Digital Payments & Fintech - Luxembourg

The CSSF is the single competent authority for payments and e-money. The Law of 10 November 2009 on payment services (as amended) transposes PSD2 (Directive (EU) 2015/2366) and the E-Money Directive 2009/110/EC; no entity established in Luxembourg may provide payment services or issue e-money without CSSF authorisation.

Prospective PIs and EMIs file a detailed application with the CSSF; the licence is formally granted by the Minister on the CSSF's recommendation. Minimum initial capital ranges from EUR 20,000–125,000 for PIs (depending on services) and EUR 350,000 for EMIs, with head office and central administration required in Luxembourg.

Open banking is in force: account-servicing PSPs must give licensed third-party providers (AISPs and PISPs) access to payment accounts based on customer consent. AISPs are subject to CSSF registration rather than full authorisation.

The EU Instant Payments Regulation (EU) 2024/886 applies directly: euro-area banks had to receive SEPA instant credit transfers from 9 January 2025 and send them from 9 October 2025 (PIs/EMIs by 9 April 2027), with no surcharge above standard transfers. Luxembourg banks settle via the ECB's TIPS platform, accessed through the Banque centrale du Luxembourg (BCL).

Crypto-asset service providers (CASPs) and ART/EMT issuers are regulated under EU Regulation (EU) 2023/1114 (MiCA), in force since 30 December 2024. The Law of 6 February 2025 designated the CSSF as the sole national MiCA authority; pre-existing VASPs benefit from a transitional/grandfathering period until 1 July 2026.

Buy-now-pay-later credit is being brought under the revised EU Consumer Credit Directive (Directive (EU) 2023/2225), to be transposed nationally and applied by November 2026. The EU is also negotiating PSD3 and a Payment Services Regulation that will eventually supersede the current PSD2-based regime.