Pin and benchmark
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| Dimension |
Pinned 🇳🇱 Netherlands partly open Verified 2026-08-15
|
🇵🇹 Portugal
partly open
Verified 2026-08-15
|
|---|---|---|
| Licence type | 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 | Instituicao de Moeda Eletronica under the RJSPME (Decree-Law 91/2018). |
| Regulator | De Nederlandsche Bank (DNB), acting as prudential supervisor under the Wft (with AFM as conduct supervisor) | Banco de Portugal. |
| Capital requirement | Netherlands capital requirement is included in the £349 pass. | Portugal capital requirement is included in the £349 pass. |
| Timeline to authorisation | Netherlands timeline to authorisation is included in the £349 pass. | Portugal timeline to authorisation is included in the £349 pass. |
| Local substance | Netherlands local substance is included in the £349 pass. | Portugal local substance is included in the £349 pass. |
| Application cost | Netherlands application cost is included in the £349 pass. | Portugal application cost is included in the £349 pass. |
| Ongoing cost | Netherlands ongoing cost is included in the £349 pass. | Portugal ongoing cost is included in the £349 pass. |
| Passporting | Netherlands passporting is included in the £349 pass. | Portugal passporting is included in the £349 pass. |
| EMIs authorised | Netherlands emis authorised is included in the £349 pass. | Portugal emis authorised is included in the £349 pass. |
| Key restrictions | Netherlands key restrictions is included in the £349 pass. | Portugal key restrictions is included in the £349 pass. |
| Safeguarding | Netherlands 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 | Netherlands difficulty rating is included in the £349 pass. | Portugal 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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