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
|
🇪🇸 Spain
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 | 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 | De Nederlandsche Bank (DNB), acting as prudential supervisor under the Wft (with AFM as conduct supervisor) | Banco de Espana (Bank of Spain) |
| Capital requirement | Netherlands capital requirement is locked. Unlock with the £349 pass. | Spain capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Netherlands timeline to authorisation is locked. Unlock with the £349 pass. | Spain timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Netherlands local substance is locked. Unlock with the £349 pass. | Spain local substance is locked. Unlock with the £349 pass. |
| Application cost | Netherlands application cost is locked. Unlock with the £349 pass. | Spain application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Netherlands ongoing cost is locked. Unlock with the £349 pass. | Spain ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Netherlands passporting is locked. Unlock with the £349 pass. | Spain passporting is locked. Unlock with the £349 pass. |
| EMIs authorised | Netherlands emis authorised is locked. Unlock with the £349 pass. | Spain emis authorised is locked. Unlock with the £349 pass. |
| Key restrictions | Netherlands key restrictions is locked. Unlock with the £349 pass. | Spain key restrictions is locked. Unlock with the £349 pass. |
| Safeguarding | Netherlands safeguarding is locked. Unlock with the £349 pass. | Spain 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/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 | Netherlands 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.