🇪🇸 Spain vs 🇬🇧 United Kingdom: e-money licensing compared
Decision context and regulator route
Choosing between Spain and United Kingdom for a e-money licence starts with who you will answer to: Banco de Espana (Bank of Spain) on one side, Financial Conduct Authority (FCA). on the other, via 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. and the Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011. respectively. The public fields are shown below, with the full dated and sourced comparison included with access.
Spain: verified 2026-08-15 · United Kingdom: verified 2026-08-15
| Dimension |
🇪🇸 Spain
partly open
Verified 2026-08-15
|
🇬🇧 United Kingdom
Free in full
Verified 2026-08-15
|
|---|---|---|
| Licence type | 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. | Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011. |
| Regulator | Banco de Espana (Bank of Spain) | Financial Conduct Authority (FCA). |
| Capital requirement | Spain capital requirement is included in the £349 pass. | AEMI GBP 350,000 initial plus own funds 2% of average outstanding e-money. SEMI no initial capital, capped below EUR 5m outstanding. |
| Timeline to authorisation | Spain timeline to authorisation is included in the £349 pass. | About 6 to 12 months including pre-application (statutory 3 months from a complete application). |
| Local substance | Spain local substance is included in the £349 pass. | UK entity with UK mind and management, MLRO, adequate local staffing. |
| Application cost | Spain application cost is included in the £349 pass. | FCA application fee GBP 5,640 for an authorised EMI (Category 5) or GBP 1,130 for a small EMI (Category 3). Professional and implementation costs are project-specific. |
| Ongoing cost | Spain ongoing cost is included in the £349 pass. | FCA periodic fees, annual safeguarding audit, compliance headcount. |
| Passporting | Spain passporting is included in the £349 pass. | None after Brexit, no EEA passport. |
| EMIs authorised | Spain emis authorised is included in the £349 pass. | Around 338 e-money firms on the FCA register including small EMIs, the largest EMI population in Europe. |
| Key restrictions | Spain key restrictions is included in the £349 pass. | No interest on e-money, no deposit-taking; a SEMI cannot provide AIS or PIS. |
| Safeguarding | Spain safeguarding is included in the £349 pass. | Segregation or insurance or comparable guarantee. FCA Supplementary safeguarding regime (Policy Statement PS25/12, published 7 August 2025) in force from 7 May 2026: daily reconciliations, monthly regulatory reporting, annual safeguarding audit by a qualified auditor, resolution pack, third-party due diligence; audit exemption below GBP 100k. Stage 2 CASS-style statutory trust (Post-Repeal Regime) still under FCA review, not yet confirmed. |
| Recent changes | 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. | FCA safeguarding reform live from 7 May 2026 (first monthly REP027 return fell due 21 July 2026). HM Treasury's Modernising Payment Services Regulation consultation, published 14 July 2026, proposes rebuilding the PSRs 2017 and EMRs 2011 into a single FCA-rulebook framework spanning fiat, tokenised deposits and UK qualifying stablecoins; it closes 6 October 2026. |
| Difficulty rating | Spain difficulty rating is included in the £349 pass. | 4. Rigorous on financial crime and safeguarding, very large market. |
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What changed recently
🇪🇸 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.
🇬🇧 United Kingdom (verified 2026-08-15): FCA safeguarding reform live from 7 May 2026 (first monthly REP027 return fell due 21 July 2026). HM Treasury's Modernising Payment Services Regulation consultation, published 14 July 2026, proposes rebuilding the PSRs 2017 and EMRs 2011 into a single FCA-rulebook framework spanning fiat, tokenised deposits and UK qualifying stablecoins; it closes 6 October 2026.
Quick answers
Who regulates e-money licensing in Spain and United Kingdom?
Spain: Banco de Espana (Bank of Spain). United Kingdom: Financial Conduct Authority (FCA)..
What licence do you need in Spain compared with United Kingdom?
In Spain the authorisation route 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.; in United Kingdom it is Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011.. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Spain vs United Kingdom 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/spain-vs-united-kingdom.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.