Pin and benchmark
Pin the jurisdiction you are leaning towards, then line up to 5 rivals against it. Every unlocked figure shows where a peer beats it or loses to it on capital, timeline, cost and difficulty, so one screen tells you whether your first choice actually holds up.
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| Dimension |
Pinned 🇪🇪 Estonia partly open Verified 2026-07-03
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🇱🇺 Luxembourg
partly open
Verified 2026-07-03
|
|---|---|---|
| Licence type | 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 | 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 | Finantsinspektsioon (Estonian Financial Supervision and Resolution Authority, FSA) | Commission de Surveillance du Secteur Financier (CSSF) |
| Capital requirement | Estonia capital requirement is locked. Unlock with the £349 pass. | Luxembourg capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Estonia timeline to authorisation is locked. Unlock with the £349 pass. | Luxembourg timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Estonia local substance is locked. Unlock with the £349 pass. | Luxembourg local substance is locked. Unlock with the £349 pass. |
| Application cost | Estonia application cost is locked. Unlock with the £349 pass. | Luxembourg application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Estonia ongoing cost is locked. Unlock with the £349 pass. | Luxembourg ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Estonia passporting is locked. Unlock with the £349 pass. | Luxembourg passporting is locked. Unlock with the £349 pass. |
| EMIs authorised | Estonia emis authorised is locked. Unlock with the £349 pass. | Luxembourg emis authorised is locked. Unlock with the £349 pass. |
| Key restrictions | Estonia key restrictions is locked. Unlock with the £349 pass. | Luxembourg key restrictions is locked. Unlock with the £349 pass. |
| Safeguarding | Estonia safeguarding is locked. Unlock with the £349 pass. | Luxembourg safeguarding is locked. Unlock with the £349 pass. |
| Recent changes | 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. | PSD3/PSR: EU agreement reached Nov 2025, texts published April 2026, repealing EMD2 with EMIs becoming a 'payment institution authorised to issue e-money' sub-category; Luxembourg's payment services law will need amendment within the transposition window, with transitional relief (24 months, extendable to 30) for existing EMD2-authorised entities. CSSF also active on crypto/e-money-token overlap (MiCA e-money token issuer guidance). |
| Difficulty rating | Estonia difficulty rating is locked. Unlock with the £349 pass. | Luxembourg difficulty rating is locked. Unlock with 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.