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 🇱🇺 Luxembourg partly open Verified 2026-07-03
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🇳🇱 Netherlands
partly open
Verified 2026-07-03
|
|---|---|---|
| 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 licence under the Dutch Financial Supervision Act (Wet op het financieel toezicht - Wft), implementing EMD2; an exempted/excepted EMI status also exists for smaller issuers who do not need a full DNB licence |
| Regulator | Commission de Surveillance du Secteur Financier (CSSF) | De Nederlandsche Bank (DNB), acting as prudential supervisor under the Wft (with AFM as conduct supervisor) |
| Capital requirement | Luxembourg capital requirement is locked. Unlock with the £349 pass. | Netherlands capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Luxembourg timeline to authorisation is locked. Unlock with the £349 pass. | Netherlands timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Luxembourg local substance is locked. Unlock with the £349 pass. | Netherlands local substance is locked. Unlock with the £349 pass. |
| Application cost | Luxembourg application cost is locked. Unlock with the £349 pass. | Netherlands application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Luxembourg ongoing cost is locked. Unlock with the £349 pass. | Netherlands ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Luxembourg passporting is locked. Unlock with the £349 pass. | Netherlands passporting is locked. Unlock with the £349 pass. |
| EMIs authorised | Luxembourg emis authorised is locked. Unlock with the £349 pass. | Netherlands emis authorised is locked. Unlock with the £349 pass. |
| Key restrictions | Luxembourg key restrictions is locked. Unlock with the £349 pass. | Netherlands key restrictions is locked. Unlock with the £349 pass. |
| Safeguarding | Luxembourg safeguarding is locked. Unlock with the £349 pass. | Netherlands safeguarding is locked. Unlock with the £349 pass. |
| Recent changes | 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). | EU-wide PSD3/PSR: agreement reached Nov 2025, texts published April 2026, repealing EMD2 and merging EMIs into the payment institution category ('payment institutions authorised to issue e-money'). Dutch Wft/DNB framework will need corresponding amendment during the transposition window, with existing Dutch EMD2 licences remaining valid on a transitional basis (up to 24-30 months). |
| Difficulty rating | Luxembourg difficulty rating is locked. Unlock with the £349 pass. | Netherlands 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.