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 measure | Duration | Source |
|---|---|---|
| Application preparation | 2 to 4 months | Firm's planning figure |
| Case officer allocation | Up to 20 working days | FCA |
| Statutory deadline, complete application | 3 months | PSRs and EMRs |
| Statutory deadline, any application | 12 months | PSRs and EMRs |
| FCA target, incomplete application | 10 months | FCA |
| Median, April to June 2026 | 219 days (about 7 months) | FCA |
| Lower quartile, April to June 2026 | 168 days (about 5.5 months) | FCA |
| Upper quartile, April to June 2026 | 268 days (about 9 months) | FCA |
| API and authorised EMI, submission to decision | 6 to 8 months | Firm'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.
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.
For new payment services and e-money authorisations and registrations decided in April to June 2026, the FCA reports:
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.
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.
| Licence | Preparation | Submission to decision |
|---|---|---|
| Authorised payment institution | 2 to 4 months | 6 to 8 months |
| Authorised EMI | 3 to 4 months | 6 to 8 months |
| Small PI registration | 4 to 8 weeks | Weeks to a few months |
| Small EMI registration | 2 to 3 months | A 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.
| Area | Typical questions |
|---|---|
| Business model | Exactly which payment or e-money services each product involves, and the flow of funds for each |
| People | Each director's and manager's relevant experience, time commitment and UK base |
| Ownership | The chain to the ultimate owners, source of funds and close links |
| Finances | Assumptions behind the forecasts, the downside case and evidence of funding |
| Safeguarding | The bank, the reconciliation method and the resolution pack |
| Financial crime | The business-wide risk assessment, monitoring scenarios and the MLRO's resources |
| Operations | IT 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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
Within the FCA's deadline, and completely. A fast but partial answer produces another round of questions. The answers that move an application forward:
One person coordinating the responses across management, advisers and suppliers keeps the answers consistent.
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.
The statutory framework is similar across the routes, but the substance differs.
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.
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.
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.
There is no legitimate shortcut, but most delay is avoidable. Before filing:
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.
Existing firms face shorter but still significant timelines for changes to their licence.
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:
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'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.
| Phase | Planning figure |
|---|---|
| Regulatory structuring and route selection | 2 to 4 weeks |
| Application preparation | 2 to 4 months |
| FCA assessment, API or authorised EMI | 6 to 8 months |
| Pre-launch implementation after approval | Runs 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.
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.
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.
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.
Three months is the statutory deadline for a complete application. Most applications become complete during the assessment, after the FCA's questions are answered.
The statutory limit is 12 months from receipt. The FCA's own target is to decide incomplete applications within 10 months.
Incomplete or inconsistent documents, changes to the business model after filing, unclear ownership, thin financial crime controls and unsettled safeguarding arrangements.
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.
The firm plans small PI registrations at weeks to a few months from submission when the file is complete.
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.