EMD2 / EMD3

E-money, issued without the drag .

From EMI authorisation to safeguarding reconciliations and redemption operations — ComplyBridge covers the E-Money Directive lifecycle, and brings the emerging EMD3 / Payment Services Regulation changes in as a controlled delta rather than a rebuild.

At a glance

€350k

Minimum own funds for an EMI licence

2%

Of average outstanding e-money (Method D)

D+1

Safeguarding reconciliation cadence

EMD3 alignment with PSR

Expected 2026

EMI regime folds into the PSD3 / PSR package

One EMI programme, from day-one authorisation to day-1,000 supervision.

The E-Money Directive is the EU framework governing the issuance of electronic money and the operation of e-money institutions (EMIs). It sits alongside PSD2 — and will increasingly be subsumed into the PSD3 / Payment Services Regulation package — to provide a single model for payment and e-money services across the Union.

Most firms building wallets, prepaid cards, stored-value accounts, or stablecoin-adjacent products touch the EMD regime. ComplyBridge is built so the authorisation phase, the safeguarding operations, and the eventual EMD3 transition all run on the same spine — no reshuffles, no parallel stacks.

What EMD covers.

The directive captures the full lifecycle of electronic money — issuance, distribution, redemption, and safeguarding of the funds behind it.

E-money institutions

Full EMI authorisation to issue, distribute, and redeem electronic money across the EU.

Small EMIs

Simplified regime for firms under average outstanding e-money of €5M, with proportionate requirements.

Safeguarding of funds

Segregation, insurance, or bank-guarantee options for user funds — with daily reconciliation evidence.

Issuance & redemption

At par, without unjustified fees, and within the statutory timeframes. Redemption SLAs tracked.

Own-funds monitoring

Method A / B / C / D calculation with live monitoring against the higher of the relevant floor.

Passporting

Freedom to provide services and freedom of establishment notifications across the 27 EU member states.

What we handle, day in day out.

EMI compliance is mostly operational work. ComplyBridge automates the checks and the evidence so your team focuses on the commercial side of the product.

  • Safeguarding reconciliation against client funds with daily bank-level evidence.
  • Own-funds method calculation (A / B / C / D) with live floor monitoring.
  • Redemption at par — SLA monitoring and unjustified-fee audit.
  • Outstanding e-money reporting, agent register, and distributor oversight.
  • Major-incident classification aligned with EBA guidelines and PSR expectations.
  • Passporting register with per-member-state confirmation status.

From EMI licence to EMD3 transition.

Whether you're applying for your first EMI licence or keeping a mature book clean, the path is the same four steps.

01

Scope & structuring

Confirm whether full EMI or small-EMI is the right perimeter; map the exact services in scope.

02

License build

Generate the EMI authorisation pack — business plan, capital model, safeguarding arrangement, governance map.

03

Go-live operations

Stand up daily safeguarding reconciliation, own-funds monitoring, and redemption-SLA instrumentation.

04

EMD3 / PSR transition

As the EMD folds into PSD3 / PSR, we flag the deltas, stage the policy updates, and keep supervisory peace.

Frequently Asked Questions

Common questions about EMD2 / EMD3 and how ComplyBridge supports compliance.

  • Small-EMI works while your average outstanding e-money stays below €5M and you don't passport. If you plan to cross that threshold or serve customers in other member states, full EMI is the right starting point — transitions from small-EMI to full EMI mid-flight are expensive. We size it with you in the first session.

  • You either segregate client funds in a dedicated safeguarding account at a credit institution, invest them in secure low-risk assets (subject to NCA approval), or cover them with an eligible insurance policy or bank guarantee. ComplyBridge supports all three and keeps the daily reconciliation evidence the NCA will eventually ask for.

  • The headline shift is consolidation: the EMI regime is folding into the Payment Services Regulation alongside PI / PSD3. The substance stays familiar — safeguarding, own funds, redemption at par — but the rulebook becomes directly applicable EU law, with sharper fraud-liability and technical-standards expectations. We roll the changes out as a staged migration.

  • Yes. We manage the freedom-to-provide-services and freedom-of-establishment notifications to host NCAs, track confirmation per member state, and maintain the passport register supervisory reviews routinely check.

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