Launching a fintech product or expanding your payment business in the UK? We support clients through every step of obtaining an EMI license: from strategic planning and documentation to direct communication with the FCA and implementation of safeguarding procedures. Our team ensures accuracy, transparency, and compliance: only up-to-date requirements, clear milestones, and realistic timelines. The goal is to help your company enter the UK market quickly and safely.
Electronic money activities in the UK are governed by the Electronic Money Regulations 2011 (EMRs) and the Payment Services Regulations 2017 (PSRs), with supervision by the FCA. Core requirements include initial capital for Authorised EMIs, ongoing own-funds under the EMRs, mandatory safeguarding of customer funds, and compliance with FCA’s organisational and operational standards. Small EMIs are subject to thresholds (average outstanding e-money and, for unrelated payment services, monthly transaction value); exceeding these triggers authorisation. Also note current FCA changes to the safeguarding regime (PS25/12) and updates to the FCA Approach.
Key instruments: EMRs 2011 and PSRs 2017 (FCA-supervised).
Capital & operations: €350,000 for Authorised EMIs; EMRs safeguarding.
Oversight: authorisation/registration and supervision by the FCA.
Types of EMI licenses in United Kingdom
In the UK, there is a single legal framework for electronic money institutions, but the FCA distinguishes two levels depending on the scale of operations: Authorised EMI and Small EMI. This system allows businesses to select the model that best fits their needs: smaller firms may start with fewer requirements, while larger players gain full access to the market.
Authorised Electronic Money Institution
The full EMI license is designed for companies that plan to operate on a larger or even international scale. It enables the issuance of e-money without restrictions, offers the ability to provide a wide range of payment services, and ensures credibility with partners and banks. To qualify, firms must demonstrate a robust business model, sufficient initial capital, and strict compliance with FCA safeguarding and AML requirements.
Minimum initial capital of €350,000
No limits on the issuance of e-money
Ability to provide payment services (transfers, acquiring, cards)
Full FCA supervision
Strict safeguarding and AML requirements
Small Electronic Money Institution
This regime is intended for smaller fintech firms and startups that operate with limited volumes. It allows companies to enter the market with simplified requirements and lower costs, while still providing legitimacy under FCA oversight. However, it comes with thresholds for issued e-money and unrelated payment transactions, and exceeding these thresholds requires upgrading to full Authorised EMI status.
Average outstanding e-money ≤ €5 million
Unrelated payment transactions ≤ €3 million per month
Easier FCA registration process
Reduced capital requirements
Must upgrade to Authorised EMI if thresholds exceeded
Services you can provide with an EMI license in UK
An EMI license in the United Kingdom grants access to a wide range of services in the field of electronic money and payments. This status provides legal recognition, builds trust with banks and partners, and enables expansion across both domestic and certain international markets.
Issuance of electronic money and e-wallets
Execution of domestic and international money transfers
Issuance and management of payment cards
Processing transactions with third-party involvement (API, open banking)
Providing payment services for e-commerce businesses
Safeguarding and holding client funds in compliance with FCA rules
To obtain an EMI licence in the UK, a firm must satisfy regulatory requirements covering financial resources, governance, risk management, safeguarding of client funds, and appropriate legal and operational presence. Below are key requirement areas that FCA scrutinises both at application stage and during ongoing supervision.
Initial and ongoing capital / financial resources
An Authorised EMI is required to have a minimum initial capital of €350,000, as specified under EMRs and enforced by FCA for full EMI authorisation. On top of that, the firm must maintain adequate ongoing own funds: a percentage of outstanding e-money or other liabilities, sufficient to manage liquidity risk, operational losses, and other financial stress scenarios. FCA expects financial forecasts, stress testing, and contingency plans (for example covering counterparty risk, adverse market conditions) as part of the demonstration of financial soundness.
Safeguarding of customer funds
The regulations (EMRs and PSRs) mandate that funds received in exchange for electronic money (and certain payment transactions) are protected – segregated from the firm's own funds or covered by an insurance or comparable guarantee. With recent changes via PS25/12, FCA has increased requirements for audit, stricter reconciliation, robust arrangements with safeguarding providers, and obligations to return relevant funds quickly in case of firm failure. Firms must also have systems to monitor safeguarding arrangements, manage third-party providers, perform periodic reconciliations, and ensure prompt action if there are shortfalls.
Fitness & Propriety of management and key individuals
Key personnel – directors, senior managers, shareholders with significant influence – must pass the «fit and proper» test, demonstrating integrity, competence, relevant experience, and financial soundness. FCA checks for prior misconduct, regulatory history, criminal records, and whether any personal or corporate connections might impede regulatory oversight. The leadership team should have experience relevant to electronic money, payments, AML/KYC, risk management, and operational resilience.
Business plan, programme of operations and governance
Applicants must submit a detailed business plan (typically covering 3 years), including projected revenues, expenses, growth forecasts, and stress scenarios. The programme of operations should outline how the business will run day to day: transaction flows, systems, technology infrastructure, data security, backup and incident management, continuity plans. Governance framework is essential: define roles and responsibilities, internal control, compliance and AML oversight, risk management, policies for handling incidents and customer complaints.
Physical presence, legal form and registered office
The firm must be a UK-registered legal entity (body corporate), have its registered office in the UK and a physical address, which may include an operations office. This ensures FCA can exercise supervision effectively, including inspections, communications, and legal notices. Ownership structure must be transparent: all qualifying shareholders must be identified, and their background checked to ensure no conflicts or risk to effective oversight.
Robust anti-money laundering (AML) and counter-terrorist financing (CTF) measures are mandatory, including client verification (KYC), monitoring transactions, suspicious activity reporting, and proactive systems. Operational resilience: firms must have plans for business continuation, data security, risk of cyber threats, disaster recovery, and mechanisms to manage them. Additionally, new safeguarding regime changes require firms to prepare resolution/wind-down plans (resolution pack), more frequent independent auditing, accurate reporting of safeguarded funds and any shortfalls.
Roadmap to obtain a payment license in United Kingdom
The process of obtaining an EMI license in the UK requires careful preparation and structured engagement with the FCA. Typical timelines range from 6 to 12 months depending on the completeness of documentation, experience of the management team, and responsiveness during the review. Each stage involves internal preparation, submission of documents, and active dialogue with the regulator.
Step 1. Incorporation and initial setup
The first step is to incorporate a legal entity in the UK and establish a registered office. At this stage, the shareholder structure is set, directors and key managers are appointed, and initial arrangements are made with a bank for a safeguarding account. A solid foundation at this stage helps avoid delays and ensures regulatory compliance from the outset.
Incorporation at UK Companies House
Defining shareholder and director structure
Establishing the registered office address
Initial contact with a bank for safeguarding account
Step 2. Documentation and business plan
The second stage involves preparing the core documentation required for FCA submission. This includes a detailed 3-year business plan, programme of operations, IT and safeguarding arrangements, AML/CTF framework, and evidence of sufficient capital. This package demonstrates the firm’s ability to operate transparently and sustainably under FCA supervision.
Drafting a comprehensive business plan and forecasts
Describing operational model and internal procedures
Preparing AML/KYC and risk management documents
Providing proof of capital and financial soundness
Step 3. Submission to FCA and regulatory review
Once the documentation is complete, the full application is submitted via FCA Connect. The FCA conducts a thorough assessment of the firm’s governance, management qualifications, safeguarding systems, and business model. The regulator often issues requests for additional information, so timely and accurate responses are critical.
Submission through FCA Connect portal
FCA review of company documentation and structure
Fit & proper assessment of directors and shareholders
Responding to regulator’s requests within deadlines
Step 4. Decision and post-authorisation setup
The final stage is FCA’s decision and the granting of the EMI license. After authorisation, the firm must finalise its safeguarding account, implement internal policies, and launch operations in full compliance. Ongoing obligations include regular reporting, risk monitoring, and readiness for FCA inspections.
Receiving written authorisation from FCA
Opening the safeguarding account with a bank
Setting up internal reporting and compliance processes
Preparing for regular FCA supervision and inspections
Advantages of EMI license in United Kingdom
Obtaining an EMI license in the UK provides businesses with strong competitive advantages. It not only offers legal recognition but also opens access to Europe’s leading financial hub, builds trust with clients and partners, and allows flexible business models.
Direct access to the UK financial market
Strong regulatory supervision by FCA
Enhanced reputation and client trust
Opportunity for international expansion
Flexible business model and product offering
High standards of customer fund safeguarding
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Don’t delay your fintech launch – the sooner you begin the licensing process, the faster you can operate under FCA supervision. Our expert team will guide you through every stage: from company incorporation and documentation to authorisation and compliance setup.
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