New Measures Against Abuse of Alternative Payment Systems
As part of the measures against abuse of alternative payment systems developed in Prop. 2024/25:67, all payment services except account information services, currency exchange and all issuance of e-money will be subject to authorisation as of 1 July 2025. The main changes are introduced by four laws, the Act (1996:1006) on Currency Exchange and Other Financial Activities, the Payment Services Act (2010:751), the Electronic Money Act (2011:755) and the new the Currency Exchange Act (2025:250). The ability to monitor and counter money laundering and terrorist financing will be enhanced by making currency exchange, all issuance of electronic money and all payment services except account information services subject to authorisation rather than registration.
Summary of the Legislative Changes
- The amendments to the Payment Services Act (2010:751) makes all payment services except account information services subject to authorisation. Previously, certain companies that met a number of conditions, including a 12-month average payment volume of less than €3 million, were able to apply for an exemption from the authorisation requirement and did not have to comply with anti-money laundering and counter-terrorist financing rules.
- According to the new the Currency Exchange Act (2025:250) only payment institutions, electronic money institutions, credit institutions and branches of corresponding foreign companies, all of which are subject to authorisation, may engage in currency exchange. This means that many of the types of activities that were previously allowed to provide currency exchange services under the Act on Currency Exchange and Other Financial Activities must now apply for authorisation to continue providing currency exchange services.
- The amendments to the Electronic Money Act (2011:755) removes the possibility for electronic money issuers with average outstanding liabilities related to electronic money of less than €5 million to apply for an exemption from authorisation. This means that all firms providing the service of issuing electronic money will be subject to authorisation.
- All companies providing payment services (including account information services), currency exchange services and electronic money issuance must now comply with the rules to prevent money laundering and terrorist financing under the Act (2017:630) on measures against money laundering and terrorist financing.
According to the transitional provisions of the current legislative amendments, firms registered before 1 July 2025 may continue to provide their services until 31 December 2025. If such an undertaking applies for authorisation to operate as a payment institution, electronic money institution or credit institution by 31 December 2025, it may continue to operate under the previous regulatory framework until the application has been finally assessed.
Next Steps
If you are subject to the new legislative changes and need to apply for a licence to continue operating after the turn of the year, it is important to start the application well in advance. NFC has extensive experience of working with licence applications and offers support throughout the process. We can help you with everything from preparing a complete licence application, producing and developing risk frameworks, producing financial forecasts and performing capital requirement calculations. Read more about our licence application services or contact us if you have questions or need help with your licence application.
