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| Dimension |
Pinned 🇱🇮 Liechtenstein partly open Verified 2026-07-03
|
🇬🇧 United Kingdom
Free in full
Verified 2026-08-01
|
|---|---|---|
| Licence type | E-money institution licence under the E-Geldgesetz (EGG, E-Money Act of 17 March 2011), Liechtenstein's EMD2 transposition; FMA-Guidance 2018/18 sets out the licensing process | Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011. |
| Regulator | Financial Market Authority Liechtenstein (Finanzmarktaufsicht, FMA) | Financial Conduct Authority (FCA). |
| Capital requirement | Liechtenstein 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 | Liechtenstein 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 | Liechtenstein local substance is included in the £349 pass. | UK entity with UK mind and management, MLRO, adequate local staffing. |
| Application cost | Liechtenstein application cost is included in the £349 pass. | FCA application fee GBP 5,580 for an authorised EMI (Category 5) or GBP 1,120 for a small EMI (Category 3), plus roughly GBP 75k to 200k professional; representative all-in around GBP 145k (~EUR 168k at 1.16). |
| Ongoing cost | Liechtenstein ongoing cost is included in the £349 pass. | FCA periodic fees, annual safeguarding audit, compliance headcount. |
| Passporting | Liechtenstein passporting is included in the £349 pass. | None after Brexit, no EEA passport. |
| EMIs authorised | Liechtenstein 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 | Liechtenstein key restrictions is included in the £349 pass. | No interest on e-money, no deposit-taking; a SEMI cannot provide AIS or PIS. |
| Safeguarding | Liechtenstein 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 will merge the payment institution and EMI regimes into one licence that can issue e-money. Final texts published 23 April 2026, applicability targeted around 2028; existing EMIs are grandfathered but must update their file. | 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 | Liechtenstein 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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