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 🇨🇾 Cyprus partly open Verified 2026-07-03
|
🇪🇸 Spain
partly open
Verified 2026-07-03
|
|---|---|---|
| Licence type | Electronic Money Institution (EMI) authorisation under The Electronic Money Laws of 2012-2018 and The Provision and Use of Payment Services and Access to Payment Systems Laws of 2018 to 2025 (transposing EMD2/PSD2); a Small EMI / exempt tier also exists under the same framework for issuers below EMD2 thresholds | Entidad de Dinero Electronico (EDE), authorised under Ley 21/2011, de 26 de julio, de dinero electronico, and Real Decreto 778/2012 (as amended by Real Decreto 736/2019). Spain recognises 'entidades de dinero electronico hibridas' (hybrid EMIs) and an exemption/light regime under art. 14 of Real Decreto-ley 19/2018 for small-scale e-money issuers below activity thresholds, analogous to a 'small EMI' tier. |
| Regulator | Central Bank of Cyprus (CBC) - Licensing Section | Banco de Espana (Bank of Spain) |
| Capital requirement | Cyprus capital requirement is locked. Unlock with the £349 pass. | Spain capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Cyprus timeline to authorisation is locked. Unlock with the £349 pass. | Spain timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Cyprus local substance is locked. Unlock with the £349 pass. | Spain local substance is locked. Unlock with the £349 pass. |
| Application cost | Cyprus application cost is locked. Unlock with the £349 pass. | Spain application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Cyprus ongoing cost is locked. Unlock with the £349 pass. | Spain ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Cyprus passporting is locked. Unlock with the £349 pass. | Spain passporting is locked. Unlock with the £349 pass. |
| EMIs authorised | Cyprus emis authorised is locked. Unlock with the £349 pass. | Spain emis authorised is locked. Unlock with the £349 pass. |
| Key restrictions | Cyprus key restrictions is locked. Unlock with the £349 pass. | Spain key restrictions is locked. Unlock with the £349 pass. |
| Safeguarding | Cyprus safeguarding is locked. Unlock with the £349 pass. | Spain safeguarding is locked. Unlock with the £349 pass. |
| Recent changes | CBC issued three new directives effective 2025: the Electronic Money Institutions Directive 2025 (authorisation/prudential supervision), a Directive on Internal Organisation and Governance of EMIs, and a Directive on Assessment of Suitability of board/management members, materially tightening governance and fit-and-proper requirements ahead of PSD3/PSR. EU political agreement on PSD3/PSR was reached Nov 2025, texts published April 2026; EMD2 will be repealed and EMIs folded into the payment institution framework as a sub-category, with existing EMD2 licences remaining valid for up to 24 months post-entry-into-force (extendable to 30 months at national regulator discretion). | PSD3/PSR final texts published 23 April 2026, undergoing legal-linguistic review, OJ publication expected June/July 2026 (risk of slipping to September). Analysis flags that Spain's separate payment-institution and e-money statutes (despite an integrated supervisor) will likely require a more structural legislative overhaul than in peer states to merge into PSD3/PSR's single rulebook. |
| Difficulty rating | Cyprus difficulty rating is locked. Unlock with the £349 pass. | Spain 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.