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Dimension Pinned
🇭🇷 Croatia partly open
Verified 2026-09-01
🇱🇮 Liechtenstein partly open
Verified 2026-09-01
Licence type Authorisation to issue electronic money under Croatia's Electronic Money Act (transposing EMD2); a distinct 'small electronic money institution' (mala institucija za elektronički novac) exemption tier exists for issuers below the EMD2 threshold, with its own HNB registration track
Verified 2026-08-15 Source: Current national regulator authorisation material: https://www.hnb.hr/en/core-functions/payment-system/licensing/electronic-money-institutions
E-money institution licence under the E-Geldgesetz (EGG, E-Money Act of 17 March 2011), Liechtenstein's EMD2 transposition; FMA-Guidance 2018/18 sets out the licensing process
Verified 2026-08-15 Source: Current national regulator authorisation material: https://www.fma-li.li/en/financial-intermediaries/financial-institutions-division/e-money-institutions
Regulator Croatian National Bank (Hrvatska narodna banka, HNB)
Verified 2026-08-15 Source: Current national regulator authorisation material: https://www.hnb.hr/en/core-functions/payment-system/licensing/electronic-money-institutions
Financial Market Authority Liechtenstein (Finanzmarktaufsicht, FMA)
Verified 2026-08-15 Source: Current national regulator authorisation material: https://www.fma-li.li/en/financial-intermediaries/financial-institutions-division/e-money-institutions
Capital requirement Croatia capital requirement is included in the £349 pass. Liechtenstein capital requirement is included in the £349 pass.
Timeline to authorisation Croatia timeline to authorisation is included in the £349 pass. Liechtenstein timeline to authorisation is included in the £349 pass.
Local substance Croatia local substance is included in the £349 pass. Liechtenstein local substance is included in the £349 pass.
Application cost Croatia application cost is included in the £349 pass. Liechtenstein application cost is included in the £349 pass.
Ongoing cost Croatia ongoing cost is included in the £349 pass. Liechtenstein ongoing cost is included in the £349 pass.
Passporting Croatia passporting is included in the £349 pass. Liechtenstein passporting is included in the £349 pass.
EMIs authorised Croatia emis authorised is included in the £349 pass. Liechtenstein emis authorised is included in the £349 pass.
Key restrictions Croatia key restrictions is included in the £349 pass. Liechtenstein key restrictions is included in the £349 pass.
Safeguarding Croatia safeguarding is included in the £349 pass. Liechtenstein 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 1 September 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. Liechtenstein's EEA implementation timing also depends on incorporation through the EEA Agreement. 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 Croatia difficulty rating is included in the £349 pass. Liechtenstein difficulty rating is included in 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.

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