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Licence guide

Small payment institution registration.

Payment businesses starting in the UK with modest volumes register as a small payment institution to trade under FCA supervision without initial capital, then move to authorisation as they grow.

Published 16 October 2026 · Last reviewed 17 October 2026 · Reviewed against the regulator’s current publications
FCARegulator
NoneInitial capital
£1,130Application fee
3 to 4 monthsOur realistic timeline
€3 millionMonthly limit

Firms we have licensed.

Selected engagements from more than 250 licences obtained since 2013, for payment, e-money, cryptoasset and consumer credit firms.

Since 2013Advising global payment firms
60+Countries licensed in
250+Licences obtained globally
Clients
ClearBankVolkswagenStaysureOval MoneyEMQCentus
nexpayPayment Institution

Obtained Nexpay’s FCA Authorised Payment Institution licence.

Payment Institution

Obtained Orbital’s FCA Authorised Payment Institution licence.

ovalPayment Institution

Obtained Oval’s FCA Authorised Payment Institution licence with open banking permissions.

What you get

3 to 4 monthsRegistration granted

Our realistic timeline from submission, set against the regulator’s own published figures.

Day oneReady to trade

Safeguarding, operating and settlement accounts opened alongside the application, so you trade on authorisation.

Your teamKey people in place

Candidates introduced for directors and an MLRO, each assessed against the regulator’s standard.

Same dayWritten proposal

A reply within three business hours and a written proposal the same day: the licence, the requirements, the cost and the timing.

How the firm obtains the registration

  1. Scoping and proposal. The monthly transaction average against the €3 million limit, the services in scope and whether registration or authorisation fits the business plan are confirmed in writing, with the FCA’s Pre-Application Support Service used where it adds value.
  2. Application pack. The application form, the individual and controller forms, the financial forecasts, policies written for the business and the safeguarding arrangements where the business safeguards for submission through Connect with the category 3 fee.
  3. Banking. The operating and settlement accounts and, where the business safeguards, a separate safeguarding account with an authorised credit institution are arranged through the firm’s relationships before the decision.
  4. Regulator engagement. Each FCA question is answered through one process with the evidence assembled, with the correct fee and the minimum information in place from the outset, until the FCA’s decision on registration.

Key people, banking and technology

You will need directors and a senior manager with payments experience, and an MLRO, none of whom has a money laundering or other financial crime conviction.

Key peopleThe firm introduces candidates for directors and an MLRO from its register of senior compliance, financial crime, risk and finance professionals, and assesses each against the regulator’s approval standard before they are put forward.
BankingSafeguarding, operating and settlement accounts, card acquiring and payment processing, arranged through the institutions that serve regulated firms, in parallel with the application.
TechnologyBespoke white-label technology for accounts, payments, wallets and card programmes, built and ready to go live with the licence.

One engagement and one timetable, from scoping to launch. Speak to an expert about the people, the banking and the technology for this licence.

Case studies

Small payment institution · FCA

Onpoint Money

  • Managed the SPI registration and submission
  • Planned the regulatory route and the evidence
  • Wrote the compliance policies and procedures
  • Provided ongoing regulatory advice

Outcome. SPI registration granted, with compliance policies and regulatory reporting in place.

The licence in detail

The regulator’s requirements, capital, timing, fees and the questions firms ask, from the regulator’s own publications.

Key takeaways
  • A small payment institution is registered, not authorised, by the FCA under the Payment Services Regulations 2017, for a business whose monthly average of payment transactions, including its UK agents, stays at or below €3 million over 12 months.
  • There is no initial capital requirement; an authorised payment institution holds €20,000 to €125,000 depending on its services.
  • The FCA application fee is £1,130 under pricing category 3; the annual fee is a flat £652 under fee-block G.4 for 2026/27.
  • Every payment service is available except the 2 open banking services, payment initiation and account information, and the registration covers the UK only, with no passporting.
  • The FCA decides within 3 months of a complete application and within 12 months at most, the same periods as for authorisation.
  • Regulation 14 requires the head office, registered office or place of residence to be in the UK and no relevant financial crime conviction for anyone managing the business; safeguarding under regulation 23 is voluntary.

Who needs SPI registration

A business that provides payment services as a regular occupation in the UK needs FCA authorisation or registration. Registration as a small payment institution is the route for a business whose payment volumes stay within the €3 million monthly average and which does not need the open banking services or access to other markets. It suits remittance businesses, merchant payment services and payment account providers at the start of their growth, and businesses testing a payment product in the UK before committing the capital that authorisation requires.

A business that will issue stored value needs e-money authorisation or registration instead. A business that expects to pass the limit within its plan applies for authorisation as a payment institution from the outset.

What a small payment institution may do

Small payment institutionAuthorised payment institution
StatusRegisteredAuthorised
Monthly payment transactionsAverage not above €3 million over 12 months, including UK agentsNo limit
Payment accounts, payment execution, payment instruments, card acquiring, money remittancePermittedPermitted
Payment initiation and account informationNot permittedPermitted
Initial capitalNone€20,000, €50,000 or €125,000 by service
Application fee£1,130, category 3£2,820 or £5,640
SafeguardingVoluntaryRequired
GeographyUK only; no passportingUK; no passporting

The services open to a small payment institution are operating payment accounts and executing transactions on them, issuing payment instruments, acquiring card transactions and money remittance. Payment initiation and account information require authorisation.

What the FCA requires

Regulation 14 of the Payment Services Regulations 2017 sets the conditions for registration. An applicant shows all of the following.

  • Volume. A monthly average of payment transactions, including those of its UK agents, not above €3 million over 12 months.
  • Services. No payment initiation or account information services.
  • Location. Its head office, registered office or place of residence in the UK. There is no rule that directors must be resident.
  • No relevant convictions. No person responsible for managing or operating the business convicted of money laundering, terrorist financing or other financial crime offences.
  • People and governance. Directors and managers of good repute with appropriate knowledge and experience, fit and proper controllers, and governance proportionate to the business.
  • Money laundering registration. Inclusion in the register kept under the Money Laundering Regulations where it applies.
  • Application. The application form, the individual and controller forms, policies written for the business, financial forecasts, and the safeguarding and wind-down arrangements, submitted through Connect with the fee, with an optional pre-application meeting under the FCA’s Pre-Application Support Service.

Safeguarding

Safeguarding under regulation 23 is voluntary for a small payment institution. Banks and customers expect it, and most small payment institutions safeguard. A firm that safeguards segregates customer funds and, by the end of the business day after receipt, places them in a separate account with an authorised credit institution or the Bank of England, or in secure liquid assets, or covers them with an insurance policy or comparable guarantee. The firm sets out the arrangements in its safeguarding service.

Timing

FigureValueSource
Statutory decision period3 months from a complete application; 12 months maximumPayment Services Regulations 2017, regulation 9, applied to registration by regulation 15
Application preparation4 to 6 weeksFrom instruction to submission, including banking in parallel
Our realistic timeline3 to 4 months after submissionThe firm’s own figure, from the regulator’s published data and its own applications

Figures published by the regulator are quoted as published and converted to months. The realistic timeline is the firm’s own, for a complete, well-prepared application.

Costs

ItemAmountNotes
Application fee£1,130FCA pricing category 3; paid on submission
Initial capitalNoneNo initial capital requirement for a small payment institution
Annual fee£652Fee-block G.4 flat fee for small payment institutions, 2026/27
Professional feesFixed, in writingQuoted after scoping

Why applications are delayed or refused

The FCA publishes the reasons it rejects or returns applications, and they apply to registration as they do to authorisation.

  1. The wrong fee or missing minimum information. The FCA rejects these without assessment and the applicant starts again.
  2. Generic policies. Policies that do not describe the applicant’s business are treated as an incomplete application.
  3. Unanswered form questions. Where the form leaves the case officer to ask, the clock stops while the FCA waits for the answer.

Moving up to an authorised payment institution

A small payment institution applies for authorisation as a payment institution when its monthly average of payment transactions is set to pass €3 million, or when it wants to add payment initiation or account information services. Authorisation brings initial capital of €20,000, €50,000 or €125,000 by service, an application fee of £2,820 or £5,640, mandatory safeguarding and the FCA’s three-month statutory period. The firm plans the move against the business plan so the authorisation is in place before the limit is reached.

Banking

A small payment institution needs an operating account and settlement accounts in the currencies it pays out, and a separate safeguarding account where it safeguards. Banks review the safeguarding arrangement and the financial crime framework before opening them. The firm arranges each through its relationships during the application. See banking and payment processing.

Questions firms ask

What is the limit for a small payment institution?

A monthly average of payment transactions, including those of its UK agents, not above €3 million over 12 months. A business set to pass it applies for authorisation as a payment institution.

How much does SPI registration cost?

The FCA application fee is £1,130 under pricing category 3, and the annual fee is a flat £652 under fee-block G.4 for 2026/27. There is no initial capital requirement.

How long does SPI registration take?

The FCA must decide within three months of a complete application and within twelve months at most, under regulation 9 as applied to registration by regulation 15. The firm plans for three to four months after submission.

Can a small payment institution provide open banking services?

No. Payment initiation and account information services require authorisation as a payment institution.

Does a small payment institution need a UK office or UK directors?

Its head office, registered office or place of residence must be in the UK. There is no rule that directors must be resident.

References

  1. FCA: Apply for authorisation or registration as an e-money institution or payment institution
  2. FCA: Authorisation application fees
  3. FCA Handbook FEES 4 Annex 11: periodic fees for payment services
  4. Payment Services Regulations 2017, regulation 14 (conditions for registration)
  5. Payment Services Regulations 2017, regulation 15 (decision period applied to registration)
  6. Payment Services Regulations 2017, regulation 23 (safeguarding)

About Buckingham Capital Consulting

A regulatory advisory firm to payment, e-money and cryptoasset companies since 2013, with more than 250 licences obtained in more than 60 countries. The firm advises on authorisation, compliance, safeguarding, banking and transactions, and builds the white-label payment and card technology its clients launch on.

A written proposal on cost, timing and requirements, the same day: speak to an expert.

This guide is general information for firms considering authorisation and is reviewed against the regulator’s published requirements. It is not legal advice; requirements and fees change, and the regulator’s current publications take precedence.

How we work.

  • Senior-ledEvery engagement is led by the practitioners who prepare the application and attend the regulator.
  • Same dayA reply within three business hours and a written proposal the same day: the licence, the requirements, the cost and the timing, before you commit.
  • ConfidentialYour plans, your application and any listing stay private. Clients are named only with their agreement.
  • Live workspaceEvery engagement runs in a shared workspace on Hector: documents, regulator questions, messages and progress in one place, visible to your team at every stage.

Why firms choose BCC.

  • OperatorsWe have taken firms through licensing, run regulated payments and consumer credit businesses, and signed the regulatory returns ourselves.
  • BankingSafeguarding, operating and settlement accounts arranged alongside the authorisation, through the institutions that serve this market.
  • FoundersThe firm is run by founders who have built and run regulated payments businesses, so every position is given with the launch date and the cost of waiting in mind.
  • One firmLicensing, key people, banking, compliance, technology and transactions from the same team, for the life of the regulated firm.

Apply for this licence.

The requirements, the cost and the timing for your business, in a written proposal the same day.