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Payment Institution licence vs Electronic Money Licence: What EU EMIs need to know about the 2026 requalification
['Angela Scott-Briggs']
TechBullion
A payment institution licence has become an increasingly important alternative to an electronic money institution licence as European supervisors narrow the legal concept of electronic money.
Payment institution versus electronic money institution: what changedAn entity holding a payment institution licence executes payment transactions, operates payment accounts, issues payment instruments and provides related services under the Second Payment Services Directive, but does not issue electronic money.
If the function is a payment service, the applicable regime is that of a payment institution licence.
The clearest surviving example of genuine electronic money is the electronic money token under the Markets in Crypto-Assets Regulation.
ConclusionThe distinction between a payment institution licence and an electronic money institution licence is collapsing into a question of function rather than licence label.