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FCA SPI Registration UK 2026: Complete Guide for Small Payment Institutions

Published 18 August 2026 · Last reviewed 17 October 2026 · Buckingham Capital Consulting
Contents
  1. What an FCA small payment institution is
  2. Who SPI registration suits
  3. What an SPI can and cannot do
  4. The €3 million monthly transaction limit
  5. SPI or API: how to decide
  6. Requirements for registration
  7. Does an SPI need capital or safeguarding?
  8. What to have in place before applying
  9. How to apply, step by step
  10. How long SPI registration takes
  11. What SPI registration costs
  12. After registration: ongoing obligations
  13. What the FCA looks for in an SPI application
  14. Frequently asked questions
Key takeaways
  • A small payment institution (SPI) is registered, not authorised, by the FCA and can provide payment services while average monthly transactions stay at or below €3 million.
  • The FCA application fee is £1,130 (category 3), per the FCA fees page updated 13 July 2026, and there is no initial capital requirement.
  • An SPI cannot provide payment initiation or account information services, or issue electronic money such as prepaid cards.
  • Safeguarding is optional; an SPI that elects to safeguard follows the CASS 15 rules in force since 7 May 2026.
  • An SPI that exceeds the limit must apply for authorisation within 30 days under regulation 16 of the PSRs 2017.

What an FCA small payment institution is

A small payment institution (SPI) is a payment firm registered, rather than authorised, by the Financial Conduct Authority (FCA) under the Payment Services Regulations 2017 (the PSRs). Once registered it appears on the Financial Services Register and can provide the payment services named in its registration, provided its volumes stay within the small payment institution limit.

The SPI regime is the proportionate route into UK payments. There is no initial capital requirement, safeguarding is optional, and the application is lighter than for an authorised payment institution (API). In return, the firm accepts a ceiling on volumes and a narrower set of services. It is commonly called an "SPI licence", but legally it is a registration.

An SPI can be a company, a partnership or, unusually among FCA regimes, an individual, provided its head office, registered office or place of residence is in the UK.

Who SPI registration suits

SPI registration suits founders launching a focused payments business with volumes that will stay below the threshold for the foreseeable future. Typical applicants are:

  • international money remittance businesses serving one or a few corridors;
  • bill payment and collection services;
  • smaller payment processors and merchant services providers; and
  • businesses adding a payment service alongside their main activity, such as a marketplace or travel business.

It suits less well where rapid growth is planned, where the product needs payment initiation or account information services, or where customers will hold a stored balance, which is electronic money. Those businesses are better served by applying for full authorisation from the start. Our comparison of the API, SPI, RAISP and EMI routes sets out the choice.

StatusVolume limitInitial capital
Small payment institution (SPI)Average €3 million a monthNone
Authorised payment institution (API)None€20,000 to €125,000
Small electronic money institution€5 million average outstanding e-moneyNone (own funds rule applies)
Authorised electronic money institutionNone€350,000
Registered account information service providerNoneNone (insurance required)

What an SPI can and cannot do

An SPI can provide any of the payment services in paragraphs (a) to (f) of Schedule 1 to the PSRs, as listed in its registration. In practice that means:

  • money remittance, the most common SPI service;
  • executing payment transactions, such as transfers, direct debits and card payments;
  • operating payment accounts, including cash placement and withdrawal;
  • issuing payment instruments or acquiring card payments for merchants.

An SPI cannot provide:

  • Payment initiation services, where the firm initiates a payment from the customer's account at another bank through open banking.
  • Account information services, which need registration as an account information service provider instead.
  • Electronic money, including prepaid cards and wallets where the customer holds a balance to spend later. These need a small or authorised electronic money institution registration.
  • Deposits, which only banks can accept.

Currency exchange on its own is not a payment service. An SPI can exchange currency where it is connected to a payment it executes, for example converting pounds to rupees within a remittance, as an ancillary service.

The €3 million monthly transaction limit

Regulation 14 of the PSRs sets the core condition: the monthly average of the firm's payment transactions over the preceding 12 months, including those carried out through UK agents, must not exceed €3 million. A firm that has not yet started trading, or has traded for less than 12 months, is assessed on its projected volumes over the next 12 months.

The test is an average, so a single busy month does not break it, but the trend matters. The projections in the application should be realistic and consistent with the business plan; the FCA tests forecasts that appear designed only to sit under the limit.

Worked example

A remittance business forecasts £18 million of transfers in its first year. At an exchange rate of about €1.15 to the pound, that is roughly €20.7 million, or about €1.7 million a month on average, comfortably inside the limit. If year two is forecast at £40 million, roughly €3.8 million a month, the firm should plan for full authorisation now rather than register and reapply in 12 months.

What happens when the business outgrows the limit

Under regulation 16, an SPI that no longer meets the volume condition, or wants to provide services outside the SPI regime, must apply for authorisation within 30 days of becoming aware of the change if it wants to keep providing payment services. There is no conversion: moving to an API is a new application with initial capital, own funds and mandatory safeguarding. Planning should start once forecasts show the firm approaching the limit.

SPI or API: how to decide

The choice turns on three questions: the services the product needs, the volumes the business will reach in the next two to three years, and what banks, partners and customers expect. The SPI route is the right answer for a genuinely small, focused business. It is the wrong answer where it only defers a full application by a year.

  • Choose SPI where volumes will stay below an average of €3 million a month, the services fall within (a) to (f) of Schedule 1, and the firm wants a proportionate start.
  • Choose API where volumes will exceed the limit, the product needs payment initiation, or banks and enterprise customers expect full authorisation and mandatory safeguarding.
  • Choose an e-money route where customers will hold a balance, such as a wallet or prepaid card.

Customers outside the UK

An SPI can serve customers outside the UK where the law of the customer's country allows it, but it has no passporting rights into the European Economic Area; passporting for UK firms ended on 31 December 2020. A business that needs to serve EU customers at scale needs a separately authorised EU payment institution.

Requirements for registration

The FCA may refuse registration only where one of the conditions in regulation 14 is not met. The applicant must show that:

  • its head office, registered office or place of residence is in the UK;
  • its average monthly payment transactions will not exceed €3 million;
  • it will not provide payment initiation or account information services;
  • no one responsible for managing the business has been convicted of money laundering, terrorist financing or other financial crimes, including offences involving fraud or dishonesty;
  • its directors and managers are of good repute and have appropriate knowledge and experience;
  • anyone holding 10% or more is fit and proper;
  • it complies with the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (the MLRs); and
  • it has no close links that would prevent effective supervision.

UK management and substance

The FCA must be able to supervise the firm effectively, so the UK business should be run from the UK. Founders should be able to show who runs the business, who owns compliance and financial crime, where decisions are made and how outsourced functions are overseen. Directors and managers each complete a PSD Individual form on the FCA's Connect system, and directors must have verified their identity with Companies House.

Financial crime

An SPI that carries on money remittance or currency exchange is a money service business, and is normally supervised for anti-money laundering by HM Revenue and Customs (HMRC) rather than the FCA. It must register with HMRC under the MLRs as well as with the FCA, and the two registrations must be consistent; the FCA cancels the registration of SPIs that do not hold the HMRC registration. Where the firm also carries on other FCA-regulated activities, the FCA can become its sole supervisor. Either way, the FCA expects a business-wide risk assessment, customer due diligence, sanctions screening, transaction monitoring proportionate to volumes, suspicious activity reporting, training and record keeping. The title of the responsible person can vary, but in practice the firm appoints a money laundering reporting officer (MLRO) with the knowledge, authority and time to do the role.

Does an SPI need capital or safeguarding?

Capital

There is no prescribed initial capital or own funds requirement for an SPI, unlike the €20,000, €50,000 or €125,000 bands that apply to an API. The FCA still expects a viable business: realistic spending, enough funding to reach break-even, and the resources to meet regulatory obligations as volumes grow.

Safeguarding

Safeguarding is optional for an SPI. A firm may elect to safeguard customer funds, and if it does, the FCA's CASS 15 safeguarding rules, in force since 7 May 2026, apply in full: a responsible director, reconciliations each reconciliation day, a monthly safeguarding return within 15 business days of month end, and a resolution pack. Firms that safeguard more than £100,000 also need an annual safeguarding audit.

Electing to safeguard can strengthen the firm's position with banks and customers, but it adds a real operating commitment. Our guide to CASS 15 explains what is involved.

What to have in place before applying

  1. A settled product and a clear flow of funds showing who receives money, where it is held and how it is settled.
  2. A UK applicant with transparent ownership and identified controllers.
  3. Directors and managers with relevant payments, compliance or financial experience.
  4. A regulatory business plan and realistic three-year forecasts.
  5. The exact payment services to be registered, mapped to Schedule 1.
  6. Financial crime policies, procedures and the systems that will run them.
  7. Complaints handling, security, incident management and outsourcing controls.
  8. Banking and settlement arrangements that fit the model.
  9. Safeguarding arrangements, if the firm elects to safeguard.
  10. A plan for onboarding and monitoring agents, if agents will be used.

How to apply, step by step

  1. Confirm the route. Test projected volumes against the €3 million limit and rule out any e-money, payment initiation or account information element.
  2. Map the flow of funds. Show each account, partner and settlement step.
  3. Set the services. Match each activity to Schedule 1 of the PSRs.
  4. Write the business plan and forecasts. Cover customers, pricing, volumes, staffing, technology, banking and the path to profit.
  5. Build the compliance framework. Financial crime, complaints, security, outsourcing and operational controls written for this business, not adapted from a template.
  6. Prepare the individual and controller forms. A PSD Individual form for each director and manager, and the relevant controller forms.
  7. Submit through Connect and pay the £1,130 fee. The FCA rejects without assessment any submission that is missing minimum information or the correct fee.
  8. Answer the FCA's questions promptly and consistently with the rest of the application.
  9. Prepare for launch during assessment: banking, technology, procedures, staff training and customer terms.

How long SPI registration takes

The PSRs require the FCA to decide a complete application within 3 months of receipt, and any application within 12 months. In 2025/26 the FCA determined 98.7% of payment services registration applications within these statutory deadlines, according to its operating service metrics.

The firm plans SPI registrations at weeks to a few months from submission, depending mainly on how complete the application is and how quickly questions are answered. Preparing the application typically takes 3 to 6 weeks where the business model is settled.

What SPI registration costs

The FCA application fee for a small payment institution is £1,130 (fee category 3), according to the FCA's application fees page last updated on 13 July 2026. It is paid by card through Connect on submission and is non-refundable.

Cost itemWho sets itNotes
Application feeFCA£1,130, paid on submission
Annual periodic fee and Financial Ombudsman Service levyFCA and OmbudsmanSet each year; first year pro-rated
Compliance and MLRO resourceThe firmIn-house, or part outsourced with oversight retained
Screening and monitoring systemsProvidersScaled to volumes
Banking and settlement accountsBanks and payment partnersPlus a safeguarding account if the firm elects to safeguard

After registration: ongoing obligations

Once registered, an SPI must keep meeting the registration conditions and file its regulatory returns on time. The FCA cancels the registration of firms that stop filing returns or no longer meet the conditions.

ObligationTiming
Payment transactions report (FSA057)Annual, by the end of January
Payment fraud report (REP017)Two half-year reports, within 2 months of the calendar year end
Operational and security risk report (REP018)At least once a year
Annual financial returnAnnual
Complaints returnUnder DISP; new rules from 1 January 2027
Monthly safeguarding returnOnly if the firm elects to safeguard

The firm must also notify the FCA of changes to its directors, managers, controllers, services or agents, and keep its financial crime controls, complaints handling and, where it serves consumers, Consumer Duty arrangements up to date. Our guide to FCA regulatory reporting for payment and e-money firms covers each return.

Agents

An SPI can provide services through agents, such as remittance agents in shops. Each agent must be registered with the FCA before it acts, and the SPI remains responsible for everything done on its behalf, so onboarding, due diligence, training, contracts and monitoring belong in the compliance framework.

What the FCA looks for in an SPI application

  • Projected volumes tested against the €3 million limit, with a plan for the move to authorisation if growth is expected.
  • Services that match the flow of funds, with no e-money, payment initiation or account information element.
  • A real UK business with clear ownership of compliance and financial crime.
  • Financial crime documents written for the firm's own customers, corridors and products.
  • A clear account of what third parties do and how the SPI oversees them.
  • Banking, settlement and, where chosen, safeguarding arrangements identified at submission.

Firms that expect to grow beyond the limit should read our guide to UK authorised payment institution licensing, and details of the firm's SPI service are on the small payment institution registration page.

Frequently asked questions

Is an SPI an FCA licence?

It is commonly called a licence, but legally it is an FCA registration under the Payment Services Regulations 2017. The firm appears on the Financial Services Register and can provide the services in its registration.

What is the SPI transaction limit?

The monthly average of payment transactions over the preceding 12 months must not exceed €3 million, including transactions through UK agents. New firms are assessed on projected volumes.

How much does FCA SPI registration cost?

The FCA application fee is £1,130, paid through Connect on submission and non-refundable. Annual FCA fees and the Financial Ombudsman Service levy follow after registration.

Does an SPI need minimum capital?

No. There is no initial capital or own funds requirement for an SPI, although the FCA expects the business to be adequately funded.

Can an SPI send money internationally?

Yes, if money remittance is in its registration. The firm must still meet the financial crime rules and the local rules of each destination country, and the UK registration gives no rights in the EU.

Can an SPI issue prepaid cards or hold customer balances?

No. A balance held for the customer to spend later is electronic money, which needs a small or authorised electronic money institution registration.

Which body supervises an SPI for anti-money laundering?

An SPI that is a money service business, such as a money remitter, is normally supervised by HMRC and must register with HMRC as well as the FCA. The FCA becomes the sole supervisor where the firm also carries on other FCA-regulated activities.

Can I convert an SPI into an API later?

There is no conversion. Moving to an authorised payment institution is a new application, which must be made within 30 days of the firm becoming aware it no longer meets the SPI conditions.

References

  1. FCA: Payment institution applicants
  2. FCA: Application fees for EMIs and payment institutions
  3. Payment Services Regulations 2017, regulation 14: conditions for registration as a small payment institution
  4. Payment Services Regulations 2017, regulation 16: application if requirements cease to be met
  5. FCA PS25/12: Changes to the safeguarding regime for payments and e-money firms
  6. FCA Handbook SUP 16.13: Reporting under the Payment Services Regulations
  7. FCA operating service metrics 2025/26
  8. HMRC: Who needs to register for money laundering supervision

About Buckingham Capital Consulting

Buckingham Capital Consulting has obtained FCA small payment institution registrations, including for Onpoint Money, and FCA authorised payment institution licences since 2013. The team advises when the SPI route fits and when to build for full authorisation from the start, and prepares the business plan, financial crime framework and FCA submission.

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.