Pin and benchmark
Pin one jurisdiction. Line up to five rivals against it. Deltas show where each peer is better or worse.
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| Dimension |
Pinned 🇮🇹 Italy partly open Verified 2026-08-15
|
🇱🇺 Luxembourg
partly open
Verified 2026-08-15
|
|---|---|---|
| Licence type | 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. | 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 | Banca d'Italia (Bank of Italy) - Vigilanza (Supervision) function | Commission de Surveillance du Secteur Financier (CSSF) |
| Capital requirement | Italy capital requirement is included in the £349 pass. | Luxembourg capital requirement is included in the £349 pass. |
| Timeline to authorisation | Italy timeline to authorisation is included in the £349 pass. | Luxembourg timeline to authorisation is included in the £349 pass. |
| Local substance | Italy local substance is included in the £349 pass. | Luxembourg local substance is included in the £349 pass. |
| Application cost | Italy application cost is included in the £349 pass. | Luxembourg application cost is included in the £349 pass. |
| Ongoing cost | Italy ongoing cost is included in the £349 pass. | Luxembourg ongoing cost is included in the £349 pass. |
| Passporting | Italy passporting is included in the £349 pass. | Luxembourg passporting is included in the £349 pass. |
| EMIs authorised | Italy emis authorised is included in the £349 pass. | Luxembourg emis authorised is included in the £349 pass. |
| Key restrictions | Italy key restrictions is included in the £349 pass. | Luxembourg key restrictions is included in the £349 pass. |
| Safeguarding | Italy safeguarding is included in the £349 pass. | Luxembourg 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 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 | Italy 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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