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.
Sign in to watch these jurisdictions for changes.
| Dimension |
Pinned 🇲🇹 Malta partly open Verified 2026-07-03
|
🇪🇸 Spain
partly open
Verified 2026-07-03
|
|---|---|---|
| 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 locked. Unlock with the £349 pass. | Spain capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Malta timeline to authorisation is locked. Unlock with the £349 pass. | Spain timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Malta local substance is locked. Unlock with the £349 pass. | Spain local substance is locked. Unlock with the £349 pass. |
| Application cost | Malta application cost is locked. Unlock with the £349 pass. | Spain application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Malta ongoing cost is locked. Unlock with the £349 pass. | Spain ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Malta passporting is locked. Unlock with the £349 pass. | Spain passporting is locked. Unlock with the £349 pass. |
| EMIs authorised | Malta emis authorised is locked. Unlock with the £349 pass. | Spain emis authorised is locked. Unlock with the £349 pass. |
| Key restrictions | Malta key restrictions is locked. Unlock with the £349 pass. | Spain key restrictions is locked. Unlock with the £349 pass. |
| Safeguarding | Malta safeguarding is locked. Unlock with the £349 pass. | Spain safeguarding is locked. Unlock with the £349 pass. |
| Recent changes | 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. Ongoing reputational rebuild after FATF grey-listing (delisted 2022). | 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 | Malta 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.