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
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🇬🇧 United Kingdom
Free in full
Verified 2026-07-03
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| 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 | Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011. |
| Regulator | De Nederlandsche Bank (DNB), acting as prudential supervisor under the Wft (with AFM as conduct supervisor) | Financial Conduct Authority (FCA). |
| Capital requirement | Netherlands 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 | Netherlands 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 | Netherlands local substance is locked. Unlock with the £349 pass. | UK entity with UK mind and management, MLRO, adequate local staffing. |
| Application cost | Netherlands 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 | Netherlands ongoing cost is locked. Unlock with the £349 pass. | FCA periodic fees, annual safeguarding audit, compliance headcount. |
| Passporting | Netherlands passporting is locked. Unlock with the £349 pass. | None after Brexit, no EEA passport. |
| EMIs authorised | Netherlands 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 | Netherlands 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 | Netherlands 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 | 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). | FCA safeguarding reform live from 7 May 2026; HM Treasury payments-law reform expected later in 2026. |
| Difficulty rating | Netherlands 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.