Home › Blog › UK payments

How Long Does an FCA Payment Institution or EMI Licence Take in 2026? Realistic Timelines and Delays

Published 14 July 2026 · Last reviewed 17 October 2026 · Buckingham Capital Consulting
Contents
  1. FCA payment and EMI authorisation timelines at a glance
  2. Does an FCA PI or EMI licence really take three months?
  3. What do the FCA's latest 2026 figures show?
  4. A realistic timeline for an API or EMI application in 2026
  5. What happens after the application is submitted?
  6. Why some FCA applications take much longer than others
  7. Complete applications are the main way to avoid delay
  8. A strong regulatory business plan moves the assessment forward
  9. Governance determines whether the FCA is comfortable with the application
  10. Financial crime controls carry significant weight
  11. Safeguarding is now central to the application
  12. Financial forecasts need to match the regulatory story
  13. Ownership structures add time when they are hard to follow
  14. Changing the business model during the application can reset parts of the assessment
  15. How quickly should applicants answer FCA questions?
  16. Can the FCA refuse an application instead of asking more questions?
  17. API, SPI, authorised EMI and small EMI applications differ in complexity
  18. Can a firm launch while the FCA application is pending?
  19. Should you apply before banking and technology partners are finalised?
  20. How to keep an FCA PI or EMI application on schedule
  21. Timelines for variations, agents and changes in control
  22. From approval to launch
  23. The FCA is working to faster targets
  24. What timeline should founders put in their business plan?
  25. How Buckingham Capital Consulting can help
  26. Frequently asked questions
Key takeaways
  • The FCA must decide a complete PI or EMI application within 3 months and any application within 12 months; its own target for incomplete applications is 10 months.
  • In April to June 2026 the median FCA decision on payment and e-money authorisations took 219 days, about 7 months; the middle half took 168 to 268 days.
  • The firm plans authorised PI and EMI applications at 6 to 8 months from submission, after 2 to 4 months of preparation.
  • Small PI and small EMI registrations are shorter, at weeks to a few months from submission when the file is complete.
  • The FCA allocates a case officer within 20 working days; complete, consistent files and settled business models keep the assessment on schedule.
  • Safeguarding under CASS 15, in force since 7 May 2026, is a core part of the assessment, so naming the safeguarding bank early saves time.

FCA payment and EMI authorisation timelines at a glance

The three-month period in the Payment Services Regulations 2017 (PSRs) and the Electronic Money Regulations 2011 (EMRs) applies to a complete application, and most applications are completed during the assessment rather than on the day they are filed. The FCA's own figures show how long decisions take in practice: in April to June 2026, the median payment services and e-money authorisation took 219 days, about 7 months.

Stage or measureDurationSource
Application preparation2 to 4 monthsFirm's planning figure
Case officer allocationUp to 20 working daysFCA
Statutory deadline, complete application3 monthsPSRs and EMRs
Statutory deadline, any application12 monthsPSRs and EMRs
FCA target, incomplete application10 monthsFCA
Median, April to June 2026219 days (about 7 months)FCA
Lower quartile, April to June 2026168 days (about 5.5 months)FCA
Upper quartile, April to June 2026268 days (about 9 months)FCA
API and authorised EMI, submission to decision6 to 8 monthsFirm's planning figure

The FCA figures come from its authorisations operating service metrics for 2026/27 Q1 and cover new authorisations and registrations under the PSRs and EMRs together. They do not separate authorised payment institutions (APIs) from authorised EMIs or from the small registrations.

Does an FCA PI or EMI licence really take three months?

Three months is a legal deadline for a complete application, not a promise of approval in three months. The FCA treats an application as complete only when it has all the information it needs to make a decision. Until then, the separate twelve-month deadline applies to the application as a whole.

Case officers ask questions on governance, forecasts, safeguarding, financial crime controls, ownership and the business model. Each round of questions, and each answer that needs a follow-up, extends the time before the file is complete. A founder who plans the launch around the end-to-end timetable rather than the statutory period sets the right expectations with investors, banks and partners.

What do the FCA's latest 2026 figures show?

For new payment services and e-money authorisations and registrations decided in April to June 2026, the FCA reports:

  • A quarter of cases were decided within 168 days, about 5.5 months.
  • Half of cases were decided within 219 days, about 7 months.
  • Three quarters of cases were decided within 268 days, about 9 months.

The FCA's target for this category is to decide 95% of cases within 3 months of a complete application and 10 months of receipt for an incomplete one. In April to June 2026 the FCA reported that this category did not meet its target, citing operational demands, applications needing greater scrutiny and the tighter deadlines it is working towards.

Variations of permission for existing PIs and EMIs move faster: in the same quarter the median was 164 days, about 5.5 months.

A realistic timeline for an API or EMI application in 2026

The firm plans authorised PI and authorised EMI applications at 6 to 8 months from submission, in line with the FCA's median of about 7 months. Preparation before submission adds 2 to 4 months, depending on the model and how much of the team and framework already exists.

LicencePreparationSubmission to decision
Authorised payment institution2 to 4 months6 to 8 months
Authorised EMI3 to 4 months6 to 8 months
Small PI registration4 to 8 weeksWeeks to a few months
Small EMI registration2 to 3 monthsA few months

A simple remittance business with experienced management sits at the shorter end. A multi-currency EMI with wallets, cards, merchant services and several outsourced suppliers needs more preparation. The work of building the business, from hiring and capital to banking, safeguarding and technology, runs in parallel with the application rather than after it. The full EMI procedure is in our UK EMI licence guide and the API route in our UK payment institution licence guide.

What happens after the application is submitted?

  1. Submission through Connect. The application fee is paid and the FCA checks the minimum information is present. It returns a submission without assessing it if the minimum information or the correct fee is missing.
  2. Case officer allocation. For PI, EMI and RAISP applications this takes up to 20 working days.
  3. Assessment. The case officer reviews the business model, governance, ownership, financial resources, safeguarding, financial crime, risk management, outsourcing and the suitability of each individual.
  4. Questions. The case officer sends written questions with a deadline for answers. Follow-up questions are normal, even for strong applications, and some firms are interviewed.
  5. Decision. The FCA approves, approves with requirements, or proposes refusal. On approval the firm appears on the Financial Services Register.

What case officers usually ask about

AreaTypical questions
Business modelExactly which payment or e-money services each product involves, and the flow of funds for each
PeopleEach director's and manager's relevant experience, time commitment and UK base
OwnershipThe chain to the ultimate owners, source of funds and close links
FinancesAssumptions behind the forecasts, the downside case and evidence of funding
SafeguardingThe bank, the reconciliation method and the resolution pack
Financial crimeThe business-wide risk assessment, monitoring scenarios and the MLRO's resources
OperationsIT systems, security, outsourcing oversight and the wind-down plan

Preparing answers to these questions before filing, and building them into the documents, is what turns an application into a complete one sooner.

Why some FCA applications take much longer than others

The main drivers are the quality of the application and the complexity of the business, more than the licence type. Complexity is acceptable when it is clearly described, with responsibilities assigned and controls that match the model. Questions multiply when the model is hard to follow, when responsibilities are unclear or when controls do not fit the risks described.

Changes made after submission are the other main driver. A new product, a different owner, a replacement director, a change of technology provider or a new payment flow can require the FCA to reassess parts of the file that were already settled.

Complete applications are the main way to avoid delay

The twelve-month statutory deadline and the FCA's ten-month target for incomplete applications are upper limits, not normal timelines. An application is incomplete when evidence is missing, explanations are thin, documents are inconsistent with each other, or a material question is unresolved.

The FCA's published good practice notes for applicants make the same point. It looks for policies tailored to the business, documents that align with one another, clear information on planned IT systems, forecasts with notes and assumptions, evidence of funding commitments, and historic accounts with the initial application. If information the FCA needs is not provided within its deadlines, the FCA can decide the application on what it has. Filing a few weeks early to meet an internal date can cost months during the assessment.

Three checks that prevent avoidable questions

  • Confirm the licence fits the product. Check that the stored value the firm plans to issue meets the legal definition of e-money, or that the service is a payment service, before choosing the route. A mismatch found during the assessment changes the whole file.
  • Show the UK presence. The CEO and MLRO are based in the UK, staff can evidence their right to work here, and the office is a real working space rather than a virtual address.
  • Explain payments security. The security policy describes how systems, data and customer funds are protected, including strong customer authentication and incident reporting.

A strong regulatory business plan moves the assessment forward

The business plan is the document every other document is read against. It covers the activities, customers, products, transaction flows, revenue model, markets, banking, safeguarding, governance, outsourcing and planned growth, and it maps each legal entity and each activity to the permissions applied for. The FCA's good practice notes encourage applicants to use the FCA's sample business plan and to analyse why each permission is needed.

The forecasts, safeguarding procedure, financial crime risk assessment, policies and answers to FCA questions should all describe the same business. When they do, the case officer can move through the file quickly.

Governance determines whether the FCA is comfortable with the application

The FCA expects directors and senior managers with relevant knowledge and experience, compliance and financial crime expertise, and a board that oversees the business effectively. Founders with strong technology or commercial backgrounds and limited regulated experience usually add experienced payments people to the board or leadership team before filing.

The structure should fit the size of the business. The FCA's good practice notes ask firms to explain how individuals with several roles will divide their time, to show where staffing gaps will be filled and when, and to demonstrate that the firm itself understands its obligations rather than relying on its consultants. Senior people who can explain the business in their own words shorten the assessment.

Financial crime controls carry significant weight

The FCA expects the money laundering reporting officer (MLRO) to understand the firm's actual money laundering risks and to have the capability to manage them. A generic anti-money laundering policy does not meet that standard. The business-wide risk assessment reflects the firm's real customers, products, countries, payment flows and distribution channels.

Areas the FCA examines most closely include high-risk payment corridors, agent networks, complex business-to-business payment chains, merchant acquiring, cryptoasset-related flows and cross-border group structures. Where transaction monitoring is outsourced, the application still explains the monitoring scenarios, thresholds and how alerts are escalated and decided.

Safeguarding is now central to the application

Since 7 May 2026, payment and e-money firms operate under the CASS 15 safeguarding rules introduced by PS25/12. The application explains when funds become relevant funds, how they are segregated, where the safeguarding accounts are held, how daily reconciliations work, how third parties are selected and monitored, how the resolution pack is kept, and how safeguarding is governed and reported.

Not every safeguarding account has to be open at submission, but the arrangements must be specific. An application that names the intended bank and shows the onboarding is under way gives the FCA confidence; one that says the bank will be chosen after authorisation generates questions. Banks run their own due diligence, so those conversations start early. Our article on the CASS 15 safeguarding regime explains each requirement.

Financial forecasts need to match the regulatory story

Forecasts reflect realistic growth, volumes, revenue, staffing, compliance and technology costs, and the capital requirement as it grows. Where the business plan describes gradual market entry, a first-year forecast with rapid customer growth needs explaining. A base case and a downside case, with the point at which further funding is needed and evidence that shareholders will provide it, answer most of the FCA's financial questions in advance.

The capital requirement and the cost of running the firm through the assessment are set out in our guide to what an FCA PI or EMI licence costs.

Ownership structures add time when they are hard to follow

The FCA identifies every shareholder with 10% or more, the ultimate beneficial owners and any close links, and assesses the fitness and propriety of each controller. Overseas holding companies, trusts, nominee arrangements and multi-layer structures lead to more questions.

A clear ownership chart, source of funds evidence for each controller and an explanation of which functions sit inside the UK entity, from the outset, keep this part of the assessment short. For group structures, the FCA also asks whether any overseas law could affect its ability to supervise the UK firm.

Changing the business model during the application can reset parts of the assessment

Adding cards or e-money while a PI application is under review, switching technology provider or safeguarding bank, changing ownership or moving to a different target market are all material changes. Each can require updates to the permissions, business plan, forecasts, safeguarding procedure, risk assessment and policies, and a fresh review of those documents.

Settling the fundamental decisions before filing is the single most effective way to keep an application on its planned timetable.

How quickly should applicants answer FCA questions?

Within the FCA's deadline, and completely. A fast but partial answer produces another round of questions. The answers that move an application forward:

  • Address exactly what was asked, with evidence.
  • Explain any change and why it was made.
  • Update every affected document at the same time, so the file stays consistent.
  • Keep version control, so the case officer can see what changed.

One person coordinating the responses across management, advisers and suppliers keeps the answers consistent.

Can the FCA refuse an application instead of asking more questions?

Yes. The FCA can refuse an application if it is not satisfied that the conditions for authorisation or registration are met, and it issues a warning notice before a final decision. An applicant can withdraw before a decision, but the application fee is not refunded, and a new application means a new fee and a fresh start.

Where the FCA has serious concerns, it may tell the applicant before deciding, which gives the firm the chance to strengthen the application or withdraw and reapply. Our article on why the FCA refuses EMI and API applications sets out what the FCA looks for in each area.

API, SPI, authorised EMI and small EMI applications differ in complexity

The statutory framework is similar across the routes, but the substance differs.

  • API: operates without volume limits and needs full governance, capital, safeguarding, risk and financial crime arrangements.
  • Authorised EMI: often the most complex, because wallets, accounts, cards, payments and FX can sit in one model.
  • Small PI and small EMI: narrower scope because of the volume limits and activity restrictions, with shorter assessments, but registration is still a full review of the people, controls and safeguarding.

The route follows the business plan. Choosing a small registration for speed when the plan shows growth past the limits leads to a second application within a short period.

Can a firm launch while the FCA application is pending?

No. A firm cannot provide regulated payment services or issue e-money before it is authorised or registered, unless another lawful basis applies, such as operating as the agent or distributor of a licensed firm. Submitting an application gives no temporary permission.

The firm can build its technology, recruit, contract partners and prepare marketing during the assessment. Contracts with partners usually include conditions linked to authorisation, and public launch dates are set once the decision is close.

Should you apply before banking and technology partners are finalised?

The core operating model must be developed enough for the FCA to assess, but not every contract has to be signed. Advanced discussions or provisional arrangements with the main providers, including the safeguarding bank, the core platform and the card sponsor, show the model is real.

Placeholder partners lead to rewritten documents when the actual arrangements differ. Some banks complete onboarding only once authorisation is near, which is acceptable when the application shows where the process stands.

How to keep an FCA PI or EMI application on schedule

There is no legitimate shortcut, but most delay is avoidable. Before filing:

  • Settle the scope, permissions and business model.
  • Appoint a credible leadership team, including the MLRO.
  • Prepare realistic forecasts with a downside case and evidence of funding.
  • Write every policy for the firm's own business.
  • Document the ownership chain and source of funds in full.
  • Name the safeguarding bank and the main suppliers.

During the review, manage the FCA's questions from one place, answer accurately and on time, and tell the case officer about any change before it happens. The firm's free FCA application gap checker tests a draft application against these points.

Timelines for variations, agents and changes in control

Existing firms face shorter but still significant timelines for changes to their licence.

  • Variation of permission: adding payment services to an existing authorisation. The FCA's median in April to June 2026 was 164 days, about 5.5 months, against the same 3 and 10 month targets as new applications.
  • Agents: the FCA's target is to process 95% of notifications for a UK agent within 2 months. An agent cannot act for the firm until it appears on the register.
  • Change in control: a new controller at 10% or more needs FCA approval before completion. The FCA has 60 working days from a complete notice to decide, and the period can be paused while it asks for more information.
  • Small to authorised: a small PI or small EMI that outgrows its limits makes a new application for authorisation, which follows the full timeline.

From approval to launch

Authorisation is the point at which the firm may start trading, but launch depends on the work done in parallel. Firms that use the assessment period well launch within weeks of the decision. The final steps are:

  1. Activate the safeguarding and operating accounts and test the daily reconciliation.
  2. Complete end-to-end testing of the platform, card programme and payment rails.
  3. Train staff on the financial crime, complaints and Consumer Duty procedures.
  4. Publish the customer terms, the safeguarding disclosure and the complaints procedure.
  5. Set the reporting calendar, including the monthly safeguarding return and the first regulatory returns.

Card scheme sponsors and banks often complete their own final approvals only once the FCA decision is issued, so the launch plan allows a short period for them after authorisation.

The FCA is working to faster targets

The FCA's target for payment services and e-money applications is to decide 95% within 3 months of a complete application and within 10 months of receipt for an incomplete one, shorter than the 12-month statutory limit. These are targets for the FCA's own performance, not approval times for any one firm.

Faster processing does not mean lighter scrutiny. Complete, consistent applications are the ones that benefit most from the shorter targets.

What timeline should founders put in their business plan?

PhasePlanning figure
Regulatory structuring and route selection2 to 4 weeks
Application preparation2 to 4 months
FCA assessment, API or authorised EMI6 to 8 months
Pre-launch implementation after approvalRuns in parallel; final testing in the weeks after the decision

A business plan that assumes launch three months after filing sets an expectation the FCA's own figures do not support. Planning on 6 to 8 months for the assessment, with contingency for a new hire, a change of safeguarding bank or an extra round of questions, keeps funding and launch commitments realistic. Simple applications can move faster.

How Buckingham Capital Consulting can help

Buckingham Capital Consulting has worked on UK payment and e-money authorisations since 2013. It obtained FCA API authorisation for Nexpay, Orbital, Oval and Global Send, FCA EMI authorisation for Dzing Finance, Hryze and HFS, and FCA SPI registration for Onpoint Money. The firm scopes the route and permissions, prepares the full application, from business plan and forecasts to safeguarding, financial crime, wind-down and policies, and coordinates the answers to the FCA's questions through to the decision.

Frequently asked questions

How long does an FCA payment institution licence take in 2026?

The firm plans authorised PI applications at 6 to 8 months from submission, after 2 to 4 months of preparation. The FCA's median for payment and e-money authorisations in April to June 2026 was 219 days.

How long does an FCA EMI licence take?

The same 6 to 8 months from submission for an authorised EMI, with 3 to 4 months of preparation. A small EMI registration is shorter.

Why does the FCA say three months if applications take longer?

Three months is the statutory deadline for a complete application. Most applications become complete during the assessment, after the FCA's questions are answered.

What is the longest an FCA PI or EMI application can take?

The statutory limit is 12 months from receipt. The FCA's own target is to decide incomplete applications within 10 months.

What causes FCA payment or EMI applications to be delayed?

Incomplete or inconsistent documents, changes to the business model after filing, unclear ownership, thin financial crime controls and unsettled safeguarding arrangements.

Can I start trading while my FCA application is pending?

No. Payment services and e-money issuance need authorisation or registration first, unless the firm operates as the agent or distributor of a licensed firm.

How long does an SPI registration take?

The firm plans small PI registrations at weeks to a few months from submission when the file is complete.

References

  1. FCA: Authorisations operating service metrics 2026/27 Q1
  2. FCA: Authorisation and registration applications, good practice and areas for improvement
  3. FCA: Payments and e-money firm applicants
  4. The Payment Services Regulations 2017
  5. The Electronic Money Regulations 2011
  6. FCA PS25/12: Changes to the safeguarding regime for payments and e-money firms

About Buckingham Capital Consulting

Buckingham Capital Consulting has obtained FCA payment institution and EMI licences for firms including Nexpay, Orbital, Global Send and Hryze since 2013, and arranges the safeguarding and operating accounts alongside the application. The firm plans each application timetable from preparation to decision and manages the FCA's questions so the file is complete as early as possible.

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.