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Dimension Pinned
🇪🇪 Estonia partly open
Verified 2026-08-15
🇵🇹 Portugal partly open
Verified 2026-08-15
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
Verified 2026-08-15 Source: Finantsinspektsioon - operating licences for payment institutions and e-money institutions: https://www.fi.ee/en/payment-and-e-money-services/applying-operating-licence-payment-services/operating-licences-payment-institutions-and-e-money-institutions
Instituicao de Moeda Eletronica under the RJSPME (Decree-Law 91/2018).
Verified 2026-08-15 Source: Current national regulator authorisation material: https://clientebancario.bportugal.pt/pt-pt/instituicoes
Regulator Finantsinspektsioon (Estonian Financial Supervision and Resolution Authority, FSA) Banco de Portugal.
Verified 2026-08-15 Source: Current national regulator authorisation material: https://clientebancario.bportugal.pt/pt-pt/instituicoes
Capital requirement Estonia capital requirement is included in the £349 pass. Portugal capital requirement is included in the £349 pass.
Timeline to authorisation Estonia timeline to authorisation is included in the £349 pass. Portugal timeline to authorisation is included in the £349 pass.
Local substance Estonia local substance is included in the £349 pass. Portugal local substance is included in the £349 pass.
Application cost Estonia application cost is included in the £349 pass. Portugal application cost is included in the £349 pass.
Ongoing cost Estonia ongoing cost is included in the £349 pass. Portugal ongoing cost is included in the £349 pass.
Passporting Estonia passporting is included in the £349 pass. Portugal passporting is included in the £349 pass.
EMIs authorised Estonia emis authorised is included in the £349 pass. Portugal emis authorised is included in the £349 pass.
Key restrictions Estonia key restrictions is included in the £349 pass. Portugal key restrictions is included in the £349 pass.
Safeguarding Estonia safeguarding is included in the £349 pass. Portugal 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 Estonia difficulty rating is included in the £349 pass. Portugal difficulty rating is included in the £349 pass.

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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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