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🇨🇾 Cyprus partly open
Verified 2026-07-03
🇮🇹 Italy 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 Istituto di Moneta Elettronica (IMEL), authorised under Legislative Decree 11/2010 / TUB (Testo Unico Bancario) implementing EMD2, per Banca d'Italia's 'Disposizioni di vigilanza per gli Istituti di Pagamento e gli IMEL'. No separate branded 'small IMEL' tier distinct from general PSD2 exemption thresholds was confirmed; Italy's framework centers on the full IMEL authorisation.
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
Banca d'Italia (Bank of Italy) - Vigilanza (Supervision) function
Capital requirement Cyprus capital requirement is locked. Unlock with the £349 pass. Italy capital requirement is locked. Unlock with the £349 pass.
Timeline to authorisation Cyprus timeline to authorisation is locked. Unlock with the £349 pass. Italy timeline to authorisation is locked. Unlock with the £349 pass.
Local substance Cyprus local substance is locked. Unlock with the £349 pass. Italy local substance is locked. Unlock with the £349 pass.
Application cost Cyprus application cost is locked. Unlock with the £349 pass. Italy application cost is locked. Unlock with the £349 pass.
Ongoing cost Cyprus ongoing cost is locked. Unlock with the £349 pass. Italy ongoing cost is locked. Unlock with the £349 pass.
Passporting Cyprus passporting is locked. Unlock with the £349 pass. Italy passporting is locked. Unlock with the £349 pass.
EMIs authorised Cyprus emis authorised is locked. Unlock with the £349 pass. Italy emis authorised is locked. Unlock with the £349 pass.
Key restrictions Cyprus key restrictions is locked. Unlock with the £349 pass. Italy key restrictions is locked. Unlock with the £349 pass.
Safeguarding Cyprus safeguarding is locked. Unlock with the £349 pass. Italy 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/PSR final compromise texts agreed by Parliament and Council, published 23 April 2026; undergoing legal-linguistic review before Official Journal publication expected June/July 2026 (possible slip to September). As a Regulation, the PSR will apply directly in Italy without national transposition; PSD3 requires transposition within 18 months. No Italy-specific transposition law yet as of mid-2026.
Difficulty rating Cyprus difficulty rating is locked. Unlock with the £349 pass. Italy 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.