🇳🇱 Netherlands vs 🇸🇪 Sweden: e-money licensing compared
Decision context and regulator route
Netherlands's public 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 and Sweden's public Tillstand att ge ut elektroniska pengar (e-money institution licence) under lagen (2011:755) om elektroniska pengar, transposing EMD2; a lighter-touch registration tier ('registrerad utgivare av elektroniska pengar' for small-scale issuers below EMD2 thresholds) also exists are set out side by side. Licence type, regulator and public recent-change notes are open; the full dated and sourced comparison is included with access.
Netherlands: verified 2026-11-01 · Sweden: verified 2026-11-01
| Dimension |
🇳🇱 Netherlands
partly open
Verified 2026-11-01
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🇸🇪 Sweden
partly open
Verified 2026-11-01
|
|---|---|---|
| Licence type | 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 | Tillstand att ge ut elektroniska pengar (e-money institution licence) under lagen (2011:755) om elektroniska pengar, transposing EMD2; a lighter-touch registration tier ('registrerad utgivare av elektroniska pengar' for small-scale issuers below EMD2 thresholds) also exists |
| Regulator | De Nederlandsche Bank (DNB), acting as prudential supervisor under the Wft (with AFM as conduct supervisor) | Finansinspektionen (FI, the Swedish Financial Supervisory Authority) |
| Capital requirement | Netherlands capital requirement is included in the £349 pass. | Sweden capital requirement is included in the £349 pass. |
| Timeline to authorisation | Netherlands timeline to authorisation is included in the £349 pass. | Sweden timeline to authorisation is included in the £349 pass. |
| Local substance | Netherlands local substance is included in the £349 pass. | Sweden local substance is included in the £349 pass. |
| Application cost | Netherlands application cost is included in the £349 pass. | Sweden application cost is included in the £349 pass. |
| Ongoing cost | Netherlands ongoing cost is included in the £349 pass. | Sweden ongoing cost is included in the £349 pass. |
| Passporting | Netherlands passporting is included in the £349 pass. | Sweden passporting is included in the £349 pass. |
| EMIs authorised | Netherlands emis authorised is included in the £349 pass. | Sweden emis authorised is included in the £349 pass. |
| Key restrictions | Netherlands key restrictions is included in the £349 pass. | Sweden key restrictions is included in the £349 pass. |
| Safeguarding | Netherlands safeguarding is included in the £349 pass. | Sweden safeguarding is included in the £349 pass. |
| Recent changes | PSD3 and the Payment Services Regulation would merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. On 1 November 2026, both files were awaiting the Council's first-reading position, with an indicative European Parliament plenary sitting on 14 December 2026. No adopted act or Official Journal publication was identified. The negotiated Council text requires national transposition and application after 21 months, allows existing EMIs to continue until 27 months after entry into force, and permits an exceptional extension of no more than three months where the institution supplied the required information but the authority could not process it in time. | PSD3 and the Payment Services Regulation would merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. On 1 November 2026, both files were awaiting the Council's first-reading position, with an indicative European Parliament plenary sitting on 14 December 2026. No adopted act or Official Journal publication was identified. The negotiated Council text requires national transposition and application after 21 months, allows existing EMIs to continue until 27 months after entry into force, and permits an exceptional extension of no more than three months where the institution supplied the required information but the authority could not process it in time. |
| Difficulty rating | Netherlands difficulty rating is included in the £349 pass. | Sweden difficulty rating is included in the £349 pass. |
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What changed recently
🇳🇱 Netherlands (verified 2026-11-01): PSD3 and the Payment Services Regulation would merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. On 1 November 2026, both files were awaiting the Council's first-reading position, with an indicative European Parliament plenary sitting on 14 December 2026. No adopted act or Official Journal publication was identified. The negotiated Council text requires national transposition and application after 21 months, allows existing EMIs to continue until 27 months after entry into force, and permits an exceptional extension of no more than three months where the institution supplied the required information but the authority could not process it in time.
🇸🇪 Sweden (verified 2026-11-01): PSD3 and the Payment Services Regulation would merge payment-institution and EMI authorisation into one payment-institution category able to issue e-money. On 1 November 2026, both files were awaiting the Council's first-reading position, with an indicative European Parliament plenary sitting on 14 December 2026. No adopted act or Official Journal publication was identified. The negotiated Council text requires national transposition and application after 21 months, allows existing EMIs to continue until 27 months after entry into force, and permits an exceptional extension of no more than three months where the institution supplied the required information but the authority could not process it in time.
Quick answers
Who regulates e-money licensing in Netherlands and Sweden?
Netherlands: De Nederlandsche Bank (DNB), acting as prudential supervisor under the Wft (with AFM as conduct supervisor). Sweden: Finansinspektionen (FI, the Swedish Financial Supervisory Authority).
What licence do you need in Netherlands compared with Sweden?
In Netherlands the authorisation route 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; in Sweden it is Tillstand att ge ut elektroniska pengar (e-money institution licence) under lagen (2011:755) om elektroniska pengar, transposing EMD2; a lighter-touch registration tier ('registrerad utgivare av elektroniska pengar' for small-scale issuers below EMD2 thresholds) also exists. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Netherlands vs Sweden 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/netherlands-vs-sweden.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.