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API vs SPI vs RAISP vs EMI: Which UK Payment Licence Should You Get in 2026?

Published 5 May 2026 · Last reviewed 17 October 2026 · Buckingham Capital Consulting
Contents
  1. The five UK payment licences in brief
  2. At-a-glance comparison
  3. Authorised payment institution (API)
  4. Small payment institution (SPI)
  5. Registered account information service provider (RAISP)
  6. Authorised electronic money institution (authorised EMI)
  7. Small electronic money institution (small EMI)
  8. API or EMI: the decision most firms face
  9. How to choose: a decision framework
  10. Common scenarios and the right licence
  11. Running costs and obligations by licence
  12. Launching before your own licence: agents and distributors
  13. What banks, card schemes and investors look for in your licence choice
  14. How Buckingham Capital Consulting can help
  15. Frequently asked questions
Key takeaways
  • An API pays a £2,820 or £5,640 FCA fee and holds €20,000, €50,000 or €125,000 initial capital; an authorised EMI pays £5,640 and holds €350,000.
  • SPI, RAISP and small EMI registrations each cost £1,130; the SPI is limited to a €3m monthly average and the small EMI to €5m of outstanding e-money.
  • Only APIs and authorised EMIs can provide payment initiation; RAISPs provide account information only and hold professional indemnity insurance instead of capital.
  • CASS 15 safeguarding, in force since 7 May 2026, applies to APIs holding customer funds and to all EMIs; SPIs may safeguard voluntarily.
  • Moving from SPI to API, small EMI to authorised EMI, or API to EMI is a new application, not a variation of permission.
  • The firm plans API and authorised EMI applications at 6 to 8 months from submission, and registrations at weeks to a few months.

The five UK payment licences in brief

The FCA grants five licences for non-bank payment and e-money businesses. Two are authorisations under the Payment Services Regulations 2017 (PSRs) and the Electronic Money Regulations 2011 (EMRs); three are registrations, with lighter requirements and limits on size or scope.

  • Authorised payment institution (API): any of the eight payment services, with no volume limit.
  • Small payment institution (SPI): payment services up to a €3m monthly average, without account information or payment initiation.
  • Registered account information service provider (RAISP): account information services only.
  • Authorised electronic money institution (authorised EMI): e-money issuance plus all payment services, with no volume limit.
  • Small electronic money institution (small EMI): e-money issuance up to €5m of average outstanding e-money and payment services up to a €3m monthly average.

This guide is written for founders, finance directors, general counsel and investors choosing between them. The right licence follows from the business model, the expected volumes, the services and the growth plan, in that order.

At-a-glance comparison

Fees and capital

LicenceFCA application feeInitial capital
API£2,820 (services f to h only) or £5,640€20,000, €50,000 or €125,000
SPI£1,130None
RAISP£1,130None; professional indemnity insurance
Authorised EMI£5,640€350,000
Small EMI£1,130None below €500,000 average outstanding e-money, then 2%

Limits and services

LicenceVolume limitPayment initiation and account information
APINoneBoth permitted
SPI€3m monthly average of payment transactionsNeither
RAISPNoneAccount information only
Authorised EMINoneBoth permitted
Small EMI€5m average outstanding e-money; €3m monthly unrelated paymentsNeither

Safeguarding and timeline

LicenceCASS 15 safeguardingFirm's planning figure, submission to decision
APIRequired where it holds customer funds6 to 8 months
SPIOptional; the firm may choose to safeguardWeeks to a few months
RAISPNot applicable; holds no fundsWeeks to a few months
Authorised EMIRequired6 to 8 months
Small EMIRequiredA few months

No UK licence gives access to the EU: passporting ended on 31 December 2020. Fees are from the FCA's application fees page (updated 13 July 2026); the earlier figures of £1,120, £2,790 and £5,580 are out of date. The FCA must decide a complete application within 3 months and any application within 12 months; its median for payment and e-money authorisations in April to June 2026 was 219 days, about 7 months. Each cost is explained in our guide to FCA PI and EMI licence costs.

Authorised payment institution (API)

What it is

An API is authorised under the PSRs to provide payment services without being a bank. Merchant acquirers, money remitters, payment platforms, open banking firms and corporate payment providers are typical APIs.

What it can do

An API can provide all eight payment services in Schedule 1 to the PSRs: cash placement and withdrawal, executing transfers, credit-linked transfers, card issuing and merchant acquiring, money remittance, payment initiation and account information. There is no volume limit. An API cannot issue e-money, take deposits or lend customer funds; it can offer short-term credit linked to a payment only under strict conditions.

Capital

ServicesInitial capital
Money remittance only€20,000
Payment initiation€50,000
Any of services (a) to (e)€125,000

The highest applicable figure applies, not the sum. After authorisation the API holds own funds at least equal to the higher of its initial capital and a figure calculated under Method A, B or C, as the FCA directs.

Safeguarding and governance

An API that holds customer funds safeguards them under CASS 15, in force since 7 May 2026: daily reconciliation, a monthly safeguarding return, a resolution pack and an annual safeguarding audit. The FCA expects a UK-based leadership team with payments experience, including a CEO, a money laundering reporting officer (MLRO), compliance and finance capability, and a board that oversees the business. APIs are not under the Senior Managers and Certification Regime (SM&CR); the FCA assesses each director and manager at application.

Best for

  • Businesses above, or soon above, €3m of monthly payment volume.
  • Payment initiation or account information as a core service.
  • Merchant acquirers, scaled remitters and corporate payment platforms.

Buckingham Capital Consulting obtained FCA API authorisation for Nexpay, Orbital, Oval (with open banking) and Global Send. The API route is set out in our UK payment institution licence guide.

Small payment institution (SPI)

What it is

An SPI is registered, not authorised, for payment services where the monthly average of payment transactions over the previous 12 months, or projected for a new firm, does not exceed €3m. The applicant must be a UK company with its head office in the UK.

What it can do

An SPI can provide the payment services in paragraphs (a) to (f) of Schedule 1, including transfers, card issuing, merchant acquiring and money remittance. It cannot provide payment initiation or account information services, and it cannot issue e-money.

Capital, safeguarding and governance

There is no initial capital requirement. SPIs may choose to safeguard customer funds, and many adopt CASS 15 standards voluntarily to prepare for authorisation; the FCA encourages SPIs that safeguard to arrange an annual audit. The directors and managers must be fit and proper, the firm must comply with the Money Laundering Regulations 2017, and no manager may have a conviction for money laundering, terrorist financing or other financial crime.

Limits

  • The €3m monthly average is the limit that matters most in practice.
  • No payment initiation or account information services.
  • No access to the EU.

Best for

Early-stage firms testing a model, businesses whose volumes will stay under €3m a month, and niche remitters serving one corridor or community. Buckingham Capital Consulting obtained FCA SPI registration for Onpoint Money. Our SPI registration guide covers the route in full.

Registered account information service provider (RAISP)

What it is

A RAISP is registered to provide account information services only: with the customer's consent, it collects and consolidates data from the customer's payment accounts at banks and other providers, usually through open banking connections.

What it cannot do

A RAISP never holds customer funds, initiates payments, executes transactions or issues payment instruments or e-money.

Capital and insurance

There is no initial capital requirement. A RAISP must hold professional indemnity insurance, or a comparable guarantee, covering its liability to account providers and customers. The minimum cover is calculated using the method in the FCA's Approach Document.

Governance focus

Assessment concentrates on data security, consent management, compliance with UK data protection law and the firm's arrangements with account providers. Because no funds are handled, financial crime obligations are lighter than for a PI or EMI.

Best for

  • Account aggregation and personal finance apps.
  • Lending decisions based on bank data.
  • Accounting and tax software bank feeds.
  • Corporate cash visibility tools.

Adding payment initiation means applying for authorisation as an API, which is a new application rather than a change to the registration.

Authorised electronic money institution (authorised EMI)

What it is

An authorised EMI is authorised under the EMRs to issue e-money: stored monetary value, issued when a customer pays in funds and accepted as payment by others. Prepaid cards, digital wallets, stored-value accounts and most UK neobank products sit on an EMI licence.

What it can do

Everything an API can do, plus issuing, distributing and redeeming e-money, with no volume limit. An EMI cannot pay interest on e-money balances. It serves EU customers only through a separate entity authorised in an EU member state.

Capital

Initial capital of €350,000. After authorisation the EMI holds own funds of at least the higher of €350,000 and 2% of average outstanding e-money (Method D), plus a requirement under Method A, B or C for any payment services not linked to e-money. Method D passes the €350,000 floor at €17.5m of average outstanding e-money.

Safeguarding and governance

CASS 15 applies to all e-money in issue and to funds received for payment services. The FCA expects an experienced, UK-based leadership team with e-money or banking experience, robust risk management and independent challenge on the board in proportion to the size of the business. EMIs are not under SM&CR; the FCA assesses directors and managers at application.

Best for

  • Neobanks and multi-currency consumer or business accounts.
  • Prepaid and debit card issuers.
  • Digital wallets and embedded stored-value products.
  • Payroll and platform businesses that hold funds for users.

Buckingham Capital Consulting obtained FCA EMI authorisation for Dzing Finance, Hryze and HFS, and UK EMI authorisation for EuroPanPay. The full procedure is in our UK EMI licence guide.

Small electronic money institution (small EMI)

What it is

A small EMI is registered to issue e-money while its average outstanding e-money, measured over the preceding six months, stays at or below €5m, and its payment services not linked to e-money stay at or below a €3m monthly average. It cannot provide payment initiation or account information services.

Capital and safeguarding

No initial capital is required below €500,000 of average outstanding e-money; from that level the firm holds at least 2% of the average, which is €100,000 at the €5m ceiling. Safeguarding under CASS 15 is mandatory, as for an authorised EMI.

When it fits

The €5m limit is reached quickly by a consumer product with any scale, and moving up to authorised EMI is a new application with the full €350,000 capital. Most firms with ambitions beyond a narrow product apply for full authorisation from the start. The small EMI suits:

  • Products with a natural ceiling, such as employee benefit cards for a limited client base.
  • Pilots with a planned move to authorised EMI.
  • Closed communities such as a university or membership organisation.

Our small EMI guide answers the common questions on the route.

API or EMI: the decision most firms face

The choice between an API and an authorised EMI is the one most fintechs make. It turns on a single question: will customers hold a balance with the firm that they can spend later?

QuestionPoints to APIPoints to EMI
Do customers hold balances between payments?No; funds move straight throughYes; wallets or accounts hold value
Prepaid or debit cards on own balances?NoYes
Capital available€20,000 to €125,000€350,000 and growing at 2% of balances
Product roadmapTransfers, remittance, acquiring, open bankingAccounts, cards, multi-currency wallets

A payment institution can hold customer funds only for the time needed to execute a payment; it cannot keep stored balances. A firm that starts as an API and later adds wallets makes a new application under the EMRs, so a roadmap that includes stored value within the planning horizon usually points to an EMI from the outset.

SPI or API: the cost of moving up

An SPI costs £1,130 to register and needs no capital, against £5,640 and up to €125,000 for an API. The saving is real for a firm that stays small. For a firm that passes €3m a month within two years, the SPI route means a second application, a second assessment of 6 to 8 months during which volumes must stay under the limit, and the API capital in any case. Firms in that position usually apply for the API directly.

How to choose: a decision framework

Step 1: map your regulated activities

Map each product to the eight payment services and to e-money. Holding stored value that customers spend points to an EMI. Account information only points to a RAISP. Payment services without stored value point to an API or SPI.

Step 2: test your scale

A payment business above a €3m monthly average, or an e-money business above €5m of average outstanding e-money, needs an authorised licence. A registered firm must stay within its limits until it is authorised, and in consumer fintech the limits arrive sooner than many founders expect.

Step 3: plan for your growth

If the plan shows growth past the small limits within two to three years, apply for authorisation directly. A move from small to authorised status is a new application with a second fee, full capital and a full assessment, and investors increasingly expect a clear path to an API or authorised EMI.

Step 4: decide on payment initiation and account information

Both are central to open banking, embedded finance and business payment automation. If either is on the product roadmap, plan for an API (for payment initiation) or a RAISP (for account information only) from the outset, because neither small registration permits them.

Step 5: decide on EU access

No UK licence gives access to the EU. Firms serving both markets plan a UK licence and a separate EU authorisation, in parallel or in sequence, depending on market priority, capital and management capacity.

Step 6: understand the upgrade paths

MoveHow it is done
SPI to APINew application for authorisation
Small EMI to authorised EMINew application for authorisation
RAISP to API with payment initiationNew application for authorisation
API to EMINew application under the EMRs
API adding payment servicesVariation of permission, £1,410 or £565

The FCA states that moving between registered and authorised status needs a new application, not a variation, and that the wrong application type is returned. Each new application follows the full timeline, so authorising at the target level is usually the better choice when the direction is clear.

Common scenarios and the right licence

BusinessLicenceWhy
Consumer remittance app processing €5m a monthAPIAbove the SPI limit; €20,000 capital if remittance only, €125,000 if it also executes transfers from accounts
Business payment platform processing €40m a monthAPI, or authorised EMI if it holds balancesNo volume limit; stored balances need e-money
Personal finance app using open banking dataRAISPAccount information only, no funds handled
Embedded finance platform issuing accounts and prepaid cards to business usersAuthorised EMIStored value and cards at scale
Single-corridor remitter processing €1m a monthSPI, with a planned move to APIWithin the €3m limit today
Account-to-account merchant payments through open bankingAPI with payment initiation€50,000 capital, or €125,000 with other services
Consumer neobankAuthorised EMIE-money accounts, cards and scale from launch

Firms that need a regulated product before their own licence is granted can launch as the agent of a PI or the distributor of an EMI, under that firm's licence and supervision, and move to their own licence later.

Running costs and obligations by licence

Annual FCA periodic fees for 2026/27

LicencePeriodic fee 2026/27
API£628 minimum, plus £0.309 per £1,000 of relevant income above £100,000
SPI£652 flat
Authorised EMI£2,063 minimum, plus £43.40 per £1m of average outstanding e-money above £5m
Small EMI£1,432 flat

These are the FCA's final rates in PS26/14, published on 2 July 2026. Firms also pay the Financial Ombudsman Service general levy, and in the first year the FCA charges a proportion of the annual fee based on the months remaining.

Regular reporting

LicenceMain returns
API and authorised EMICapital and financial returns, payments fraud report every 6 months, operational and security risk report at least yearly, monthly safeguarding return
SPIAnnual financial return, transactions report before the end of each January, payments fraud report every 12 months
Small EMIAnnual return, outstanding e-money report by the end of each January, payments fraud report every 12 months, monthly safeguarding return
RAISPAnnual financial return and payments fraud report every 12 months

Obligations common to every licence

  • The Money Laundering Regulations 2017, overseen by the MLRO, for every firm that handles funds.
  • The Consumer Duty for services to retail customers, with an annual board report.
  • Complaints handling within the PSR time limits and complaints reporting; the FCA's new reporting rules (PS25/19) start with the period 1 January to 30 June 2027.
  • Advance notice to the FCA of new directors, managers, controllers, agents and material outsourcing.

Launching before your own licence: agents and distributors

A firm that needs to trade before its own licence is granted, or that does not yet need one, can operate under another firm's licence.

  • Agent of a PI or EMI: the agent provides payment services on behalf of the licensed firm, which registers it with the FCA and remains responsible for it. The FCA's target is to process 95% of UK agent notifications within 2 months.
  • Distributor of an EMI: the distributor markets and distributes the EMI's e-money, for example prepaid cards, but does not issue it. The EMI remains responsible for the distributor and oversees it.
  • Programme partner: a brand runs a card or account product built on a licensed firm's platform, with the licensed firm holding the regulatory responsibility.

These routes are quicker to start, but the licensed principal controls the compliance framework and takes a share of the economics. Many firms use them to launch and build volume while their own application is prepared and assessed.

What banks, card schemes and investors look for in your licence choice

The licence is assessed by more than the FCA. Banks offering safeguarding and operating accounts, card scheme sponsors and investors each form a view of whether the licence fits the plan.

  • Banks look for a licence that matches the flows they will see, a named MLRO, written safeguarding procedures and realistic volumes. A firm processing above its registration limit is a concern for any bank.
  • Card scheme sponsors generally require an EMI or an API with card issuing, and assess capital, financial crime controls and programme management.
  • Investors look for a licence that will carry the business through the next funding round without a second application, and for capital planning that shows when further capital will be needed.

Choosing the licence the business will need in two to three years, rather than the one that is quickest today, usually satisfies all three.

How Buckingham Capital Consulting can help

Buckingham Capital Consulting has worked on UK payment licences since 2013. The firm advises on licence selection, covering the regulatory perimeter, capital, governance, timing, cost and the upgrade path, and prepares the full application through the FCA's questions to the decision. For firms already licensed, it runs gap analyses and applications for the move from SPI to API, small EMI to authorised EMI, RAISP to API and API to EMI, and supports safeguarding under CASS 15, regulatory reporting and FCA supervision. Our guide to FCA PI and EMI timelines sets out how long each stage takes.

Frequently asked questions

What is the main difference between an API and an EMI licence?

An EMI can issue e-money and hold customer balances; an API provides payment services only. An EMI needs €350,000 initial capital against €20,000 to €125,000 for an API.

Should I start with an SPI or go straight to an API?

Start with an SPI if volumes will stay under the €3m monthly average for several years. If the plan shows growth past it, apply for an API directly, because moving up is a new application.

Can a RAISP also process payments?

No. A RAISP provides account information only. Payment initiation or other payment services need authorisation as an API or an EMI.

Which licence allows prepaid cards in the UK?

An EMI, authorised or small, because prepaid card balances are e-money. Other firms can distribute an EMI's cards as its distributor or programme manager.

Does SM&CR apply to payment institutions and EMIs?

No. APIs, SPIs, RAISPs and EMIs are not under the Senior Managers and Certification Regime; the FCA assesses their directors and managers at application.

Can one firm hold both an API and an EMI licence?

A single firm does not need both, because an EMI authorisation already covers payment services. Some groups hold them in separate companies.

What happens if an SPI exceeds the €3m monthly average?

It must apply for authorisation as an API and stay within the limit until authorised, so firms start the application well before reaching it.

Do any UK payment licences give an EU passport in 2026?

No. Passporting ended on 31 December 2020, so EU customers are served through a separate EU-authorised entity.

References

  1. FCA: Payments and e-money firm applicants
  2. FCA: Application fees for EMIs and payment institutions
  3. The Payment Services Regulations 2017
  4. The Electronic Money Regulations 2011
  5. FCA: Payment Services and Electronic Money, Our Approach
  6. FCA PS25/12: Changes to the safeguarding regime for payments and e-money firms
  7. FCA: Authorisations operating service metrics 2026/27 Q1

About Buckingham Capital Consulting

Buckingham Capital Consulting has obtained FCA payment and e-money licences for firms including Nexpay, Oval, Onpoint Money and Dzing Finance since 2013, and arranges the safeguarding and operating accounts alongside the application. The firm advises on the choice between API, SPI, RAISP and EMI routes and plans the move from one licence to the next as the business grows.

Speak to an expert: WhatsApp +44 7563 115980, Telegram @buckinghamcapital or info@buckinghamcapitalconsulting.co.uk.

This article is general information, reviewed against the regulator’s published requirements on the date shown. It is not legal advice; the regulator’s current publications take precedence.