Fintech & payments regulation in Denmark (2026)
Fintech and digital payments in Denmark: licensing regime.
Denmark operates a clear, in-force licensing regime for payments and fintech. Payment institutions and e-money institutions must be authorised by Finanstilsynet under the Danish Payments Act, which transposes the EU PSD2 and E-Money frameworks, and PSD2-based open banking (access to accounts via APIs) is enforced. Crypto-asset service providers fall under the EU MiCA Regulation (fully applicable since 30 December 2024) and BNPL credit was brought within the consumer-credit licensing regime in July 2023.
Legal framework
Danish Payments Act ('Lov om betalinger') implementing PSD2 and the E-Money Directive (EMD2), supervised by Finanstilsynet (Danish FSA); EU MiCA applies to crypto-asset services. BNPL/consumer credit governed by the Consumer Loan Undertakings Act and Credit Agreements Act.
How to get an EMI license in Denmark
To provide electronic-money or payment services in Denmark you need authorisation as an Electronic Money Institution (EMI), supervised by the Danish Financial Supervisory Authority (Finanstilsynet), under the EU E-Money Directive (2009/110/EC) and the Second Payment Services Directive (PSD2).
- Authority
- the Danish Financial Supervisory Authority (Finanstilsynet)
- License required
- authorisation as an Electronic Money Institution (EMI)
- Framework / law
- the EU E-Money Directive (2009/110/EC) and the Second Payment Services Directive (PSD2)
- Minimum capital
- €350,000 initial capital for a full (Authorised) EMI; a lighter Small EMI regime exists below an average €5m of outstanding e-money
- Timeline
- roughly 3–12 months; the regulator has up to 3 months to decide once the application is complete
- Cost
- application and supervisory fees that vary by country (often €5,000–€25,000), plus safeguarding and audit costs
- Passporting
- Yes: an EMI authorisation passports across the whole EEA (all 27 EU states plus Norway, Iceland and Liechtenstein).
What an EMI license in Denmark covers
- Issuing electronic money and maintaining payment accounts
- Executing payment transactions: credit transfers, direct debits and card payments
- Issuing and/or acquiring payment instruments
- Money remittance
- Payment initiation services (PIS)
- Account information services (AIS)
Step by step: getting an EMI license in Denmark
Incorporate in the member state and establish real local substance (registered office and part of the business conducted there).
Build the application file: programme of operations, three-year business plan, governance, AML/CFT, safeguarding and security policies.
Deposit and evidence the €350,000 initial capital.
Submit the application to the national competent authority.
The authority has three months from a complete application to grant or refuse.
On authorisation you are entered in the national and EBA registers, then passport into other EEA states before serving them.
Documents required in Denmark
- Programme of operations listing each payment service you will provide
- Business plan with a three-year budget forecast
- Evidence of the €350,000 initial capital
- Governance arrangements and internal-control mechanisms
- AML/CFT policy and appointment of a compliance officer
- Safeguarding arrangements for client funds (segregated account or insurance)
- Security policy, incident management and ICT resilience procedures
- Fit-and-proper documentation for directors and qualifying shareholders
- Description of any outsourcing, agents or distributors
- Professional indemnity insurance where you provide PIS or AIS
Ongoing obligations in Denmark
- Maintain own funds under the applicable calculation method (A, B or C)
- Safeguard client funds at all times, segregated or insured
- Apply strong customer authentication (SCA) under PSD2
- Run continuous AML/CFT monitoring and reporting
- Report major operational and security incidents to the regulator
- Submit annual audited accounts and periodic regulatory reporting
Key points: digital payments & fintech in Denmark
Competent authority & core law
Finanstilsynet (Danish FSA) licenses and supervises payment institutions and e-money institutions under the Danish Payments Act ('Lov om betalinger'), assessing financial soundness, governance, risk management, AML and cybersecurity before granting authorisation.
Payment & e-money licences
The Act provides distinct authorisations for payment institutions (full payment services, including fund transfers and payment-account management) and e-money institutions (issuing e-money such as digital wallets/prepaid cards), plus restricted/limited authorisations, transposing PSD2 and the E-Money Directive.
Open banking (PSD2)
Denmark enforces PSD2 through Finanstilsynet, requiring banks to provide APIs allowing licensed third-party providers to initiate payments and access account information with customer consent (AIS/PIS access to accounts).
Instant-payment rails
Denmark launched its instant A2A rail Straksclearing ('Express Clearing') in 2014; Danish-krone settlement migrated to the Eurosystem's TARGET Services in 2025, bridging to pan-European instant settlement (TIPS) and the EU Instant Payments Regulation.
Crypto-assets (MiCA)
The EU Markets in Crypto-Assets Regulation (MiCA) has been fully applicable in Denmark since 30 December 2024, with Finanstilsynet authorising and supervising crypto-asset service providers; the national transitional period ended 30 December 2025, and the FSA takes a notably strict line on what counts as genuinely decentralised/exempt.
Buy Now Pay Later (BNPL)
Effective 1 July 2023, bill L 58 amended the Consumer Loan Undertakings Act (lov om forbrugslånsvirksomheder) and Credit Agreements Act (kreditaftaleloven) to bring most BNPL providers under the consumer-credit licensing/creditworthiness regime; a narrow exemption remains only for interest- and fee-free seller-granted deferrals up to 90 days.
EMI license in Denmark: FAQ
Do you need a license to run an e-money business in Denmark?
Yes. To provide electronic-money or payment services in Denmark you need authorisation as an Electronic Money Institution (EMI), supervised by the Danish Financial Supervisory Authority (Finanstilsynet), under the EU E-Money Directive (2009/110/EC) and the Second Payment Services Directive (PSD2).
Which authority issues EMI licenses in Denmark?
The Danish Financial Supervisory Authority (Finanstilsynet).
How much does an EMI license cost in Denmark?
Application and supervisory fees that vary by country (often €5,000–€25,000), plus safeguarding and audit costs.
How long does it take to get an EMI license in Denmark?
Typically roughly 3–12 months; the regulator has up to 3 months to decide once the application is complete.
What documents do you need for an EMI license in Denmark?
The application file centres on programme of operations listing each payment service you will provide; business plan with a three-year budget forecast; evidence of the €350,000 initial capital; governance arrangements and internal-control mechanisms; plus fit-and-proper evidence for directors and qualifying shareholders.
What is the application process for an EMI license in Denmark?
Incorporate in the member state and establish real local substance (registered office and part of the business conducted there). Build the application file: programme of operations, three-year business plan, governance, AML/CFT, safeguarding and security policies. The authority then assesses the file and, once authorised, you can begin operating.
Does an Denmark EMI license work in other EU/EEA countries?
Yes: an EMI authorisation passports across the whole EEA (all 27 EU states plus Norway, Iceland and Liechtenstein).
Timeline of decisions
- DecisionEU Commission clears merger of MobilePay and Vipps
The Commission approved combining Denmark's MobilePay with Norway's Vipps into Vipps MobilePay, finding no competition concerns as the wallets operated in different national markets. It consolidated the dominant Nordic mobile-payment players serving roughly 11 million users.
Vipps MobilePay
- GuidanceFinanstilsynet grants 18-month extension for strong customer authentication
Citing an EBA opinion and e-commerce readiness, the Danish FSA delayed enforcement of PSD2 strong customer authentication for online card payments until 14 March 2021. It exemplified Denmark's pragmatic, phased rollout of the PSD2 security regime.
Lund Elmer Sandager (reporting Finanstilsynet)
- Law · officialDanish Payments Act enters into force, transposing PSD2 and the E-Money Directive
Act No. 652 of 8 June 2017 (lov om betalinger) took effect, establishing the licensing regime for payment institutions and e-money institutions and opening account access to third-party providers (AISPs/PISPs) under Finanstilsynet's supervision. It is the foundational statute governing how digital payments and fintech are licensed in Denmark today.
Retsinformation (Danish official gazette)
Sources
- forbrugerombudsmanden.dk/media/46537/payment-services-act.pdf
- dfsa.dk/
- nationalbanken.dk/en/what-we-do/safe-and-efficient-payments/the-payments-infrastructure
- dfsa.dk/news/2024/jun/crypto-assets_250624
- esma.europa.eu/esmas-activities/digital-finance-and-innovation/markets-crypto-assets
- ecb.europa.eu/paym/retail/instant_payments/html/instant_payments_regulation.en.html
- plesner.com/insights/articles/2022/07/new-bill-to-regulate-buy-now-pay-later-cred
- twobirds.com/en/trending-topics/buy-now-pay-later-regulatory-tracker/denmark
- lexology.com/library/detail.aspx?g=9a1b96e2-5db9-4ad6-b35f-db3f2490654d
- plesner.com/insights/articles/2017/02/ny-betalingslov?sc_lang=en
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