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| Dimension |
Pinned 🇩🇪 Germany partly open Verified 2026-08-15
|
🇬🇧 United Kingdom
Free in full
Verified 2026-08-15
|
|---|---|---|
| Licence type | E-Geld-Institut under the ZAG. | Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011. |
| Regulator | BaFin, with the Deutsche Bundesbank. | Financial Conduct Authority (FCA). |
| Capital requirement | Germany capital requirement is included in the £349 pass. | AEMI GBP 350,000 initial plus own funds 2% of average outstanding e-money. SEMI no initial capital, capped below EUR 5m outstanding. |
| Timeline to authorisation | Germany timeline to authorisation is included in the £349 pass. | About 6 to 12 months including pre-application (statutory 3 months from a complete application). |
| Local substance | Germany local substance is included in the £349 pass. | UK entity with UK mind and management, MLRO, adequate local staffing. |
| Application cost | Germany application cost is included in the £349 pass. | FCA application fee GBP 5,640 for an authorised EMI (Category 5) or GBP 1,130 for a small EMI (Category 3). Professional and implementation costs are project-specific. |
| Ongoing cost | Germany ongoing cost is included in the £349 pass. | FCA periodic fees, annual safeguarding audit, compliance headcount. |
| Passporting | Germany passporting is included in the £349 pass. | None after Brexit, no EEA passport. |
| EMIs authorised | Germany emis authorised is included in the £349 pass. | Around 338 e-money firms on the FCA register including small EMIs, the largest EMI population in Europe. |
| Key restrictions | Germany key restrictions is included in the £349 pass. | No interest on e-money, no deposit-taking; a SEMI cannot provide AIS or PIS. |
| Safeguarding | Germany safeguarding is included in the £349 pass. | Segregation or insurance or comparable guarantee. FCA Supplementary safeguarding regime (Policy Statement PS25/12, published 7 August 2025) in force from 7 May 2026: daily reconciliations, monthly regulatory reporting, annual safeguarding audit by a qualified auditor, resolution pack, third-party due diligence; audit exemption below GBP 100k. Stage 2 CASS-style statutory trust (Post-Repeal Regime) still under FCA review, not yet confirmed. |
| 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. | FCA safeguarding reform live from 7 May 2026 (first monthly REP027 return fell due 21 July 2026). HM Treasury's Modernising Payment Services Regulation consultation, published 14 July 2026, proposes rebuilding the PSRs 2017 and EMRs 2011 into a single FCA-rulebook framework spanning fiat, tokenised deposits and UK qualifying stablecoins; it closes 6 October 2026. |
| Difficulty rating | Germany difficulty rating is included in the £349 pass. | 4. Rigorous on financial crime and safeguarding, very large market. |
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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