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 🇱🇺 Luxembourg partly open Verified 2026-07-03
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🇬🇧 United Kingdom
Free in full
Verified 2026-07-03
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| Licence type | Electronic Money Institution (EMI) authorisation under the Law of 10 November 2009 on payment services, as amended by the Law of 20 July 2018 (transposing PSD2); this same law also transposed EMD2's e-money provisions. No prominent separate small-EMI regime; EMIs are typically authorised as full EMIs given Luxembourg's fund/institutional client base. | Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011. |
| Regulator | Commission de Surveillance du Secteur Financier (CSSF) | Financial Conduct Authority (FCA). |
| Capital requirement | Luxembourg capital requirement is locked. Unlock with 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 | Luxembourg timeline to authorisation is locked. Unlock with the £349 pass. | About 6 to 12 months including pre-application (statutory 3 months from a complete application). |
| Local substance | Luxembourg local substance is locked. Unlock with the £349 pass. | UK entity with UK mind and management, MLRO, adequate local staffing. |
| Application cost | Luxembourg application cost is locked. Unlock with the £349 pass. | FCA application fee (order of GBP 5,000 for AEMI) plus roughly GBP 75k to 200k professional. |
| Ongoing cost | Luxembourg ongoing cost is locked. Unlock with the £349 pass. | FCA periodic fees, annual safeguarding audit, compliance headcount. |
| Passporting | Luxembourg passporting is locked. Unlock with the £349 pass. | None after Brexit, no EEA passport. |
| EMIs authorised | Luxembourg emis authorised is locked. Unlock with the £349 pass. | Around 338 e-money firms on the FCA register including small EMIs, the largest EMI population in Europe. |
| Key restrictions | Luxembourg key restrictions is locked. Unlock with the £349 pass. | No interest on e-money, no deposit-taking; a SEMI cannot provide AIS or PIS. |
| Safeguarding | Luxembourg safeguarding is locked. Unlock with 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/PSR: EU agreement reached Nov 2025, texts published April 2026, repealing EMD2 with EMIs becoming a 'payment institution authorised to issue e-money' sub-category; Luxembourg's payment services law will need amendment within the transposition window, with transitional relief (24 months, extendable to 30) for existing EMD2-authorised entities. CSSF also active on crypto/e-money-token overlap (MiCA e-money token issuer guidance). | FCA safeguarding reform live from 7 May 2026; HM Treasury payments-law reform expected later in 2026. |
| Difficulty rating | Luxembourg difficulty rating is locked. Unlock with 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.