Pin and benchmark
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| Dimension |
Pinned 🇱🇺 Luxembourg partly open Verified 2026-08-15
|
🇲🇹 Malta
partly open
Verified 2026-08-15
|
|---|---|---|
| Licence type | 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. | Electronic Money Institution under the Financial Institutions Act (Cap. 376). |
| Regulator | Commission de Surveillance du Secteur Financier (CSSF) | Malta Financial Services Authority (MFSA). |
| Capital requirement | Luxembourg capital requirement is included in the £349 pass. | Malta capital requirement is included in the £349 pass. |
| Timeline to authorisation | Luxembourg timeline to authorisation is included in the £349 pass. | Malta timeline to authorisation is included in the £349 pass. |
| Local substance | Luxembourg local substance is included in the £349 pass. | Malta local substance is included in the £349 pass. |
| Application cost | Luxembourg application cost is included in the £349 pass. | Malta application cost is included in the £349 pass. |
| Ongoing cost | Luxembourg ongoing cost is included in the £349 pass. | Malta ongoing cost is included in the £349 pass. |
| Passporting | Luxembourg passporting is included in the £349 pass. | Malta passporting is included in the £349 pass. |
| EMIs authorised | Luxembourg emis authorised is included in the £349 pass. | Malta emis authorised is included in the £349 pass. |
| Key restrictions | Luxembourg key restrictions is included in the £349 pass. | Malta key restrictions is included in the £349 pass. |
| Safeguarding | Luxembourg safeguarding is included in the £349 pass. | Malta 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 | Luxembourg difficulty rating is included in the £349 pass. | Malta 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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