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.
Sign in to watch these jurisdictions for changes.
| Dimension |
Pinned 🇩🇪 Germany partly open Verified 2026-07-03
|
🇱🇺 Luxembourg
partly open
Verified 2026-07-03
|
|---|---|---|
| Licence type | E-Geld-Institut under the ZAG. | 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 | BaFin, with the Deutsche Bundesbank. | Commission de Surveillance du Secteur Financier (CSSF) |
| Capital requirement | Germany capital requirement is locked. Unlock with the £349 pass. | Luxembourg capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Germany timeline to authorisation is locked. Unlock with the £349 pass. | Luxembourg timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Germany local substance is locked. Unlock with the £349 pass. | Luxembourg local substance is locked. Unlock with the £349 pass. |
| Application cost | Germany application cost is locked. Unlock with the £349 pass. | Luxembourg application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Germany ongoing cost is locked. Unlock with the £349 pass. | Luxembourg ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Germany passporting is locked. Unlock with the £349 pass. | Luxembourg passporting is locked. Unlock with the £349 pass. |
| EMIs authorised | Germany emis authorised is locked. Unlock with the £349 pass. | Luxembourg emis authorised is locked. Unlock with the £349 pass. |
| Key restrictions | Germany key restrictions is locked. Unlock with the £349 pass. | Luxembourg key restrictions is locked. Unlock with the £349 pass. |
| Safeguarding | Germany safeguarding is locked. Unlock with the £349 pass. | Luxembourg safeguarding is locked. Unlock with the £349 pass. |
| Recent changes | PSD3 and PSR merge the payment institution and EMI regimes into one payment institution licence that can issue e-money. Final texts published 23 Apr 2026, OJ expected mid to late 2026, PSR applies about 20 days after publication, PSD3 transposition within 18 months (applicability ~Q2/Q3 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 | Germany 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.