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🇨🇾 Cyprus partly open
Verified 2026-07-03
🇪🇪 Estonia partly open
Verified 2026-07-03
Licence type Electronic Money Institution (EMI) authorisation under The Electronic Money Laws of 2012-2018 and The Provision and Use of Payment Services and Access to Payment Systems Laws of 2018 to 2025 (transposing EMD2/PSD2); a Small EMI / exempt tier also exists under the same framework for issuers below EMD2 thresholds Operating licence (tegevusluba) for e-money institutions under the Payment Institutions and E-money Institutions Act (Makse- ja e-raha asutuste seadus, MERAS), Estonia's EMD2 transposition
Verified 2026-07-02 Source: Riigi Teataja, Payment Institutions and E-money Institutions Act: https://www.riigiteataja.ee/akt/113032019024
Regulator Central Bank of Cyprus (CBC) - Licensing Section
Verified 2026-07-02 Source: Central Bank of Cyprus: https://www.centralbank.cy/en/licensing-supervision/electronic-money-institutions
Finantsinspektsioon (Estonian Financial Supervision and Resolution Authority, FSA)
Capital requirement Cyprus capital requirement is locked. Unlock with the £349 pass. Estonia capital requirement is locked. Unlock with the £349 pass.
Timeline to authorisation Cyprus timeline to authorisation is locked. Unlock with the £349 pass. Estonia timeline to authorisation is locked. Unlock with the £349 pass.
Local substance Cyprus local substance is locked. Unlock with the £349 pass. Estonia local substance is locked. Unlock with the £349 pass.
Application cost Cyprus application cost is locked. Unlock with the £349 pass. Estonia application cost is locked. Unlock with the £349 pass.
Ongoing cost Cyprus ongoing cost is locked. Unlock with the £349 pass. Estonia ongoing cost is locked. Unlock with the £349 pass.
Passporting Cyprus passporting is locked. Unlock with the £349 pass. Estonia passporting is locked. Unlock with the £349 pass.
EMIs authorised Cyprus emis authorised is locked. Unlock with the £349 pass. Estonia emis authorised is locked. Unlock with the £349 pass.
Key restrictions Cyprus key restrictions is locked. Unlock with the £349 pass. Estonia key restrictions is locked. Unlock with the £349 pass.
Safeguarding Cyprus safeguarding is locked. Unlock with the £349 pass. Estonia safeguarding is locked. Unlock with the £349 pass.
Recent changes CBC issued three new directives effective 2025: the Electronic Money Institutions Directive 2025 (authorisation/prudential supervision), a Directive on Internal Organisation and Governance of EMIs, and a Directive on Assessment of Suitability of board/management members, materially tightening governance and fit-and-proper requirements ahead of PSD3/PSR. EU political agreement on PSD3/PSR was reached Nov 2025, texts published April 2026; EMD2 will be repealed and EMIs folded into the payment institution framework as a sub-category, with existing EMD2 licences remaining valid for up to 24 months post-entry-into-force (extendable to 30 months at national regulator discretion). PSD3 and the PSR will merge the payment institution and EMI regimes into one licence that can issue e-money. Final texts published 23 April 2026, applicability targeted around 2028; existing EMIs are grandfathered but must update their file.
Verified 2026-07-03 Source: EU
Difficulty rating Cyprus difficulty rating is locked. Unlock with the £349 pass. Estonia difficulty rating is locked. Unlock with the £349 pass.

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Informational only, not legal advice. A delta compares the sortable figure only (capital, timeline, cost, difficulty, passporting, approvals); it is not a judgement on overall suitability. Verify with qualified counsel before acting.