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How Much Does an FCA PI or EMI Licence Cost in 2026? Fees, Capital and Real Application Costs

Published 6 July 2026 · Last reviewed 17 October 2026 · Buckingham Capital Consulting
Contents
  1. FCA PI and EMI costs at a glance
  2. What is the FCA application fee for an authorised payment institution in 2026?
  3. What is the FCA application fee for an EMI licence?
  4. How much does an SPI, small EMI or RAISP application cost?
  5. How much initial capital does an authorised payment institution need?
  6. How much capital does an EMI need?
  7. Regulatory capital is not the same as a licence fee
  8. What are the ongoing capital requirements for an API?
  9. What are the ongoing capital requirements for an authorised EMI?
  10. How much capital does a small EMI need?
  11. Ongoing FCA fees continue after authorisation
  12. Professional application costs can exceed the FCA filing fee
  13. The cost of management and compliance is often underestimated
  14. Safeguarding creates both set-up and ongoing costs
  15. Banking and infrastructure costs are separate from FCA authorisation
  16. Technology can be one of the largest pre-launch costs
  17. Financial crime compliance carries a real operating cost
  18. Insurance can be required for certain payment services
  19. Regulatory reporting and audits create recurring costs
  20. What does an FCA licence really cost before launch?
  21. When each cost falls due
  22. What a complete application project covers
  23. Applying yourself can reduce professional fees but not regulatory requirements
  24. Buying an existing PI or EMI is not necessarily cheaper
  25. How should founders budget for an API application?
  26. How should founders budget for an authorised EMI application?
  27. What should be included in a realistic FCA licensing budget?
  28. The cost of moving from a small licence to full authorisation
  29. The cost of serving EU customers
  30. How Buckingham Capital Consulting can help
  31. Frequently asked questions
Key takeaways
  • FCA application fees are £5,640 for an authorised EMI, £2,820 or £5,640 for an authorised PI, and £1,130 for a small PI, small EMI or RAISP.
  • Initial capital is €20,000, €50,000 or €125,000 for an authorised PI and €350,000 for an authorised EMI; only the highest applicable figure applies.
  • Capital stays in the company; ongoing own funds rise with growth, for example an EMI with €25m of average outstanding e-money needs €500,000 under Method D.
  • The FCA's 2026/27 periodic fees start at £2,063 for an authorised EMI and £628 for an authorised PI; small EMIs pay £1,432 and small PIs £652 flat.
  • CASS 15 safeguarding, in force since 7 May 2026, adds daily reconciliation, a monthly return and an annual audit for firms safeguarding above £100,000.
  • The firm plans PI and EMI authorisations at 6 to 8 months from submission, so working capital must cover that period on top of regulatory capital.

FCA PI and EMI costs at a glance

An FCA payment institution (PI) or electronic money institution (EMI) licence costs far more than the regulator's application fee. A realistic budget has three different kinds of money in it: fees the firm pays and does not get back, operating costs it spends to build and run the business, and regulatory capital it keeps inside the company. Treating these as one number either overstates or understates what a founder needs to raise.

The tables below set out the regulator-set figures for each licence type. Every fee is taken from the FCA's application fees page (updated 13 July 2026) and the FCA's final fee rates for 2026/27 (PS26/14, published 2 July 2026). Capital figures come from the Payment Services Regulations 2017 (PSRs) and the Electronic Money Regulations 2011 (EMRs) and are set in euros.

Authorised licences

Cost itemAuthorised PI (API)Authorised EMI
FCA application fee£2,820 or £5,640£5,640
Initial capital€20,000, €50,000 or €125,000€350,000
Ongoing capitalHigher of initial capital and Method A, B or CHigher of €350,000 and Method D, plus A, B or C for unrelated payments
FCA periodic fee 2026/27£628 minimum, plus £0.309 per £1,000 of relevant income above £100,000£2,063 minimum, plus £43.40 per £1m of average outstanding e-money above £5m
Annual safeguarding auditRequired above the exemption thresholdRequired above the exemption threshold

Small and registered licences

Cost itemSmall PI (SPI)Small EMI
FCA application fee£1,130£1,130
Initial capitalNoneNone below €500,000 average outstanding e-money, then 2%
FCA periodic fee 2026/27£652 flat£1,432 flat
Annual safeguarding auditNot required; voluntary audit encouragedRequired above the exemption threshold

A registered account information service provider (RAISP) also pays a £1,130 application fee and needs professional indemnity insurance in place of initial capital. A variation of permission to add services costs £1,410 or £565, which is half of the Category 4 or Category 3 fee; there is no fee to remove services.

What is the FCA application fee for an authorised payment institution in 2026?

The FCA groups application fees into numbered categories. An authorised payment institution falls into Category 4 or Category 5, depending on the payment services it applies for. The services are listed as paragraphs (a) to (h) of Schedule 1 to the PSRs.

Payment services applied forFee categoryFee
Any of paragraphs (a) to (e): cash placement and withdrawal, executing transfers, credit-linked transfers, card issuing and merchant acquiringCategory 5£5,640
Only paragraphs (f) to (h): money remittance, payment initiation, account informationCategory 4£2,820

An application that combines services from both groups pays the higher fee. The fee is paid through the FCA's Connect system when the application is submitted, it is non-refundable whatever the outcome, and the FCA returns an application without assessing it if the correct fee has not been paid. Earlier figures of £2,790 and £5,580 are out of date.

What is the FCA application fee for an EMI licence?

An authorised EMI falls into Category 5 and pays £5,640. Applying for payment services alongside e-money issuance does not increase the fee, because the payment services are covered by the same authorisation, but each service must still be described, resourced and supported by policies in the application.

The fee is separate from the €350,000 initial capital and is the smallest of the regulator-set costs. Paying it does not reserve a place or start the statutory clock on an incomplete file. The full EMI procedure, from documents to case officer questions, is set out in our UK EMI licence guide.

How much does an SPI, small EMI or RAISP application cost?

A small payment institution, a small EMI and a registered account information service provider all fall into Category 3 and pay £1,130. These routes cost less at the outset, but they are registrations with limits, and they suit a business whose plan sits within those limits for several years.

  • Small PI: payment transactions up to a monthly average of €3m; no e-money; no payment initiation or account information services.
  • Small EMI: average outstanding e-money up to €5m and unrelated payment transactions up to a monthly average of €3m; no payment initiation or account information services.
  • RAISP: account information services only, with professional indemnity insurance in place of capital.

A small firm that outgrows its limits applies for authorisation as a new application, with the full fee, capital and assessment. Choosing small status when the plan shows rapid growth usually means paying for two applications within a short period.

How much initial capital does an authorised payment institution need?

Initial capital is the minimum level of the firm's own funds it must hold before authorisation. For an API it depends on the payment services, under Schedule 3 to the PSRs.

Payment servicesInitial capital
Money remittance only€20,000
Payment initiation services€50,000
Any of paragraphs (a) to (e)€125,000
Account information services onlyNone; professional indemnity insurance instead

Where a firm applies for several services, the highest applicable figure applies; the amounts are not added together. A firm offering money remittance and merchant acquiring needs €125,000, not €145,000. Because the figures are set in euros, the sterling amount moves with the exchange rate, so firms hold a margin above the minimum on the day the capital is evidenced.

How much capital does an EMI need?

An authorised EMI must hold initial capital of at least €350,000 (EMRs Schedule 2, paragraph 2), evidenced before authorisation. The FCA may accept final evidence of the capital later in the assessment, before the decision is made.

Payment services related to issuing e-money do not add to the €350,000. Payment services that are not related to e-money do not change the initial capital either, but they add to the ongoing own funds requirement once the firm is trading. Because the ongoing requirement grows with outstanding e-money, the business plan should model capital for the forecast period, not only for the day of authorisation.

Regulatory capital is not the same as a licence fee

Capital stays inside the authorised company as an asset on its balance sheet. It is not paid to the FCA and it is not spent. It must, however, meet four conditions:

  • It is eligible own funds, mainly paid-up share capital and audited retained earnings.
  • It is genuinely held by the company, not lent to it for the application and returned afterwards.
  • Its source is documented, so the FCA can trace where the money came from.
  • It remains available to absorb losses and is not withdrawn by shareholders once the firm is authorised.

Capital can be used to pay running costs only to the extent the company stays above its requirement at all times. In practice founders raise capital for the requirement and separate working capital for salaries, suppliers and launch, and they do not count the same money twice.

What are the ongoing capital requirements for an API?

After authorisation, an API must hold own funds at least equal to the higher of its initial capital and an ongoing figure calculated under Method A, B or C of Schedule 3 to the PSRs. The FCA tells the firm which method applies and can direct it to hold up to 20% more or less than the result.

MethodBasis of the calculation
Method A10% of the previous year's fixed overheads
Method BMonthly payment volume in bands: 4% of the first €5m, 2.5% of the next €5m, 1% of the next €90m, 0.5% of the next €150m and 0.25% above that, multiplied by a scaling factor
Method CA relevant indicator made up of interest income, fees and commissions and other operating income, in bands from 10% down to 1.5%, multiplied by a scaling factor

Worked example: Method B

An API providing transfers and card issuing processes an average of €8m of payment transactions a month. The calculation is 4% of €5m (€200,000) plus 2.5% of €3m (€75,000), giving €275,000, with a scaling factor of 1 for these services. The firm's requirement is €275,000, because it is higher than the €125,000 initial capital. A money remittance firm with the same volume applies a scaling factor of 0.5 and needs €137,500.

The point for budgeting is that growth raises capital. A firm that plans to scale volumes should show in its forecasts when it will need to inject further capital and where it will come from.

What are the ongoing capital requirements for an authorised EMI?

For e-money issuance, an authorised EMI calculates its ongoing requirement under Method D: 2% of average outstanding e-money. Average outstanding e-money is the average of the e-money in issue at the end of each day over the preceding six calendar months. The firm holds the higher of €350,000 and the Method D figure.

Average outstanding e-moneyMethod D at 2%Own funds required
€5m€100,000€350,000
€17.5m€350,000€350,000
€25m€500,000€500,000
€50m€1m€1m

The Method D requirement passes the €350,000 floor at €17.5m of average outstanding e-money. Where the EMI also provides payment services not linked to e-money, the FCA adds a requirement under Method A, B or C for those services.

How much capital does a small EMI need?

A small EMI needs no initial capital while its average outstanding e-money stays below €500,000. Once it reaches or is projected to reach €500,000, it must hold capital of at least 2% of its average outstanding e-money (EMRs Schedule 2, paragraph 3). At the €5m ceiling that is €100,000. A small PI has no initial capital requirement.

Ongoing FCA fees continue after authorisation

After authorisation, the FCA charges an annual periodic fee to fund its supervision. Each type of firm sits in a fee block, and the fee depends on a measure of its size. The FCA publishes final rates each summer; the 2026/27 rates were set in PS26/14 on 2 July 2026.

Fee blockFirm type2026/27 periodic fee
G.3Authorised payment institutions£628 minimum, plus £0.309 per £1,000 of relevant income above £100,000
G.4Small payment institutions£652 flat
G.10Authorised EMIs£2,063 minimum, plus £43.40 per £1m of average outstanding e-money above £5m
G.11Small EMIs£1,432 flat

Worked example

An authorised EMI with £25m of average outstanding e-money pays the £2,063 minimum plus 20 times £43.40 (£868), a periodic fee of £2,931 for 2026/27. In its first year, a newly authorised firm pays a proportion of the annual fee based on the months remaining in the fee year.

Firms also pay the Financial Ombudsman Service general levy, which is a small amount for most payment and e-money firms, and any case fees for complaints referred to the Ombudsman. The periodic fee is rarely the largest operating cost, but it belongs in every forecast.

Professional application costs can exceed the FCA filing fee

The largest cost before submission is usually the work of preparing the application. It depends on the permissions sought, the complexity of the model, how much of the compliance framework already exists and how much support the firm needs. A full application covers:

  • A business plan, programme of operations and three-year financial forecasts with stress scenarios.
  • Capital calculations and the evidence of initial capital.
  • Governance, the structural organisation and the people assessments.
  • Safeguarding procedures, the resolution pack and the reconciliation method.
  • Risk management, financial crime, outsourcing, security and business continuity policies.
  • A wind-down plan and, for APIs and EMIs, the controllers and close links forms.

The FCA reads these documents against each other. A forecast that assumes a different customer base from the business plan, or a safeguarding procedure that names a different bank from the programme of operations, generates questions that lengthen the assessment. Consistency is what the professional work buys.

The cost of management and compliance is often underestimated

The FCA expects governance in proportion to the size and complexity of the business. A board of one director with an outsourced policy set does not meet that standard for an authorised firm. The usual leadership team for an API or EMI includes:

  • A CEO with payments or e-money experience, based in the UK.
  • A money laundering reporting officer (MLRO), based in the UK.
  • A compliance officer, combined with the MLRO role only where the business is small.
  • Finance expertise able to prepare capital calculations and regulatory returns.
  • Independent non-executive directors for larger or more complex firms.

These are salaries the firm pays from before authorisation, because the FCA assesses the people at application stage and expects them to be in post or committed. They are ongoing costs and belong in the forecasts for the whole period, not only the launch year.

Which roles can be combined or outsourced?

In a small firm the compliance officer and MLRO roles can sit with one person, provided that person has the time and experience for both. Compliance monitoring, internal audit and parts of financial crime operations, such as screening alert review, can be outsourced to specialist providers. The MLRO role itself, and the board's responsibility for the business, stay inside the firm. The FCA looks at whether each person named has enough time for the role, so a director who holds several other positions is asked to explain how they will divide their time.

How staffing cost grows after launch

As customers and volumes grow, the firm adds financial crime analysts, a dedicated compliance team, customer support trained in complaints handling and vulnerable customers, and finance staff for regulatory reporting. The forecasts in the application should show when each hire is made, because the FCA compares planned growth with planned resourcing.

Safeguarding creates both set-up and ongoing costs

Safeguarding protects customer money so it can be returned in full if the firm becomes insolvent. The FCA's CASS 15 rules, introduced by Policy Statement PS25/12, came into force on 7 May 2026, and they turned safeguarding into a set of daily, monthly and annual obligations with real running costs:

  • Identifying which funds are relevant funds and segregating them on receipt.
  • Daily internal reconciliations and regular external reconciliations against bank statements.
  • Monitoring the banks and third parties that hold or process customer funds.
  • Maintaining a resolution pack an insolvency practitioner could use.
  • Submitting the monthly safeguarding return to the FCA.
  • Commissioning the annual safeguarding audit.

Choosing the safeguarding method

MethodHow it worksCost considerations
Segregation in a safeguarding accountCustomer funds held in a designated account at a bank, or invested in secure low-risk assetsBank account fees, reconciliation tooling and staff time; the usual choice
Insurance or comparable guaranteeAn insurer or bank guarantees the funds if the firm becomes insolventPremium set by the provider; rarely offered to new firms

What drives safeguarding cost

The cost rises with the number of currencies, banks and payment flows the firm runs, because each one needs its own reconciliation. Firms that receive funds through card acquirers or agents also reconcile amounts in transit. Automating the reconciliation and the monthly return from the start keeps the cost proportionate as volumes grow.

Banks set their own fees for safeguarding accounts, and there is no regulated price. Opening a safeguarding account can take as long as the application itself, so it starts early. The annual audit applies to authorised PIs, authorised EMIs and small EMIs; a firm that has not been required to safeguard more than £100,000 at any time over at least 53 weeks is exempt, and small PIs are encouraged to arrange one voluntarily. Our article on the CASS 15 safeguarding regime explains each obligation. Safeheld, the firm's own safeguarding platform, runs the daily reconciliation and the monthly return.

Banking and infrastructure costs are separate from FCA authorisation

An FCA licence does not come with a bank account, card scheme access, IBANs or payment rails. Each provider runs its own due diligence and sets its own commercial terms. The infrastructure a typical PI or EMI needs includes:

  • A safeguarding account and an operating account.
  • Card issuing through a scheme principal member, known as a BIN sponsor, and a card processor.
  • A ledger or core e-money platform.
  • Access to Faster Payments, SEPA or SWIFT, directly or through a sponsor bank.
  • FX liquidity for multi-currency products.

Commercial terms can include set-up fees, minimum monthly commitments, per-transaction charges, collateral reserves and prefunding. Prefunding and reserves tie up cash in the same way capital does, so the forecast shows them separately from operating spend.

Technology can be one of the largest pre-launch costs

There is no requirement to build technology in-house. Most new PIs and EMIs license a core platform and add specialist tools. Outsourcing does not transfer regulatory responsibility, so the firm still carries out supplier due diligence, signs written contracts with audit and exit rights, oversees performance and plans for continuity if a supplier stops.

ApproachSuitsCost profile
White-label platformNew firms launching a standard wallet, card or transfer productLower set-up cost, ongoing licence and per-transaction fees
Licensed core plus own front endFirms that want their own customer experienceModerate set-up cost, platform fees plus an in-house product team
Own buildFirms with a distinctive model and an experienced engineering teamHighest set-up cost and longest build; lower per-transaction cost at scale

Cost follows product complexity. A single-currency transfer service needs far less than a multi-currency EMI with cards, FX, APIs for business customers and merchant acquiring. Whatever the product, the budget covers the regulatory functions as well as the customer-facing ones: transaction monitoring, sanctions screening, reconciliations, regulatory reporting, complaints handling, fraud controls and management information for the board.

Financial crime compliance carries a real operating cost

The FCA expects financial crime controls proportionate to the customers, products and countries the firm serves. Those controls include customer identification and verification, sanctions and politically exposed person screening, transaction monitoring, fraud prevention, case management and suspicious activity reporting to the National Crime Agency.

ControlWhat it covers
Identity verificationDocument and biometric checks at onboarding, and business verification for corporate customers
ScreeningSanctions, politically exposed persons and adverse media, at onboarding and on an ongoing basis
Transaction monitoringRules and models that flag unusual payments for review
Fraud preventionDevice, behaviour and payment checks, including authorised push payment fraud controls
Case managementRecording investigations, decisions and suspicious activity reports

Software is only part of the cost. Alerts need people to investigate them, higher-risk customers need enhanced due diligence, and the MLRO needs the time and team to oversee the framework and report to the board. A budget that funds the screening tools but not the analysts understates both the readiness the FCA expects at application and the cost of running the firm.

Insurance can be required for certain payment services

Firms providing payment initiation or account information services must hold professional indemnity insurance or a comparable guarantee. The minimum cover is calculated using the method in the FCA's Approach Document, and the policy must meet those terms; a general professional liability policy is not enough on its own.

Premiums are set by insurers, and new firms without trading history may receive fewer quotes. Firms identify their insurance needs early, because the application includes evidence of cover. Firms that safeguard through insurance rather than a segregated account also need a policy that meets the safeguarding rules, which is rarely available in the market.

Regulatory reporting and audits create recurring costs

Authorised firms submit a regular cycle of returns, including capital returns, the payments fraud report, the operational and security risk report, the monthly safeguarding return and event-driven notifications. Small firms have a lighter set. Each return needs accurate data from the firm's systems, reviewed before submission.

ReturnWho submits itFrequency
REP017 payments fraud reportAuthorised PIs and authorised EMIsEvery 6 months
REP017 payments fraud reportSmall PIs, small EMIs and RAISPsEvery 12 months
REP018 operational and security risk reportAll payment service providersAt least once a year
FIN060 EMI returnAuthorised EMIsPeriodic, as set in SUP 16
FIN060b annual returnSmall EMIsAnnually
FSA057 transactions reportSmall PIsBefore the end of each January
Safeguarding returnFirms that safeguard under CASS 15Monthly
Payment services and e-money complaints reportAll payment service providersPeriodic

Firms that compile returns by hand from disconnected systems spend more on reporting as they grow and have a higher chance of errors. Building reporting into the core platform from launch keeps the cost flat as volumes rise. Our guide to FCA regulatory reporting for payment and e-money firms lists every return. The statutory audit of the annual accounts and the annual safeguarding audit are separate engagements, priced by the auditor.

What does an FCA licence really cost before launch?

There is no single figure. Two firms applying for the same licence can have very different budgets because of their products, volumes, team and suppliers. A realistic pre-launch budget covers six areas:

AreaWhat it includes
FCA application fee£1,130 to £5,640, non-refundable
Regulatory capital€20,000 to €350,000 initially, retained in the company
Professional supportApplication preparation, legal and corporate work
Management and complianceSalaries from before authorisation
Technology and infrastructurePlatform, screening, banking, cards, prefunding
Working capitalRunning costs through the assessment and early trading

Working capital often matters as much as regulatory capital. An EMI that holds exactly €350,000 can still lack the cash to pay salaries, suppliers and advisers while its application is assessed. The FCA reviews whether the firm is funded for the forecast period, not only whether it meets the capital minimum.

Worked example: working capital

Take an illustrative EMI whose leadership team, office, platform and advisers cost £60,000 a month from the start of preparation. If preparation takes four months and the assessment eight, the firm spends £720,000 before it can take its first customer, on top of the €350,000 it must keep as capital. If revenue then takes six months to cover running costs, the founders need funding for a further period of losses. The FCA expects the forecasts to show this funding in place, with a downside case.

When each cost falls due

Costs arrive in stages, and the funding plan follows the same sequence. Committing spend before it is needed ties up cash; committing it too late lengthens the assessment.

StageCosts that fall due
PreparationCompany formation, application preparation, first leadership hires, supplier selection
SubmissionFCA application fee; initial capital deposited or committed; office in place
AssessmentSalaries, supplier contracts, safeguarding and operating account onboarding, answers to FCA questions
AuthorisationPro-rated FCA periodic fee and levies; platform go-live; card sponsor and scheme fees; prefunding
First year of tradingFull staffing, monitoring and screening, monthly safeguarding returns, safeguarding and statutory audits, further capital as volumes grow

The pre-authorisation stages carry cost with no revenue, which is why founders who plan for the full assessment period, rather than the three-month statutory figure, raise the right amount the first time.

What a complete application project covers

Application support is offered at very different scopes, and comparing prices is only meaningful when the scope is the same. A document set is one part of the work. A complete project also covers:

  • Financial modelling and the capital calculations under the correct method.
  • Corporate structuring, controllers and close links.
  • Safeguarding design and the banking relationship.
  • Revisions to the documents as the model develops before submission.
  • Answering the FCA case officer's questions through to the decision.
  • Implementation support so the firm is ready to trade on authorisation.

Documents that do not match the real business create inconsistencies the case officer will ask about. Whoever prepares the application, the FCA expects the policies to be written for the applicant's own model rather than taken from a template.

Applying yourself can reduce professional fees but not regulatory requirements

There is no legal requirement to use an adviser. Firms can prepare and submit their own application through Connect, and the FCA's pre-application support service offers meetings to some applicants. The main contact on the application must be an individual at the firm in either case.

The standard the FCA applies does not change. The saving depends on in-house expertise: a team that has run a PI or EMI before can prepare much of the file itself, while founders new to the regime spend significant time learning it and often rewrite documents after the first round of questions. Time is a cost too, because salaries and suppliers run throughout the assessment.

Buying an existing PI or EMI is not necessarily cheaper

Acquiring an authorised firm replaces the application with a purchase price and the cost of legal, regulatory and financial due diligence. The buyer must obtain FCA approval for the change in control before completion; under section 189 of the Financial Services and Markets Act 2000 the FCA has 60 working days from a complete notice to decide, and the period can be paused while it asks for further information.

The buyer also inherits the firm's history, systems and weaknesses. A low-priced firm with gaps in safeguarding or financial crime controls can cost more to remediate than a new application, and planned changes to the business model or management add further FCA work. Our guide to FCA change of control applications covers the process.

How should founders budget for an API application?

  1. Start with the application fee (£2,820 or £5,640) and the initial capital for the services (€20,000, €50,000 or €125,000).
  2. Add the cost of preparing the application and the leadership team's salaries from the start of preparation.
  3. Add technology, banking, safeguarding and financial crime tools, with any prefunding or reserves.
  4. Fund working capital for the assessment period and a realistic period of early trading.
  5. Model the ongoing capital requirement under the method that will apply as volumes grow.
  6. Run a downside case with slower growth and higher costs, and keep regulatory capital out of the cash available for spending.

The FCA must decide a complete application within three months and any application within twelve months. The firm plans API and EMI applications at 6 to 8 months from submission, and the budget should cover that period. Our guide to FCA PI and EMI timelines sets out each stage.

How should founders budget for an authorised EMI application?

An EMI budget starts with the £5,640 fee and the €350,000 initial capital, and then adds the larger costs of an e-money product: wallets and cards, the core platform, scheme sponsorship, banking, safeguarding, financial crime controls and the leadership team. The plan keeps regulatory own funds and operational working capital in separate lines.

The model then projects average outstanding e-money and any unrelated payment volumes month by month, so the board can see when the Method D requirement will pass €350,000 and when further capital will be needed. An EMI planning to hold £25m or more of customer balances should expect its capital requirement, its periodic fee and its safeguarding costs all to rise with that growth.

What should be included in a realistic FCA licensing budget?

A complete budget runs from the start of preparation to the end of the first full year of trading:

  • FCA application fee and, later, the periodic fee and levies.
  • Initial capital and the projected ongoing capital requirement.
  • Application preparation, legal and corporate work.
  • Leadership and compliance salaries.
  • Technology, financial crime systems and reporting tools.
  • Safeguarding and operating accounts, card sponsorship and prefunding.
  • Professional indemnity insurance where required.
  • Statutory audit and the annual safeguarding audit.
  • Contingency for further FCA questions, a change of supplier or a longer assessment.

Two questions decide the budget. The first is what it costs to obtain the licence. The second, and usually the larger, is what it costs to build and sustain a business that meets the FCA's standards once authorised.

The cost of moving from a small licence to full authorisation

A small PI or small EMI that outgrows its limits does not vary its registration; it applies for authorisation. That means a second application fee of £2,820 or £5,640, the full initial capital of €125,000 or €350,000, an expanded leadership team and a full FCA assessment. The firm keeps trading under its registration while the application is assessed, but it must stay within the small limits until it is authorised.

For a business whose plan shows growth past the limits within two to three years, applying for full authorisation from the outset usually costs less overall than two applications. For a business that will stay small, or that needs to test a product first, registration is the lower-cost start.

The cost of serving EU customers

UK firms lost EU passporting rights on 31 December 2020. A UK PI or EMI that wants to serve customers in the European Economic Area needs a separate entity authorised in an EU member state, with its own initial capital, local management, application fee and supervision. The EU minimum capital figures mirror the UK ones: €350,000 for an EMI and €20,000 to €125,000 for a PI, depending on services.

Groups that plan to serve both markets budget for two licensed entities from the start and choose the EU country on the basis of the regulator's approach, local substance requirements and the time it takes to decide applications. Running two entities also doubles a large part of the safeguarding, reporting and audit cost.

How Buckingham Capital Consulting can help

Buckingham Capital Consulting has worked on payment and e-money authorisations since 2013. It obtained FCA API authorisation for Nexpay, Orbital, Oval and Global Send, and FCA EMI authorisation for Dzing Finance, Hryze and HFS. The firm assesses the right licence route, prepares and manages the full application, answers the FCA's questions, and compares a new authorisation with the purchase of an existing firm, including due diligence and the change of control. Details are on our UK EMI licence page.

Frequently asked questions

How much is the FCA application fee for an API in 2026?

£2,820 for money remittance, payment initiation or account information only, and £5,640 if any of the services in paragraphs (a) to (e) are included. The fee is non-refundable.

How much is the FCA application fee for an EMI?

£5,640 for an authorised EMI (Category 5) and £1,130 for a small EMI (Category 3). The fee is separate from the €350,000 initial capital.

How much capital is required for an FCA payment institution?

€20,000 for money remittance only, €50,000 for payment initiation and €125,000 for services in paragraphs (a) to (e). The highest applicable figure applies, not the sum.

Is €350,000 the total cost of obtaining an EMI licence?

No. It is capital retained in the company, not a fee, and excludes the application fee, professional work, staffing, technology, banking and working capital.

What are the FCA's annual fees for a payment or e-money firm?

For 2026/27 an authorised EMI pays from £2,063, an authorised PI from £628, a small EMI £1,432 and a small PI £652, under PS26/14.

Can regulatory capital be spent on running costs?

Only to the extent the firm stays above its capital requirement at all times. Founders raise separate working capital for salaries, suppliers and launch.

What is the real total cost of an FCA PI or EMI licence?

There is no single total; it depends on permissions, product complexity, team and infrastructure. The FCA fee is usually a small part of the commitment.

References

  1. FCA: Application fees for EMIs and payment institutions
  2. FCA PS26/14: FCA regulated fees and levies 2026/27
  3. The Payment Services Regulations 2017, Schedule 3
  4. The Electronic Money Regulations 2011, Schedule 2
  5. FCA PS25/12: Changes to the safeguarding regime for payments and e-money firms
  6. FCA: Payment Services and Electronic Money, Our Approach

About Buckingham Capital Consulting

Buckingham Capital Consulting has obtained FCA payment institution and EMI licences for firms including Nexpay, Orbital, Global Send and Dzing Finance since 2013, and arranges the safeguarding and operating accounts alongside the application. The firm builds the capital model and launch budget with each client, so the business plan the FCA reviews is funded for the full forecast period.

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.