 licences remaining valid on a transitional basis (up to 24-30 months).
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.