A key regulatory enabler for building inclusive digital financial services is creating a special licensing window for electronic money issuers (EMIs). Because EMIs have a lower risk profile than banks, they require less regulatory oversight. A special licensing category that recognizes that their role is to store customer funds converted into e-money held in basic transaction accounts, not to extend credit based on such funds, can open the DFS market to new providers. While many countries have created nonbank e-money licenses to cater for this business, at least three countries have introduced a special banking licensing category – the payments bank license. This technical note analyzes the country context in which the payments banks licenses were crafted, and compares the advantages and disadvantages of the EMI license versus the payments bank license.