Pin and benchmark
Pin one jurisdiction. Line up to five rivals against it. Deltas show where each peer is better or worse.
Sign in to watch these jurisdictions for changes.
| Dimension |
Pinned 🇳🇱 Netherlands partly open Verified 2026-08-15
|
🇪🇸 Spain
partly open
Verified 2026-08-15
|
|---|---|---|
| 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 included in the £349 pass. | Spain capital requirement is included in the £349 pass. |
| Timeline to authorisation | Netherlands timeline to authorisation is included in the £349 pass. | Spain timeline to authorisation is included in the £349 pass. |
| Local substance | Netherlands local substance is included in the £349 pass. | Spain local substance is included in the £349 pass. |
| Application cost | Netherlands application cost is included in the £349 pass. | Spain application cost is included in the £349 pass. |
| Ongoing cost | Netherlands ongoing cost is included in the £349 pass. | Spain ongoing cost is included in the £349 pass. |
| Passporting | Netherlands passporting is included in the £349 pass. | Spain passporting is included in the £349 pass. |
| EMIs authorised | Netherlands emis authorised is included in the £349 pass. | Spain emis authorised is included in the £349 pass. |
| Key restrictions | Netherlands key restrictions is included in the £349 pass. | Spain key restrictions is included in the £349 pass. |
| Safeguarding | Netherlands 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 | Netherlands 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.
One-question research
Did this page help you reach the next useful outcome?
No email is collected. An optional short note helps us understand what is missing.