Comparative analysis of EMI licencing and authorisation between the Baltic States

Abstract

The EU has a framework in place to regulate electronic money services, primarily governed by the Directive 2009/110/EC (Electronic Money Directive, EMD). This directive lays down the legal framework for the issuance of electronic money and the operation of electronic money institutions within the EU and has to be implemented in national laws of the Member States. The Baltic countries have recently been a “hub” for electronic money institutions (EMI), due to regulatory sandboxes and comprehensive authorization process. However, there is a big discrepancy between the operating EMIs, with Latvia and Estonia having only a few and Lithuania being a leader for licensed EMIs, because of regulatory benefits and more business-driven approach. The thesis focuses on comparing the authorization process for EMIs in the Baltics and legal challenges affecting the authorization process that may arise from external factors, that are derived from practice of already operating EMIs, as well as finding the potential challenges that may arise when the new Payment Service Regulations package from EU comes into force.