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 🇳🇱 Netherlands partly open Verified 2026-07-03
|
🇵🇹 Portugal
partly open
Verified 2026-07-03
|
|---|---|---|
| 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 locked. Unlock with the £349 pass. | Portugal capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Netherlands timeline to authorisation is locked. Unlock with the £349 pass. | Portugal timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Netherlands local substance is locked. Unlock with the £349 pass. | Portugal local substance is locked. Unlock with the £349 pass. |
| Application cost | Netherlands application cost is locked. Unlock with the £349 pass. | Portugal application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Netherlands ongoing cost is locked. Unlock with the £349 pass. | Portugal ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Netherlands passporting is locked. Unlock with the £349 pass. | Portugal passporting is locked. Unlock with the £349 pass. |
| EMIs authorised | Netherlands emis authorised is locked. Unlock with the £349 pass. | Portugal emis authorised is locked. Unlock with the £349 pass. |
| Key restrictions | Netherlands key restrictions is locked. Unlock with the £349 pass. | Portugal key restrictions is locked. Unlock with the £349 pass. |
| Safeguarding | Netherlands safeguarding is locked. Unlock with the £349 pass. | Portugal safeguarding is locked. Unlock with the £349 pass. |
| Recent changes | 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). | PSD3 and PSR merge the payment institution and EMI regimes into one payment institution licence that can issue e-money. Final texts published 23 Apr 2026, OJ expected mid to late 2026, PSR applies about 20 days after publication, PSD3 transposition within 18 months (applicability ~Q2/Q3 2028). Existing EMIs are grandfathered but must update their file. |
| Difficulty rating | Netherlands difficulty rating is locked. Unlock with the £349 pass. | Portugal 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.