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Payment and e-money application gap checker.

Identify FCA application gaps before submitting an SPI, API, small EMI or EMI application, with a readiness score and the items to complete in order of priority.

Run the check.

Thirteen questions on your application pack, set by the application type. The result appears on this page.

Which application are you preparing?
Is a regulatory business plan written for your own business, with a three-year budget forecast?
Is there a flow of funds showing every account, party and step that customer money passes through?
Are the directors and the persons responsible for payment services appointed, with fitness and propriety evidence?
Is an MLRO appointed with experience matched to your products, customers and corridors?
Is every controller holding 10% or more identified, with ownership chart and source of wealth evidence?
Is the safeguarding arrangement designed, with a safeguarding account provider identified?

Small payment institutions may choose to safeguard; answer for the arrangement you will run.

Are the business-wide risk assessment and AML and sanctions policies written for your own customers and products?
Are the operational and security risk, incident, business continuity and complaints procedures written?
Are your outsourced providers selected, with due diligence and agreed terms?
Is a wind-down plan prepared, showing how customers are repaid if the business closes?
Is the FCA application form drafted, with every question answered and cross-referenced to your documents?
Answer each highlighted question to see your result.

How the result is worked out.

The rules the tool applies, in full. The result is guidance from your answers; the firm confirms it in a written proposal the same day.

Each answer scores 2 for “In place”, 1 for “In progress” and 0 for “Not started”. Priority items count double. The score is the total as a percentage of the maximum for the questions that apply to your firm.

ResultScore
Ready for final review85% or above, with no priority item at its lowest answer
Targeted work before submission60% to 84%, or 85% and above with a priority item at its lowest answer
Build the foundations firstBelow 60%

Priority items

  • Regulatory business plan
  • Flow of funds
  • Initial capital
  • Directors and responsible persons
  • MLRO
  • Controllers
  • Safeguarding arrangement
  • Financial crime framework
  • Wind-down plan

The capital and projections questions apply to authorised payment institutions and authorised EMIs, which hold initial capital before authorisation. Priority items are those the FCA most often returns an application for, according to its published feedback on payment and e-money applications.

Questions firms ask.

Why check an application before submitting it?

The FCA assesses an application as submitted. A complete application starts the three-month statutory period; missing or generic documents lead to questions that extend the assessment, or to the application being returned.

Which items does the FCA most often question?

Business plans written from templates, unclear flows of funds, capital without evidence of its source, financial crime frameworks that do not match the business, and wind-down plans without costs or triggers.

Does the checker cover small institutions?

Yes. Choose the application type first; the questions that apply only to authorised firms, such as initial capital, are hidden for small payment institutions and small EMIs.

Is my result stored?

No. The check runs in your browser and nothing is sent unless you choose to send the result to the firm through the contact form.

What does a pre-submission review involve?

A review of the full pack against the FCA’s form and its published expectations, with each gap and inconsistency set out in writing and closed before submission.

Speak to an expert.

A reply within three business hours and a written proposal on the licence, the requirements, the cost and the timing the same day.