RegAlert

Luxembourg: fintech & payments regulation — 2026-09

Regulated

Luxembourg fintech: CSSF regulates payments under PSD2; e-money requires LIC/EMF licence

Frozen snapshot — the guide as it stood at the end of 2026-09. See the live guide for the current state.

Luxembourg is a mature fintech hub where the CSSF supervises payment and e-money activities under the transposition of the EU Payment Services Directive (PSD2). The regime is strictly regulated, requiring specific authorisation for payment services and e-money issuance. Recent regulatory focus has shifted towards ICT risk management, relationship management, and the implementation of the EU Travel Rule for crypto-assets.

Which licence do you need?

Your activityRequirementCapitalTimelineAuthority
Payment processing / gatewayLicencePayment Institution

Requires own funds and initial capital per PSD2

EUR 20,000 (initial) / EUR 20,000 (own funds)6-9 monthsCSSF
E-money & wallet issuanceLicenceElectronic Money Institution

Strict capital and governance requirements

EUR 350,0006-9 monthsCSSF
Domestic money transferLicencePayment Institution

Domestic transfers fall under Payment Institution scope

EUR 20,000 (initial) / EUR 20,000 (own funds)6-9 monthsCSSF
Cross-border remittanceLicencePayment Institution

Cross-border payments require full Payment Institution licence

EUR 20,000 (initial) / EUR 20,000 (own funds)6-9 monthsCSSF
Agent networkRegistrationPayment Institution Agent

Agents must be registered with the CSSF

——CSSF
Open banking / account informationLicencePayment Institution / AISP

Account Information Service Providers require authorisation

——CSSF
Foreign-exchange servicesLicencePayment Institution

FX services are payment services under PSD2

EUR 20,000 (initial) / EUR 20,000 (own funds)6-9 monthsCSSF

New — what changed recently

  • 2025-04-09Circular CSSF 25/880 — Established new requirements for relationship management of payment service users and ICT assessment.[1]
  • 2025-04-08Circular CSSF 25/879 — Adopted EBA Travel Rule Guidelines on fund and crypto-asset transfers, repealing previous circulars.[2]
  • 2025-12-23Circular CSSF 25/903 — Updated annual reporting and auditor engagement rules for support Payment Financing Services entities.[3]

Market-entry checklist

  1. 1Establish legal entity in LuxembourgIncorporate a company with a registered office and effective direction in Luxembourg.
  2. 2Secure minimum capitalDeposit EUR 300,000 for Payment Institutions or EUR 350,000 for E-Money Institutions.
  3. 3Appoint fit and proper directorsEnsure management body members have sufficient experience and good repute.
  4. 4Submit authorisation applicationFile a detailed application with the CSSF including business plan and governance structure.
  5. 5Implement AML/CFT frameworkEstablish robust anti-money laundering and counter-terrorist financing procedures.
  6. 6Register agents with CSSFIf using agents, ensure they are registered with the CSSF before commencing activities.

Sources

  1. Circular CSSF 25/880 on relationship management of payment service users and PSP ICT assessment · 2025-04-09
  2. CSSF Circular 25/879: Adoption of EBA Travel Rule Guidelines on Fund and Crypto-Asset Transfers · 2025-04-08
  3. Circular CSSF 25/903 — Update of Circular CSSF 24/850 on annual reporting and auditor engagement for support PFS · 2025-12-23