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Dimension Pinned
🇱🇻 Latvia partly open
Verified 2026-07-03
🇪🇸 Spain partly open
Verified 2026-08-01
Licence type Two tiers: (1) Licensed electronic money institution (full EMI licence) and (2) Registered electronic money institution (lighter-touch registration tier for smaller issuers, restricted to issuing e-money and providing only payment instrument issuance or money remittance) - both under the Law on Payment Services and Electronic Money (transposing EMD2) 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.
Verified 2026-07-02 Source: BOE Ley 21/2011: https://www.boe.es/buscar/doc.php?id=BOE-A-2011-12909 ; BOE Real Decreto 778/2012: https://www.boe.es/diario_boe/txt.php?id=BOE-A-2012-5993
Regulator Latvijas Banka (Bank of Latvia) - sole licensing/supervisory authority, having absorbed the former FCMC (Finansu un kapitala tirgus komisija) in 2023
Verified 2026-07-02 Source: Latvijas Banka: https://www.bank.lv/en/operational-areas/licensing
Banco de Espana (Bank of Spain)
Capital requirement Latvia capital requirement is included in the £349 pass. Spain capital requirement is included in the £349 pass.
Timeline to authorisation Latvia timeline to authorisation is included in the £349 pass. Spain timeline to authorisation is included in the £349 pass.
Local substance Latvia local substance is included in the £349 pass. Spain local substance is included in the £349 pass.
Application cost Latvia application cost is included in the £349 pass. Spain application cost is included in the £349 pass.
Ongoing cost Latvia ongoing cost is included in the £349 pass. Spain ongoing cost is included in the £349 pass.
Passporting Latvia passporting is included in the £349 pass. Spain passporting is included in the £349 pass.
EMIs authorised Latvia emis authorised is included in the £349 pass. Spain emis authorised is included in the £349 pass.
Key restrictions Latvia key restrictions is included in the £349 pass. Spain key restrictions is included in the £349 pass.
Safeguarding Latvia safeguarding is included in the £349 pass. Spain safeguarding is included in the £349 pass.
Recent changes Latvijas Banka continues actively granting new EMI licences (e.g. NorthernTech SIA, AP Operations SIA, Fibonatix in 2025-2026); Latvia is increasingly featured on fintech shortlists. As of 2025, 3 new companies received EMI licences. PSD3/PSR (final texts April 2026, OJ publication expected mid-to-late 2026) will apply directly (PSR) and require transposition (PSD3) within 18 months. PSD3/PSR final texts published 23 April 2026, undergoing legal-linguistic review, OJ publication still pending as of 1 August 2026 (indicative Parliament plenary 14 December 2026). 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.
Verified 2026-08-01 Source: European Parliament Legislative Observatory 2023/0209(COD): https://oeil.europarl.europa.eu/oeil/en/procedure-file?reference=2023/0209(COD) ; Herbert Smith Freehills Kramer: https://www.hsfkramer.com/notes/fsrandcorpcrime/2026-posts/the-new-eu-payments-rulebook-psd3-psr
Difficulty rating Latvia difficulty rating is included in the £349 pass. Spain 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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