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Licence guide

UK electronic money institution licence.

For businesses that hold customer balances in wallets, prepaid cards or accounts and want one authorisation covering e-money and every payment service in the UK market.

Published 16 October 2026 · Last reviewed 17 October 2026 · Reviewed against the regulator’s current publications
FCARegulator
€350,000Initial capital
£5,640Application fee
6 to 8 monthsOur realistic timeline
Same dayWritten proposal

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
dzingElectronic Money Institution

Obtained Dzing Finance’s FCA Authorised Electronic Money Institution licence.

hryzeElectronic Money Institution

Obtained Hryze’s FCA Electronic Money Institution licence.

moneliqVariation of Permission

Obtained Moneliq’s FCA PSD2 variation of permission.

What you get

6 to 8 monthsLicence 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, a compliance officer 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 licence

  1. Scoping and proposal. The permissions, the capital method and the FCA fee category are confirmed in a written proposal the same day, with a pre-application meeting through the FCA’s support service booked where it adds value.
  2. Application pack. The business plan, projections with two stress scenarios, the CASS 15 safeguarding arrangements and resolution pack, the wind-down plan and the individual and controller forms to the standard the Connect portal expects.
  3. Banking. The safeguarding account with an authorised credit institution and the operating accounts are arranged before submission, so the account evidence sits in the pack the case officer reviews.
  4. Regulator engagement. Each case officer question is answered through one process with the evidence assembled, until the decision; the FCA’s published median for these authorisations is 219 days.

Key people, banking and technology

You will need directors with payments experience, a compliance officer, a senior manager to run the e-money and payment services, and an MLRO.

Key peopleThe firm introduces candidates for directors, a compliance officer 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

Electronic money institution · FCA

Dzing Finance

  • Prepared and submitted the EMI licence application
  • Wrote the policies and procedures the application required
  • Supported the business set-up

Outcome. EMI licence granted by the FCA.

Electronic money institution · FCA

Hryze Finance

  • Prepared and submitted the EMI licence application
  • Built the compliance policy and procedure framework

Outcome. EMI licence granted by the FCA.

Electronic money institution · FCA

EuroPanPay

  • Prepared and filed the EMI licence application for its move into the UK market
  • Wrote the application policies and operating procedures

Outcome. EMI licence approved for operations across the UK and Europe.

Buckingham Capital Consulting guided us through the EMI licence process with precision and clarity. Their regulatory experience made all the difference.
HFS, FCA electronic money institution
The licence in detail

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

Key takeaways
  • An authorised EMI issues e-money and provides any payment service in the UK, with no limit on outstanding e-money; a small EMI is a lower-cost registration with limits.
  • Initial capital is €350,000, held before authorisation; ongoing own funds are at least 2% of average outstanding e-money (Method D).
  • The application fee is £5,640 for an authorised EMI and £1,130 for a small EMI; periodic fees follow under the FCA’s fee-block for e-money firms.
  • The FCA must decide within 3 months of a complete application and within 12 months of an incomplete one; recent FCA data show a median of around seven months to determination for payments and e-money applications.
  • Safeguarding moved to the client-assets standard on 7 May 2026: daily reconciliations, a resolution pack, monthly returns and an annual safeguarding audit.
  • The firm must be a UK body corporate with its head office in the UK and carry on at least part of its business here.

Who needs an EMI licence

A business that issues electronic money, meaning stored value that customers load and spend, needs authorisation under the Electronic Money Regulations 2011. That covers digital wallets, prepaid card programmes, virtual IBAN and account products, and any platform that holds customer balances it can spend on their instruction. An authorised EMI may also provide every payment service a payment institution provides, including money remittance, card acquiring, payment initiation and account information, under the same licence.

A business that moves money without holding stored value needs a payment institution licence instead. A business that will hold limited balances and serve the UK only may register as a small EMI.

Authorised EMI and small EMI

Authorised EMISmall EMI
StatusAuthorisedRegistered
Outstanding e-moneyNo limitAverage not above €5 million
Initial capital€350,000None below €500,000 average outstanding e-money; 2% of average above it
Payment servicesAll, including unrelated servicesLimited; monthly payment transactions not above €3 million
Application fee£5,640£1,130
GeographyUK; passporting to the EEA is no longer availableUK only
SafeguardingRequiredRequired

Most businesses with investors, a card programme or an ambition beyond a single product apply for authorisation from the outset. A small EMI that grows past the limits must apply for authorisation and may not continue past them.

What the FCA requires

The regulations set the conditions; the FCA’s application form and its published expectations set the standard. An applicant must show all of the following.

  • Legal form and location. A UK body corporate with its head office, and registered office if it has one, in the UK, carrying on at least part of its e-money and payment business here.
  • Capital. Initial capital of €350,000 held before authorisation, and own funds thereafter of at least 2% of average outstanding e-money, plus Method A, B or C capital for any unrelated payment services.
  • Safeguarding. Customer funds segregated into a designated safeguarding account with an authorised credit institution or the Bank of England, or invested in secure liquid assets with a custodian, or covered by an insurance policy or comparable guarantee, with daily reconciliation and the records set out below.
  • Governance and people. Directors and managers of good repute with the knowledge and experience to run the business; a fit and proper assessment of every controller; an MLRO; and governance, risk management and internal controls proportionate to the business.
  • Regulatory business plan. The programme of operations, the products, the customers, the flow of funds, three-year financial projections with two stress scenarios, and the wind-down plan.
  • Policies written for the business. AML and sanctions, safeguarding, outsourcing, operational resilience, complaints, data and conduct. The FCA states that generic policies and unanswered form questions are a principal cause of rejection.
  • Money laundering registration. Registration under the Money Laundering Regulations runs alongside the authorisation.

Safeguarding under CASS 15

From 7 May 2026 the FCA’s supplementary safeguarding regime applies to every authorised EMI, small EMI and authorised payment institution. It keeps the existing safeguarding methods and adds the controls of a client-assets regime.

RequirementWhat it means in practice
Daily reconciliationInternal and external reconciliations on every reconciliation day, with discrepancies resolved and recorded
Resolution packThe records an administrator would need to return funds, maintained continuously
Monthly returnA monthly safeguarding return to the FCA
Annual auditAn annual safeguarding audit by a qualified auditor, submitted to the FCA; firms safeguarding under £100,000 for 53 weeks or more are exempt
Third partiesDue diligence on, and diversification of, the institutions holding safeguarded funds
Insurance and guaranteesPayouts conditional only on an insolvency certification; replacement cover arranged three months before expiry

The firm runs this regime for clients on Safeheld and sets out the full requirements in its safeguarding service.

Timing

FigureValueSource
Statutory decision period3 months from a complete application; 12 months maximumPayment Services Regulations 2017, regulation 9
Regulator’s published figure219 calendar days, about 7 months, median time to determination for new payment and e-money authorisationsFCA authorisations operating service metrics, Q1 2026/27
Application preparation6 to 10 weeksFrom instruction to submission, including banking in parallel
Our realistic timeline6 to 8 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£5,640Authorised EMI, pricing category 5; £1,130 for a small EMI; paid on submission and non-refundable
Initial capital€350,000Held before authorisation; remains in the business as own funds
Periodic feeFrom the first yearFCA fee-block for e-money issuers, by relevant income
Safeguarding auditAnnualAuditor’s fee; the firm prepares the file
Professional feesFixed, in writingThe firm quotes a fixed fee for the application after scoping

Why applications are delayed or refused

The FCA publishes the reasons it rejects or returns applications. Three recur.

  1. The wrong fee or missing minimum information. The FCA rejects these without assessment and the applicant starts again.
  2. Generic policies. Policies copied from templates, or that describe a different business, are treated as an incomplete application.
  3. Unanswered questions and unclear flows of funds. Where the form or the business plan leaves the case officer to guess, the clock stops while the FCA asks.

The Central Bank of Ireland and De Nederlandsche Bank publish the same three causes for their own regimes, which is a fair indication of what every regulator looks for first.

After authorisation

Authorisation starts supervision. An EMI reports to the FCA on capital, safeguarding and conduct, notifies changes in controllers and permissions, maintains its policies and its MLRO, and files its annual safeguarding audit. The firm’s regulatory compliance service runs that programme as a project or on retainer.

Banking

An EMI needs a safeguarding account that meets the acknowledgement-letter requirement, an operating account for its own funds and settlement accounts in the currencies it issues. The firm arranges each through institutions that serve regulated firms; the accounts are opened during the application so the firm trades on the day the licence is granted. See banking and payment processing.

Questions firms ask

How long does an FCA EMI application take?

The FCA must decide within three months of a complete application and twelve months of an incomplete one. Its published metrics for the first quarter of 2026/27 show a median of 219 calendar days to determination for new payments and e-money applications. The firm plans for six to eight months after submission.

How much capital does a UK EMI need?

Initial capital of €350,000, held before authorisation, and own funds thereafter of at least 2% of average outstanding e-money, plus capital for any unrelated payment services.

What is the FCA application fee for an EMI?

£5,640 for an authorised EMI and £1,130 for a small EMI, paid on submission and non-refundable.

Can a UK EMI passport into the EU?

No. Passporting from the UK ended with the transition period. Firms serving the EEA obtain an EU licence, most often in Ireland, Lithuania, the Netherlands or Malta.

Does the EMI need a UK office and UK directors?

The EMI must be a UK body corporate with its head office in the UK and carry on at least part of its business here. The FCA expects the people who run the business to be here; there is no fixed residency rule for directors.

What changed with CASS 15?

From 7 May 2026 EMIs and payment institutions reconcile safeguarded funds daily, keep a resolution pack, file a monthly safeguarding return and submit an annual safeguarding audit.

Can we buy an authorised EMI instead of applying?

Yes, subject to the FCA’s approval of the new controller. The firm’s marketplace lists authorised companies for sale and its transactions practice runs the change of control.

What is a small EMI?

A registration for firms whose average outstanding e-money stays below €5 million and whose monthly payment transactions stay below €3 million. It is cheaper and quicker, serves the UK only, and converts to full authorisation when the business grows.

References

  1. FCA: Apply for authorisation or registration as an e-money institution or payment institution
  2. FCA: Authorisation application fees
  3. Electronic Money Regulations 2011, Schedule 2 (capital)
  4. Electronic Money Regulations 2011, regulation 9 (decision period)
  5. Electronic Money Regulations 2011, regulation 21 (safeguarding)
  6. FCA PS25/12: Changes to the safeguarding regime for payments and e-money firms
  7. FCA authorisations operating service metrics 2026/27 Q1

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.