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| Dimension |
Pinned 🇨🇾 Cyprus partly open Verified 2026-08-15
|
🇱🇺 Luxembourg
partly open
Verified 2026-08-15
|
|---|---|---|
| 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 | Electronic Money Institution (EMI) authorisation under the Law of 10 November 2009 on payment services, as amended by the Law of 20 July 2018 (transposing PSD2); this same law also transposed EMD2's e-money provisions. No prominent separate small-EMI regime; EMIs are typically authorised as full EMIs given Luxembourg's fund/institutional client base. |
| Regulator | Central Bank of Cyprus (CBC) - Licensing Section | Commission de Surveillance du Secteur Financier (CSSF) |
| Capital requirement | Cyprus capital requirement is included in the £349 pass. | Luxembourg capital requirement is included in the £349 pass. |
| Timeline to authorisation | Cyprus timeline to authorisation is included in the £349 pass. | Luxembourg timeline to authorisation is included in the £349 pass. |
| Local substance | Cyprus local substance is included in the £349 pass. | Luxembourg local substance is included in the £349 pass. |
| Application cost | Cyprus application cost is included in the £349 pass. | Luxembourg application cost is included in the £349 pass. |
| Ongoing cost | Cyprus ongoing cost is included in the £349 pass. | Luxembourg ongoing cost is included in the £349 pass. |
| Passporting | Cyprus passporting is included in the £349 pass. | Luxembourg passporting is included in the £349 pass. |
| EMIs authorised | Cyprus emis authorised is included in the £349 pass. | Luxembourg emis authorised is included in the £349 pass. |
| Key restrictions | Cyprus key restrictions is included in the £349 pass. | Luxembourg key restrictions is included in the £349 pass. |
| Safeguarding | Cyprus safeguarding is included in the £349 pass. | Luxembourg safeguarding is included in the £349 pass. |
| Recent changes | The Central Bank of Cyprus issued new 2025 EMI authorisation, governance and suitability directives. 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. | 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 | Cyprus difficulty rating is included in the £349 pass. | Luxembourg difficulty rating is included in the £349 pass. |
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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