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Licence guide

Gibraltar e-money institution and payment institution licence.

Firms whose main market is the United Kingdom choose Gibraltar for its English law, English-language regulation, published service standards and access to the UK market.

Published 16 October 2026 · Last reviewed 17 October 2026 · Reviewed against the regulator’s current publications
GFSCRegulator
€350,000 EMIInitial capital
£11,250–£45,000Application fee
6 to 9 monthsOur realistic timeline
To 31 Dec 2026UK access

Firms we have licensed.

Selected engagements from more than 250 licences obtained since 2013, for payment, e-money, cryptoasset and consumer credit firms.

Since 2013Advising global payment firms
60+Countries licensed in
250+Licences obtained globally
Clients
ClearBankVolkswagenStaysureOval MoneyEMQCentus
nexpayPayment Institution

Obtained Nexpay’s FCA Authorised Payment Institution licence.

dzingElectronic Money Institution

Obtained Dzing Finance’s FCA Authorised Electronic Money Institution licence.

Payment Institution

Obtained Orbital’s FCA Authorised Payment Institution licence.

What you get

6 to 9 monthsLicence granted

Our realistic timeline from submission, set against the regulator’s own published figures.

Day oneReady to trade

Safeguarding, operating and settlement accounts opened alongside the application, so you trade on authorisation.

Your teamKey people in place

Candidates introduced for senior managers and non-executive directors, each assessed against the regulator’s standard.

Same dayWritten proposal

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

How the firm obtains the licence

  1. Scoping and proposal. The permission and the payment institution class, the capital and its source, the controllers and Regulated Individuals and the safeguarding arrangement are confirmed in writing, with the GFSC pre-application meeting and abridged business plan arranged.
  2. Application pack. The application form, the comprehensive business plan across its three stages, the controller forms, transfer pricing evidence and the signed Regulated Individual and non-executive director forms for each stage submission.
  3. Banking. The safeguarding account, the operating account and the settlement accounts in each currency are arranged through the firm’s relationships with institutions serving regulated firms in Gibraltar and the UK before the decision.
  4. Regulator engagement. Each stage is answered through one process with the evidence assembled, since the service-level clock pauses while the GFSC awaits information, until the decision; the standard is nine months for e-money and six for payment services.

Key people, banking and technology

You will need senior managers and non-executive directors, each approved by the GFSC as fit and proper, which takes 30 working days where it holds an interview.

Key peopleThe firm introduces candidates for senior managers and non-executive directors from its register of senior compliance, financial crime, risk and finance professionals, and assesses each against the regulator’s approval standard before they are put forward.
BankingSafeguarding, operating and settlement accounts, card acquiring and payment processing, arranged through the institutions that serve regulated firms, in parallel with the application.
TechnologyBespoke white-label technology for accounts, payments, wallets and card programmes, built and ready to go live with the licence.

One engagement and one timetable, from scoping to launch. Speak to an expert about the people, the banking and the technology for this licence.

The licence in detail

The regulator’s requirements, capital, timing, fees and the questions firms ask, from the regulator’s own publications.

Key takeaways
  • A firm issuing e-money in or from Gibraltar holds the E-Money Issuer permission; a firm providing payment services holds the Payment Service Provider permission; credit institutions and e-money issuers obtain permission for payment services rather than a separate licence, and agents are registered with the GFSC.
  • Initial capital is the higher of €350,000 and 2.2% of average outstanding e-money for an authorised e-money issuer, and €20,000, €50,000 or €125,000 for a payment institution by class.
  • Application fees are £45,000 for an EMI and £11,250, £22,500 or £45,000 for a payment institution by class, with £4,331 for a registered payment institution; annual base fees are £26,262 and £9,192 plus additional fees.
  • The statutory period is 15 months in total; the GFSC’s service standard is 9 months for e-money across three stages and 6 months for payment services, with the clock paused while information is awaited.
  • Gibraltar-authorised firms serve the United Kingdom by branch or cross-border services under transitional arrangements in effect until 31 December 2026 and expected to be renewed until the Gibraltar Authorisation Regime takes effect; EU passporting ended with Brexit.
  • The application runs in three stages after a pre-application meeting; the fee is paid in full at Stage 1 and all annual regulatory fees rose 3% from 1 April 2026.

Who needs the licence

Any firm issuing e-money, the E-Money Issuer permission, or providing payment services, the Payment Service Provider permission, in or from Gibraltar needs authorisation under Part 7 of the Financial Services Act 2019 and the payment services and e-money regulations made under it. Credit institutions and e-money issuers do not need a separate payment institution licence but obtain permission to carry on payment services; agents of a payment service provider are registered with the GFSC. Gibraltar is chosen by firms whose market is the United Kingdom: a Gibraltar authorisation gives access to the UK under the transitional arrangements and, in due course, the Gibraltar Authorisation Regime, from a jurisdiction with English law, English-language regulation and published service standards.

Permissions and classes

PermissionScopeInitial capitalPassporting
Authorised e-money issuerIssuing e-money and providing payment servicesHigher of €350,000 and 2.2% of average outstanding e-moneyUK under transitional arrangements
Small (registered) e-money issuerIssuing e-money within the small regime2.2% of average outstanding e-moneyNone
Payment institution, Class AMoney remittance€20,000UK under transitional arrangements
Payment institution, Class BPayment initiation and account information€50,000UK under transitional arrangements
Payment institution, Class CCash placement and withdrawal, payment execution including direct debits, cards and credit transfers, credit-backed execution, issuing and acquiring€125,000UK under transitional arrangements
Registered (small) payment institutionPayment services within the small regimeNot publishedNone

What the GFSC requires

  • Legal form and location. A Gibraltar firm whose rationale for establishing in Gibraltar and whose governance are set out at pre-application; board and committee terms of reference, Regulated Individual forms and non-executive director forms at Stage 3; one class of payment institution per firm, the highest applicable.
  • Capital. The higher of €350,000 and 2.2% of average outstanding e-money, projected at application, for an authorised e-money issuer; €20,000, €50,000 or €125,000 by class for a payment institution; a firm with several permissions may need the aggregate. The own funds method under the Payment Services Regulations is agreed with the GFSC before final approval.
  • Safeguarding. Adequate arrangements to protect customer funds and prevent their use for the issuer’s own account: segregation, or insurance or a comparable guarantee from a provider outside the group; records that distinguish each customer’s funds at any time; the arrangement demonstrable on an ongoing basis. Professional indemnity insurance is a Stage 3 item for payment institutions.
  • Controllers and individuals. A Controller Form for each controller; signed Regulated Individual and non-executive director forms; fitness and propriety assessed, with approvals in 30 working days with an interview or 10 without.
  • Governance and controls. Stage 2 covers governance, business continuity, IT and cyber, outsourcing, financial crime and AML/CFT, the risk framework and register and disaster recovery; Stage 3 covers conduct, the compliance structure, remuneration, conflicts, liquidity and solvency, internal audit, complaints, Consumer Duty and operational resilience where applicable.
  • Application pack. Pre-application by email request, an introductory meeting and an abridged business plan, with a follow-up meeting and written feedback within four weeks; Stage 1 with the fee in full, the application form, Stage 1 of the comprehensive business plan, controller forms and transfer pricing evidence, after which a supervisor is assigned; Stage 2 and Stage 3 submissions; the annual base fee at licensing.

Capital

RequirementAmount
Authorised e-money issuerHigher of €350,000 and 2.2% of average outstanding e-money, projected at application
Small (registered) e-money issuer2.2% of average outstanding e-money
Payment institution, Class A (money remittance)€20,000
Payment institution, Class B (payment initiation and account information)€50,000
Payment institution, Class C (execution, issuing and acquiring)€125,000
Ongoing own fundsMethod under the Payment Services Regulations agreed with the GFSC before final approval

A firm holding several permissions may need the aggregate of the amounts.

Timing

FigureValueSource
Statutory decision periodUp to 12 months to determine an incomplete application plus 3 months for e-money and payment services, 15 months in totalGFSC Service Level Standards under the Financial Services Act 2019
Regulator’s published figure9 months maximum for e-money across three stages (5, 2 and 2 months) and 6 months for payment services (3, 2 and 1); the clock starts once the fee is paid and the application is complete and pauses while information is awaitedGFSC Service Level Standards
Application preparation6 to 8 weeksFrom instruction to submission, including banking in parallel
Our realistic timeline6 to 9 months after submissionThe firm’s own figure, from the regulator’s published data and its own applications

Figures published by the regulator are quoted as published and converted to months. The realistic timeline is the firm’s own, for a complete, well-prepared application.

Fees and costs

ItemAmountNotes
EMI application fee£45,000Fee Block A1; paid in full with the Stage 1 submission
EMI annual fee£26,262 base plus e-money feeE-money fee of £0 to £45,959 by average outstanding e-money, plus £262 per agent and £133 per distributor, plus the passporting fee
Payment institution application fee£11,250 Class A; £22,500 Class B; £45,000 Class CFee Block B1; registered payment institution £4,331
Payment institution annual fee£9,192 base plus additional feesAdditional Fee 1 by class: £9,192 Class A, £13,167 Class B, £17,070 Class C, £6,568 registered; a turnover-based Additional Fee 2; £262 per agent; the passporting fee
Agent appointment£250Per agent
Passporting annual fee£1,030 services; £5,150 establishmentPayable with the annual fee
UK passport application£3,000 services; £3,500, £11,000 or £40,000 establishmentEstablishment fee by complexity: non-complex, moderately complex, complex; agent passport notification £3,000; the FCA charges no notification fee
Professional feesFixed, in writingQuoted after scoping

Small regimes

A small, registered e-money issuer holds capital of 2.2% of average outstanding e-money and may not passport; a registered payment institution applies for £4,331 and pays a reduced annual fee. The GFSC’s pages state no thresholds for either regime.

Service standards by stage

StageContentE-moneyPayment services
Pre-applicationIntroductory meeting, abridged business plan, follow-up meeting with written feedbackWithin 4 weeksWithin 4 weeks
Stage 1Business model, capital, key individuals: application form, Stage 1 of the comprehensive business plan, controller forms, transfer pricing evidence; fee paid in full; supervisor assigned5 months3 months
Stage 2Risk, IT and cyber, governance, business continuity, outsourcing, financial crime and AML/CFT, risk framework and register, disaster recovery2 months2 months
Stage 3Conduct, compliance structure, remuneration, conflicts, liquidity and solvency, internal audit, complaints, Consumer Duty and operational resilience where applicable; signed Regulated Individual and non-executive director forms; professional indemnity insurance; mobilisation plan2 months1 month
Total service standardClock starts after the fee is paid and a complete application is received; pauses while information is awaited9 months6 months

Regulated Individual approvals take 30 working days with an interview and 10 without. The GFSC gives monthly progress updates and publishes quarterly authorisation statistics: in the second quarter of 2026 the e-money sector recorded 3 Regulated Individual applications, all approved within the 30-day standard, and in the first quarter 2 applications, both approved within 30 days.

Passporting and scope

EU passporting ended with Brexit. A Gibraltar-authorised firm may carry on its permitted activities in the United Kingdom by branch or cross-border services under Gibraltar’s Financial Services (Passport Rights and Transitional Provisions) (EU Exit) Regulations 2020 and the UK’s Financial Services (Gibraltar) (Amendment) (EU Exit) Regulations 2019, which have effect until 31 December 2026 and are expected to be renewed until the Gibraltar Authorisation Regime comes into effect; the FCA confirms the arrangement runs until 31 December 2026 and may be extended, and the deadline was extended on 11 December 2023, 10 January 2025 and 19 December 2025. The regime itself is in section 22 and Schedule 6 of the Financial Services Act 2021, inserting Schedule 2A into FSMA 2000; the insertion came into force on 1 September 2023 for specified purposes only and full commencement is phased, so at October 2026 the transitional arrangements continue. A UK passport is a material change needing section 83A consent, then a notification to the GFSC, which notifies the FCA; the FCA processes it within one month under regulation 27(3) of the Payment Services Regulations 2017 and charges no fee. Passporting services is classed non-complex; passporting a branch is complex. Registered e-money issuers may not passport.

Why applications are delayed

The GFSC publishes how its standards operate. The service-level clock starts only once the fee is paid and the application is complete, and pauses while the GFSC awaits requested information; progression between stages depends on the GFSC being satisfied with each stage; a rejection or conditions add one month to variation and change of control timelines; and pre-application feedback is not an indicator of the final decision. The points settled before Stage 1 are the class, the capital and its source, the controllers and Regulated Individuals, and the safeguarding arrangement.

Banking

An EMI needs a safeguarding account that satisfies the GFSC’s requirements, an operating account and settlement accounts in the currencies it serves; a payment institution needs the same without the e-money float. The firm arranges each through institutions that serve regulated firms in Gibraltar and the United Kingdom, during the application, so the firm trades on authorisation. See banking and payment processing.

Questions firms ask

How long does a GFSC authorisation take?

The statutory maximum is 15 months. The GFSC’s service standard is 9 months for e-money across three stages and 6 months for payment services, with the clock paused while it awaits information. The firm plans for six to nine months after submission.

What does a Gibraltar licence cost?

£45,000 on application for an EMI and £11,250, £22,500 or £45,000 for a payment institution by class, with annual base fees of £26,262 and £9,192 plus additional fees by e-money outstanding, class, turnover and agents.

Can a Gibraltar firm serve the UK?

Yes, by branch or cross-border services under transitional arrangements in effect until 31 December 2026 and expected to be renewed until the Gibraltar Authorisation Regime takes effect. The passport is a material change needing GFSC consent and a notification to the FCA.

Can a Gibraltar firm passport into the EU?

No. EU passporting ended with Brexit; groups serving the EU hold an EU authorisation alongside, which the firm obtains.

Is there a small regime?

Yes: a registered e-money issuer at 2.2% of average outstanding e-money and a registered payment institution with a £4,331 application fee, neither of which may passport; the GFSC’s pages state no thresholds for either.

References

  1. GFSC: electronic money issuer
  2. GFSC: payment service provider
  3. GFSC: service level standards
  4. Financial Services (Fees) Regulations 2020, consolidated 3 September 2026
  5. GFSC: passporting
  6. FCA: passporting between the UK and Gibraltar

About Buckingham Capital Consulting

A regulatory advisory firm to payment, e-money and cryptoasset companies since 2013, with more than 250 licences obtained in more than 60 countries. The firm advises on authorisation, compliance, safeguarding, banking and transactions, and builds the white-label payment and card technology its clients launch on.

A written proposal on cost, timing and requirements, the same day: speak to an expert.

This guide is general information for firms considering authorisation and is reviewed against the regulator’s published requirements. It is not legal advice; requirements and fees change, and the regulator’s current publications take precedence.

How we work.

  • Senior-ledEvery engagement is led by the practitioners who prepare the application and attend the regulator.
  • Same dayA reply within three business hours and a written proposal the same day: the licence, the requirements, the cost and the timing, before you commit.
  • ConfidentialYour plans, your application and any listing stay private. Clients are named only with their agreement.
  • Live workspaceEvery engagement runs in a shared workspace on Hector: documents, regulator questions, messages and progress in one place, visible to your team at every stage.

Why firms choose BCC.

  • OperatorsWe have taken firms through licensing, run regulated payments and consumer credit businesses, and signed the regulatory returns ourselves.
  • BankingSafeguarding, operating and settlement accounts arranged alongside the authorisation, through the institutions that serve this market.
  • FoundersThe firm is run by founders who have built and run regulated payments businesses, so every position is given with the launch date and the cost of waiting in mind.
  • One firmLicensing, key people, banking, compliance, technology and transactions from the same team, for the life of the regulated firm.

Apply for this licence.

The requirements, the cost and the timing for your business, in a written proposal the same day.