🇱🇺 Luxembourg vs 🇪🇸 Spain: e-money licensing compared
Decision context and regulator route
Choosing between Luxembourg and Spain for a e-money licence starts with who you will answer to: Commission de Surveillance du Secteur Financier (CSSF) on one side, Banco de Espana (Bank of Spain) 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 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. respectively. The public fields are shown below, with the full dated and sourced comparison included with access.
Luxembourg: verified 2026-08-15 · Spain: verified 2026-08-15
| Dimension |
🇱🇺 Luxembourg
partly open
Verified 2026-08-15
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🇪🇸 Spain
partly open
Verified 2026-08-15
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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. | 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 | Commission de Surveillance du Secteur Financier (CSSF) | Banco de Espana (Bank of Spain) |
| Capital requirement | Luxembourg capital requirement is included in the £349 pass. | Spain capital requirement is included in the £349 pass. |
| Timeline to authorisation | Luxembourg timeline to authorisation is included in the £349 pass. | Spain timeline to authorisation is included in the £349 pass. |
| Local substance | Luxembourg local substance is included in the £349 pass. | Spain local substance is included in the £349 pass. |
| Application cost | Luxembourg application cost is included in the £349 pass. | Spain application cost is included in the £349 pass. |
| Ongoing cost | Luxembourg ongoing cost is included in the £349 pass. | Spain ongoing cost is included in the £349 pass. |
| Passporting | Luxembourg passporting is included in the £349 pass. | Spain passporting is included in the £349 pass. |
| EMIs authorised | Luxembourg emis authorised is included in the £349 pass. | Spain emis authorised is included in the £349 pass. |
| Key restrictions | Luxembourg key restrictions is included in the £349 pass. | Spain key restrictions is included in the £349 pass. |
| Safeguarding | Luxembourg safeguarding is included in the £349 pass. | Spain 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. | Spain will need to align its separate payment-institution and e-money statutes with the single PSD3 framework. 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. | Spain 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.
🇪🇸 Spain (verified 2026-08-15): Spain will need to align its separate payment-institution and e-money statutes with the single PSD3 framework. 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 Spain?
Luxembourg: Commission de Surveillance du Secteur Financier (CSSF). Spain: Banco de Espana (Bank of Spain).
What licence do you need in Luxembourg compared with Spain?
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 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 Luxembourg 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/luxembourg-vs-spain.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.