A regulatory consulting partner helps a payment or e-money business obtain FCA authorisation and then operate within the rules. For most firms the engagement covers four things: choosing the right licence, preparing the application, arranging the banking and payment infrastructure the licence depends on, and running compliance once the firm is live.
The choice matters because the FCA assesses the firm, not the adviser. A strong partner leaves the directors, the compliance officer and the MLRO (money laundering reporting officer, the person responsible for anti-money laundering controls) able to explain every part of the application in their own words.
| Stage | What the partner delivers |
|---|---|
| Licence choice | A written view on whether the model needs an authorised payment institution (API), small payment institution (SPI), e-money institution (EMI) or account information registration |
| Application | Business plan, three-year financial forecasts, capital and safeguarding methodology, governance map and firm-specific policies |
| Infrastructure | Introductions to safeguarding banks, operating accounts, card scheme sponsors and payment system access |
| People | Preparation of directors, the compliance officer and the MLRO for FCA questions and interviews |
| After authorisation | Regulatory returns, safeguarding audit readiness, monitoring and change management |
The licence types and their thresholds are set out in the firm's guides to the UK EMI licence and the UK payment institution licence.
Specialist support adds most value where the team has strong commercial or technical experience but has not taken a firm through FCA authorisation before. It is equally common for established financial groups entering the UK, where the FCA expects a UK management presence and a UK-specific governance structure.
The FCA is clear on the role of advisers. Its guidance on applying says firms do not have to use one, that many find an adviser or compliance consultant helpful, and that the FCA expects to deal directly with the firm in correspondence and meetings, not with the adviser. For payment and e-money applications, the main contact named on the form must be an individual at the applicant firm.
The FCA states that the policies and procedures submitted with a payment or e-money application should not be generic templates. Case officers test whether the documents match the business model, the transaction flows and the customer base described in the business plan. A partner who drafts with the team, rather than for it, produces documents the firm can defend.
The FCA returns a submission without assessing it if the correct fee is not paid or the minimum information is missing. Once accepted, a complete application is decided within 3 months and an incomplete one within up to 12 months, under the Payment Services Regulations 2017 and the Electronic Money Regulations 2011. Completeness on day one is therefore the single largest influence on the timetable.
The FCA may interview individuals such as the MLRO or the chief financial officer to understand their knowledge and experience. Preparation for those conversations is part of the work, not an extra.
The criteria below reflect what the FCA assesses and what a payment business needs to trade. Each can be tested with documents or verifiable facts before an engagement letter is signed.
Payment services and e-money have their own legislation, safeguarding rules and reporting regime, separate from investment or insurance regulation. A partner whose recent work is concentrated in APIs, SPIs and EMIs will know the current FCA application forms, the questions case officers ask and how the CASS 15 safeguarding rules apply in practice.
Advising on an application is not itself a regulated activity, so the adviser will not appear on the FCA Register for that work. The evidence is the clients' own Register entries. Ask for named firms the partner has taken through authorisation, check each one on the FCA Register, and ask to speak to a director at one of them.
Ask for the names and backgrounds of the people who will draft the business plan, the financial forecasts and the policies, and who will attend calls with the FCA case officer. Senior involvement in the scoping and review stages is what gives an application its coherence.
Ask how the partner builds the policies: from workshops with the team, from the firm's own transaction data and risk assessment, or from a standard set. The right answer is the first two, with the firm's staff reviewing and owning each document before submission.
An authorised firm still needs a safeguarding account at a credit institution, an operating account, and access to payment systems such as Faster Payments, SEPA or SWIFT, usually through a sponsoring bank, and to card schemes through a principal member. A partner with working relationships across these providers can run the banking workstream in parallel with the application. Ask the partner to state any commercial relationship with providers it introduces.
A credible partner quotes the FCA's own service standard, explains what moves a case between the 3-month and 12-month windows, and does not promise an outcome, since only the FCA decides. The scope should list every deliverable, the information the firm must supply and the milestones for each.
Authorisation starts a set of recurring obligations: regulatory returns, the monthly safeguarding return, the annual safeguarding audit, complaints reporting and annual reviews of financial crime controls. A partner that can support the first year of operation keeps the systems built for the application in use.
UK firms lost EU passporting rights on 31 December 2020. A UK EMI or PI serves EU customers only through a separate entity authorised in an EU member state, so a business with European plans benefits from a partner that can run a UK and an EU application on one timetable.
| Criterion | Evidence to request |
|---|---|
| Specialism | List of payment and e-money engagements in the last three years |
| Track record | Named client firms, checked on the FCA Register |
| Team | Names and CVs of the people drafting and attending FCA calls |
| Drafting method | A sample policy table of contents and the workshop plan |
| Infrastructure | Banks and providers the partner works with, and any commercial ties |
| Timeline | A milestone plan referenced to the FCA service standard |
| Ongoing support | A first-year compliance calendar |
| International | EU jurisdictions covered and recent authorisations there |
A first meeting should leave the directors with a written view on the licence, the capital and the timetable. These questions establish whether the partner can provide one.
Engagements are shaped around what the firm already has. A team with an experienced compliance officer may need only a review; a first-time founder usually needs the full application.
| Engagement | Best suited to |
|---|---|
| Full application | New firms without in-house regulatory experience |
| Review of a draft application | Firms with a compliance officer who has drafted most documents |
| Single workstreams | Firms needing specific items, such as financial forecasts or a wind-down plan |
| Change in control | Buyers of an authorised firm and their investors |
| Ongoing compliance support | Authorised firms building their first-year monitoring and reporting |
Whatever the structure, the engagement letter should state the deliverables, the reliance the firm can place on the work, confidentiality terms and how personal data on directors and controllers will be held.
Regulator fees and capital apply whichever partner is chosen, and a good partner builds them into the financial forecasts from the first draft. The FCA's application fees were last updated on 13 July 2026.
| Application | FCA fee |
|---|---|
| Small payment institution | £1,130 |
| Authorised payment institution | £2,820 or £5,640, depending on services |
| Small e-money institution | £1,130 |
| Authorised e-money institution | £5,640 |
| Variation adding payment or e-money services | £1,410 or £565 |
| Firm type | Initial capital |
|---|---|
| API: money remittance only | €20,000 |
| API: payment initiation services | €50,000 |
| API: other payment services | €125,000 |
| Authorised EMI | €350,000 |
Initial capital is set in euros by the legislation. Ongoing own funds can exceed it as volumes grow. The full budget, including insurance, audit and staffing, is set out in what an FCA PI or EMI licence costs in 2026.
The timetable has two parts: preparation, which the firm and its partner control, and assessment, which the FCA controls. Preparation depends on how settled the business model, the team and the capital are; firms with these in place submit sooner.
| Phase | Typical duration |
|---|---|
| FCA allocation of a case officer | Up to 20 working days |
| Statutory decision, complete application | 3 months |
| Statutory decision, incomplete application | Up to 12 months |
| Planning assumption for EMI and PI | 6 to 8 months after submission |
The planning assumption allows for questions from the case officer and the firm's responses. Banking and safeguarding arrangements run alongside, so the firm can trade soon after the FCA grants authorisation.
The strongest partners share a small set of habits that a firm can observe during the selection process.
Buckingham Capital Consulting has worked on payment, e-money and cryptoasset authorisations since 2013. The firm has obtained FCA EMI authorisation for Dzing Finance, Hryze and HFS, FCA API authorisation for Nexpay, Orbital, Oval and Global Send, and Central Bank of Ireland EMI authorisation for Own Solutions, each of which can be checked on the relevant public register.
Each engagement pairs the application with the banking and payment processing workstream.
No. The FCA says firms do not have to use one, though many find an adviser or compliance consultant helpful in preparing applications.
The FCA expects to deal directly with the applicant in correspondence and meetings. The main contact on a payment or e-money application must be an individual at the firm.
The FCA decides complete applications within 3 months and incomplete ones within up to 12 months. Firms commonly plan for 6 to 8 months after submission.
Ask for the names of firms it has taken through authorisation and look each one up on the FCA Register, then ask to speak to a director at one of them.
No. Only the FCA decides an application; a credible adviser explains what the FCA looks for and how the firm will evidence it.
Advising a firm on its application is not a regulated activity, so the adviser is not authorised for that work. Its clients' Register entries are the evidence of its experience.
Regulatory returns, the monthly safeguarding return, the annual safeguarding audit under CASS 15, complaints reporting and reviews of financial crime controls.
Buckingham Capital Consulting has obtained FCA e-money and payment institution authorisations for firms including Dzing Finance, Hryze, Nexpay and Orbital since 2013, and arranges the safeguarding and operating accounts alongside each application. The firm supports payment and e-money businesses from licence choice through their first year of supervision.
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.