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Procedure to Become a UK Electronic Money Institution: EMI Licence Guide 2026

Published 20 December 2019 · Last reviewed 17 October 2026 · Buckingham Capital Consulting
Contents
  1. What a UK EMI licence allows you to do
  2. Authorised EMI or small EMI
  3. Who needs an EMI licence
  4. The legal framework for UK EMIs in 2026
  5. What the FCA looks for in an EMI applicant
  6. Capital requirements: initial capital and own funds
  7. Safeguarding customer funds under CASS 15
  8. Documents in an EMI application
  9. The step-by-step procedure
  10. How long EMI authorisation takes
  11. What an EMI licence costs
  12. Card issuing, banking and launch partners
  13. After authorisation: ongoing obligations
  14. Frequently asked questions
Key takeaways
  • An authorised EMI pays an FCA application fee of £5,640 and must hold initial capital of €350,000; a small EMI pays £1,130.
  • A small EMI is limited to €5m of average outstanding e-money and a €3m monthly average of unrelated payment transactions, and cannot offer account information or payment initiation.
  • The FCA must decide a complete application within 3 months and any application within 12 months; the firm plans authorised EMI applications at 6 to 8 months from submission.
  • The CASS 15 safeguarding rules have applied since 7 May 2026, with daily reconciliation, a monthly safeguarding return and an annual safeguarding audit.
  • The FCA's 2026/27 periodic fee for an authorised EMI starts at £2,063; a small EMI pays a flat £1,432.
  • UK EMIs lost EU passporting on 31 December 2020 and serve EEA customers only through an EU-authorised entity.

What a UK EMI licence allows you to do

An electronic money institution (EMI) is a firm the Financial Conduct Authority (FCA) has authorised or registered to issue electronic money. E-money is monetary value stored electronically, issued when a customer pays in funds, and accepted as payment by people other than the issuer. A prepaid card balance, a multi-currency wallet and a stored balance in a payments app are all e-money.

The licence comes from the Electronic Money Regulations 2011 (EMRs). An EMI can issue and redeem e-money, and it can also provide the payment services listed in the Payment Services Regulations 2017 (PSRs): money transfers, card issuing, merchant acquiring, money remittance and, for an authorised EMI, account information and payment initiation services. That breadth is why most fintechs that hold customer balances choose an EMI licence over a payment institution licence.

What an EMI cannot do

  • Pay interest or any benefit linked to how long a customer holds e-money (EMRs regulation 45).
  • Take deposits or lend out customer funds. Customer money is safeguarded and kept apart from the firm's own money.
  • Arrange insurance or offer investment products without the separate permission those activities need.

Customers can redeem their e-money at par value at any time. Currency conversion that forms part of a payment can be offered as an ancillary service; FX forwards and options are investment products with their own rules. If you are still choosing between licence types, our comparison of API, SPI, RAISP and EMI licences sets out which fits each business model.

Authorised EMI or small EMI

There are two routes. An authorised EMI has no volume limits and can provide the full range of payment services. A small EMI is a registration with a lower fee and lighter capital, capped by the size of the business. The FCA assesses both against the same standards of governance, fitness and propriety, and money laundering controls.

FeatureAuthorised EMISmall EMI
Legal statusAuthorisationRegistration
FCA application fee£5,640£1,130
Initial capital€350,000None below €500,000 average outstanding e-money; 2% of that average above it
Outstanding e-moneyNo limitAverage of €5m or less
Unrelated payment servicesNo limitMonthly average of €3m or less
Account information and payment initiationPermittedNot permitted

A small EMI that grows beyond its limits applies for authorisation as a new application, not a variation. Firms that expect to pass €5m of outstanding e-money within their first two to three years usually apply for full authorisation from the outset. Our small EMI guide covers the registration route in detail.

Who needs an EMI licence

You need an EMI licence if your business issues stored value that customers can spend with third parties. Typical applicants are:

  • Digital wallet and multi-currency account providers for consumers or businesses.
  • Prepaid and debit card programmes where the firm holds the customer balance.
  • Cross-border payments firms that hold funds for customers between transactions.
  • Platforms, marketplaces and payroll providers that keep balances on behalf of users.
  • Payment institutions that want to add stored balances and need to move up to e-money.

When you may not need one

The EMRs exclude limited networks, for example a store card usable only at one retailer's outlets, and certain payments made through electronic communications networks. A firm can also launch through an existing EMI as its agent or distributor, or under a programme run by a licensed partner, and apply for its own licence later. The exclusions are narrow, and firms relying on them notify the FCA once their volumes pass the thresholds set in the regulations.

UK e-money law is now separate from EU law. UK firms lost their passporting rights on 31 December 2020, so a UK EMI serves customers in the European Economic Area only through a separate entity authorised in an EU member state. The rules that apply to a UK EMI today are:

  • Electronic Money Regulations 2011: authorisation, capital, safeguarding, redemption and conduct of business for e-money.
  • Payment Services Regulations 2017: the payment services an EMI provides, information requirements and strong customer authentication.
  • Money Laundering Regulations 2017: customer due diligence, the firm-wide risk assessment and the role of the money laundering reporting officer (MLRO).
  • FCA Handbook: including the CASS 15 safeguarding rules in force since 7 May 2026, the Consumer Duty, complaints handling and regulatory reporting.

The FCA's guidance document, Payment Services and Electronic Money: Our Approach, explains how it applies these rules and is the first document an applicant should read. HM Treasury has set out plans to reform the payments framework; until new legislation is made, the EMRs and PSRs remain the law.

What the FCA looks for in an EMI applicant

The FCA grants authorisation when it is satisfied the firm meets the conditions in regulation 6 of the EMRs. In practice the assessment centres on six areas.

1. UK head office and management

The applicant must be a UK company with its head office in the UK, and the people who direct the business day to day must do so from the UK. In practice the FCA expects the CEO and the MLRO to be based in the UK and board meetings to take place here. A virtual office address does not meet this standard; a serviced office with real working space does.

2. Directors and senior staff

Directors and the people managing the e-money business must be of good repute and have the knowledge and experience to run it. The FCA registers each of them through its individuals form and reviews their CVs, past roles and any regulatory history. A typical leadership team covers a CEO with payments experience, a finance director, a compliance officer and an MLRO, with non-executive directors where the business is larger.

3. Owners and controllers

Anyone holding 10% or more of the capital or voting rights, or exercising significant influence, must be fit and proper. The FCA asks for the ownership chain up to the ultimate individuals, the source of the funds being invested and, for corporate owners, their accounts.

4. Capital and financial forecasts

The applicant must hold its initial capital before authorisation and show it can meet its own funds requirement as it grows. The FCA asks for a three-year budget forecast with balance sheets and, where applicable, two stress-tested scenarios showing how the firm stays above its capital requirement if growth is slower or costs higher than planned.

5. Safeguarding

Customer funds must be protected from the moment they are received. The application sets out the safeguarding method, the bank or insurer used, how funds are reconciled each day and how they would be returned to customers if the firm closed.

6. Systems, controls and financial crime

The FCA reviews governance, risk management, IT and security, outsourcing and anti-money laundering controls. Systems do not have to be live at submission, but the application must describe them precisely: which core platform, card processor and screening tools the firm will use, and how it oversees each supplier under a written contract. White-label platforms are acceptable when the firm shows it controls and understands them.

Capital requirements: initial capital and own funds

An authorised EMI must hold initial capital of at least €350,000 before it is authorised (EMRs Schedule 2, paragraph 2). The figure is set in euros and the sterling amount moves with the exchange rate, so most firms hold a margin above the minimum.

After authorisation, the firm must hold own funds at least equal to its ongoing requirement. For e-money this is Method D: 2% of average outstanding e-money. Where the EMI also provides payment services not linked to e-money, it adds a requirement under Method A, B or C, as the FCA directs.

MethodHow it is calculated
Method D (e-money)2% of average outstanding e-money
Method A10% of the previous year's fixed overheads
Method BA sliding percentage of monthly payment volume, from 4% of the first €5m down to 0.25%
Method CA sliding percentage of income from interest, fees and commissions

The FCA can direct a firm to hold up to 20% more or less than the calculated figure. A small EMI has no initial capital requirement until its average outstanding e-money reaches €500,000; from that point it must hold at least 2% of that average. The arithmetic, with worked examples, is in our guide to what an FCA PI or EMI licence costs.

Safeguarding customer funds under CASS 15

Safeguarding is the protection of customer money so that it can be returned in full if the EMI becomes insolvent. The FCA's CASS 15 rules, introduced by Policy Statement PS25/12, came into force on 7 May 2026 and now apply to every EMI alongside the EMRs.

  • Segregation: funds go into a designated safeguarding account at a bank, or are covered by an insurance policy or comparable guarantee. Most EMIs use a safeguarding account because insurance cover is rarely available.
  • Reconciliation: the firm reconciles the funds it should hold with the funds it does hold every business day and corrects any shortfall.
  • Monthly return: the firm submits a safeguarding return to the FCA each month.
  • Annual audit: an independent auditor reviews the safeguarding arrangements every year.
  • Resolution pack: the firm keeps the documents an insolvency practitioner would need to return funds quickly.

The safeguarding account is one of the first items to secure, because the application names the bank. Our article on the CASS 15 safeguarding regime explains each obligation. Safeheld, the firm's own safeguarding platform, runs the daily reconciliation and prepares the monthly return.

Documents in an EMI application

The application is made through the FCA's Connect system. The FCA returns any submission that lacks its minimum information or the correct fee without assessing it, and it expects every policy to be written for the applicant's own business rather than taken from a template. The core documents are:

DocumentWhat it shows the FCA
Programme of operationsEach e-money and payment service, step by step, with the flow of funds
Business planMarket, customers, marketing, pricing and a three-year forecast with stress scenarios
Structural organisationBoard, committees, reporting lines, staffing and outsourcing
Evidence of initial capitalFunds held in the firm's account and their source
Safeguarding proceduresMethod, bank, daily reconciliation and the resolution pack
Governance and internal controlsRisk framework, compliance monitoring and the three lines of defence
AML and counter-terrorist financingBusiness-wide risk assessment, customer due diligence and transaction monitoring
Security policy and incident procedureIT risk assessment, data protection and how incidents are reported
Business continuity and wind-down planHow services continue during disruption and how the firm would close in an orderly way
Individuals and controllers formsFitness and propriety of directors, managers and owners

Authorised EMIs that offer account information or payment initiation services also need professional indemnity insurance. The main contact named on the application must be an individual at the applicant firm, not an external adviser.

The step-by-step procedure

  1. Confirm the licence and scope. Map each product to the e-money and payment services it involves, and decide between authorised and small EMI.
  2. Incorporate and set up the UK base. Form the UK company, complete Companies House identity verification for directors and persons with significant control (mandatory since 18 November 2025), and take office space.
  3. Appoint the leadership team. Recruit the CEO, MLRO, compliance officer and finance lead, and agree the board.
  4. Secure banking and suppliers. Open the operating account, agree the safeguarding account and contract the core platform, card issuing sponsor and screening providers.
  5. Prepare the application. Write the business plan, programme of operations, policies and forecasts, and deposit the initial capital.
  6. Use the FCA's pre-application support where helpful. The pre-application support service (PASS) offers meetings to EMI applicants, particularly those with new business models.
  7. Submit through Connect and pay the fee. The FCA allocates a case officer within a maximum of 20 working days.
  8. Answer the case officer's questions. Expect one or more rounds of written questions and, for some firms, an interview with the CEO and MLRO.
  9. Receive the decision and go live. The firm appears on the Financial Services Register and launches once systems testing and safeguarding are complete.

How long EMI authorisation takes

Under regulation 9 of the EMRs, the FCA must decide a complete application within three months of receiving it, and any application within twelve months. When the FCA asks for information it needs to complete the file, the three-month period runs from the date the file is complete, which is why the time from submission to decision is usually longer than three months.

StageTypical duration
Case officer allocationUp to 20 working days
Statutory deadline, complete application3 months
Statutory deadline, any application12 months
Firm's planning figure, submission to decision6 to 8 months

The firm plans authorised EMI applications at 6 to 8 months from submission. A complete file, a leadership team in place and a safeguarding bank named at submission keep an application at the shorter end. Our guide to FCA PI and EMI timelines covers each stage and what extends it.

What an EMI licence costs

The cost has four parts: the FCA application fee, initial capital, the annual FCA fees, and the people and systems the FCA expects to see in place.

ItemAuthorised EMISmall EMI
FCA application fee£5,640£1,130
Initial capital€350,000None until €500,000 average outstanding e-money
FCA periodic fee 2026/27£2,063 minimum, plus £43.40 per £1m of average outstanding e-money above £5m£1,432 flat

The periodic fees are the FCA's final rates for 2026/27, set in PS26/14 published on 2 July 2026. In the first year the FCA charges a proportion of the annual fee based on the months remaining in the fee year. Firms also pay smaller levies, including the Financial Ombudsman Service levy.

Operating costs the business plan must fund

  • UK salaries for the CEO, MLRO, compliance officer and finance lead.
  • UK office space with real working capacity.
  • The core e-money platform, card processing and screening tools.
  • The annual safeguarding audit, the statutory audit and professional indemnity insurance where required.

The business plan shows these costs funded for the forecast period, over and above the capital requirement.

Card issuing, banking and launch partners

Most EMIs issue cards through a principal member of Visa or Mastercard, known as a BIN sponsor, until they qualify for direct scheme membership. Others use a white-label platform that bundles card processing, ledger and compliance tools. Partner pricing shapes the economics of the business, so the business plan models partners at the rates actually quoted.

Banking is the other dependency. The firm needs an operating account for its own money and a safeguarding account for customer funds, and banks run their own due diligence on payments firms. Starting these conversations before submission shortens the time from authorisation to launch.

After authorisation: ongoing obligations

Authorisation starts the supervisory relationship. An authorised EMI's continuing obligations include:

  • Capital: holding own funds at or above the requirement at all times.
  • Safeguarding: daily reconciliation, the monthly safeguarding return and the annual safeguarding audit under CASS 15.
  • Reporting: regulatory returns including the FIN060 capital return, the payments fraud report (REP017) and the operational and security risk report (REP018).
  • Consumer Duty: evidencing good outcomes for retail customers, with an annual board report.
  • Complaints: handling complaints within the required time limits and reporting them; the FCA's new complaints reporting rules (PS25/19) start with the period 1 January to 30 June 2027.
  • Notifications: telling the FCA in advance about new directors or managers, new controllers, agents, distributors and material outsourcing.

A change of control at 10% or more needs FCA approval before it completes, so an EMI can be sold provided the buyer is assessed as fit and proper. An EMI may trade under a brand name if customers can see the regulated entity behind it. EMIs are not under the Senior Managers and Certification Regime. Our related guide to FCA compliance for electronic money institutions covers each obligation in detail.

Buckingham Capital Consulting obtained FCA EMI authorisation for Dzing Finance, Hryze and HFS, and UK EMI authorisation for EuroPanPay. Details of the service are on our UK EMI licence page.

Frequently asked questions

How much does an EMI licence cost in the UK?

The FCA application fee is £5,640 for an authorised EMI and £1,130 for a small EMI. An authorised EMI also needs €350,000 of initial capital and pays an annual FCA fee from £2,063 in 2026/27.

How long does it take to get an EMI licence from the FCA?

The FCA must decide a complete application within 3 months and any application within 12 months. The firm plans authorised EMI applications at 6 to 8 months from submission.

What is the minimum capital for a UK EMI?

An authorised EMI needs initial capital of €350,000 and then own funds of at least 2% of average outstanding e-money. A small EMI needs no initial capital until its average outstanding e-money reaches €500,000.

Can a foreign company get a UK EMI licence?

The applicant must be a UK company with its head office and management in the UK. A foreign group can own the UK EMI, provided the owners are assessed as fit and proper.

Can a UK EMI serve customers in the EU?

Not directly. UK firms lost passporting rights on 31 December 2020, so EEA customers are served through a separate entity authorised in an EU member state.

What is the difference between an EMI and a payment institution?

An EMI can issue e-money and hold customer balances as well as provide payment services. A payment institution provides payment services only and cannot issue stored value.

Can an EMI pay interest on customer balances?

No. Regulation 45 of the EMRs prohibits interest or any benefit linked to how long a customer holds e-money.

Do EMIs fall under SM&CR?

No. EMIs and payment institutions are not under the Senior Managers and Certification Regime; the FCA assesses their directors and managers through the EMI individuals form.

References

  1. FCA: Electronic money institution applicants
  2. The Electronic Money Regulations 2011
  3. FCA: Application fees for EMIs and payment institutions
  4. FCA: Payment Services and Electronic Money, Our Approach
  5. FCA PS25/12: Changes to the safeguarding regime for payments and e-money firms
  6. FCA PS26/14: FCA regulated fees and levies 2026/27
  7. FCA: Pre-application support service

About Buckingham Capital Consulting

Buckingham Capital Consulting has obtained FCA electronic money institution authorisation for firms including Dzing Finance, Hryze and HFS since 2013, and arranges the safeguarding and operating accounts alongside the application. The firm prepares the full EMI application, from business plan and policies to case officer questions, and supports the EMI through its first years of FCA 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.