Pin and benchmark
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| Dimension |
Pinned 🇲🇹 Malta partly open Verified 2026-08-15
|
🇪🇸 Spain
partly open
Verified 2026-08-15
|
|---|---|---|
| Licence type | Electronic Money Institution under the Financial Institutions Act (Cap. 376). | 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 | Malta Financial Services Authority (MFSA). | Banco de Espana (Bank of Spain) |
| Capital requirement | Malta capital requirement is included in the £349 pass. | Spain capital requirement is included in the £349 pass. |
| Timeline to authorisation | Malta timeline to authorisation is included in the £349 pass. | Spain timeline to authorisation is included in the £349 pass. |
| Local substance | Malta local substance is included in the £349 pass. | Spain local substance is included in the £349 pass. |
| Application cost | Malta application cost is included in the £349 pass. | Spain application cost is included in the £349 pass. |
| Ongoing cost | Malta ongoing cost is included in the £349 pass. | Spain ongoing cost is included in the £349 pass. |
| Passporting | Malta passporting is included in the £349 pass. | Spain passporting is included in the £349 pass. |
| EMIs authorised | Malta emis authorised is included in the £349 pass. | Spain emis authorised is included in the £349 pass. |
| Key restrictions | Malta key restrictions is included in the £349 pass. | Spain key restrictions is included in the £349 pass. |
| Safeguarding | Malta safeguarding is included in the £349 pass. | Spain 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. | Spain will need to align its separate payment-institution and e-money statutes with the single PSD3 framework. 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 | Malta difficulty rating is included in the £349 pass. | Spain 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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