United Kingdom · Authorisation
FCA EMI Authorisation in the UK
Full FCA authorisation to issue e-money and provide related payment services under the Electronic Money Regulations 2011 — submitted via the Connect portal.
At a glance
Is this the right permission?
Three tests. All three must be true.
The costly mistake here isn't failing the application — it's applying for the wrong permission. EMI and Payment Institution look similar from the outside and are priced very differently.
You issue e-money
You hold stored value your customers can spend or redeem at par — a wallet balance, a prepaid card float, an account balance you issue against funds received. This is the line: if you do this, a Payment Institution licence will not cover you.
You need the payment services too
An Authorised EMI can provide every payment service in Schedule 1 alongside e-money issuance, under one permission. If you only execute payments and never hold stored value, a Payment Institution is cheaper and faster.
You have, or will have, a UK presence
Either a UK-incorporated company with its head office here, or a UK branch of a foreign parent — the branch route carries a narrower permitted scope. Either way the FCA tests for genuine UK decision-making, not a registered address.
Not sure whether you are issuing e-money or just moving it? That distinction sets your capital requirement, your safeguarding obligations and your timeline — it is the first thing we scope, and the cheapest thing to get right.
Scope your services before you apply, not after
If you do not select account information or payment initiation services on the application, the FCA writes a standing restriction onto your Register entry requiring you to refrain from providing them indefinitely. Adding either later means a full Variation of Permission — effectively a second authorisation — so the cheapest time to decide is before you file.
Overview
What UK EMI authorisation actually requires.
An Electronic Money Institution licence lets you issue e-money and provide the payment services that go with it — the permission most UK-facing fintechs building a wallet, card or account product actually need. The FCA authorises on the Electronic Money Regulations 2011, and it wants evidence, not assurances: a funded firm, a fit and properly governed board, and a genuine UK operating presence.
Small EMI is the lighter-touch alternative for firms staying under the €5 million outstanding e-money threshold — no minimum capital, but you lose access to account information and payment initiation services.
Permitted services
What this licence actually lets you do.
An Authorised EMI's headline permission is issuing electronic money — but regulation 32(1)(a) of the Electronic Money Regulations 2011 ("Additional activities") also lets you provide every payment service defined in Schedule 1, Part 1 of the Payment Services Regulations 2017, without a separate Payment Institution authorisation. Listed below in the Schedule's own order, with its own wording. Regulation 32 also covers closely related operational activities — FX, safekeeping, operating payment systems — but the services below are what actually define what you can offer customers.
E-Money Issuance
Issuing electronic money — and redeeming it at par value on demand, a paired obligation under EMR 2011 Part 5 — the core permission that makes this an EMI licence rather than a Payment Institution one. Everything that follows is available alongside it as an additional activity.
EMR 2011, Part 5 — the core authorisation
Cash Placement
Services enabling cash to be placed on a payment account, and all the operations required for operating a payment account.
PSR 2017, Sch. 1, Part 1(a), via EMR 2011 reg 32(1)(a)
Cash Withdrawal
Services enabling cash withdrawals from a payment account, and all the operations required for operating a payment account.
PSR 2017, Sch. 1, Part 1(b), via EMR 2011 reg 32(1)(a)
Payment Execution
Execution of payment transactions, including transfers of funds on a payment account with the user's payment service provider or with another payment service provider.
PSR 2017, Sch. 1, Part 1(c), via EMR 2011 reg 32(1)(a)
Credit-Funded Execution
Execution of payment transactions where the funds are covered by a credit line for a payment service user.
PSR 2017, Sch. 1, Part 1(d), via EMR 2011 reg 32(1)(a)
Issuing & Acquiring
Issuing of payment instruments, or acquiring of payment transactions.
PSR 2017, Sch. 1, Part 1(e), via EMR 2011 reg 32(1)(a)
Money Remittance
Money remittance.
PSR 2017, Sch. 1, Part 1(f), via EMR 2011 reg 32(1)(a)
Payment Initiation
Payment initiation services.
PSR 2017, Sch. 1, Part 1(g), via EMR 2011 reg 32(1)(a)
Account Information
Account information services.
PSR 2017, Sch. 1, Part 1(h), via EMR 2011 reg 32(1)(a)
Card Acquiring (Merchant Acquiring)
Paragraph (e) covers two different things — issuing payment instruments to your own customers, and acquiring: contracting with a merchant to accept and process their card payments. PSR 2017 regulation 2 defines acquiring as a service provided by contracting with a payee to accept and process payment transactions that result in a transfer of funds to that payee. An Authorised EMI can hold this permission alongside e-money issuance, via regulation 32(1)(a), without a separate PI licence.
PSR 2017, Sch. 1, Part 1(e); definition at reg 2
Scope Account Information & Payment Initiation Now, Not Later
Don't select (g) or (h) at application and think you can add them cheaply once you're live — you can't. The application form itself states that any applicant who doesn't select AIS or PIS gets a permanent restriction written onto their FCA Register entry: the firm is "required to refrain from providing account information services or payment initiation services for an indefinite period." Adding either later means a full Variation of Authorisation application, not a quick amendment. The trade-off: firms that do select AIS/PIS must also hold Professional Indemnity Insurance meeting EBA minimum-amount guidelines, evidenced by an insurer's quote at application stage — so scoping this correctly from day one affects both your permitted scope and your budget.
FCA AEMI application form, Section 3.10; EBA PII Guidelines
Requirements in detail
What you actually need.
Incorporation
You can apply either as a UK-incorporated company with your head office in the UK, or as a UK branch of a foreign parent — though the branch route is restricted to business connected to e-money issuance, a narrower permitted scope than a UK-incorporated subsidiary. Either way, the FCA's “head office” test looks for genuine local decision-making: directors and senior managers actually directing the business from the UK, not a registered address with decisions made elsewhere.
Capital
Authorised EMIs need €350,000 of initial capital in place before authorisation is granted — evidenced, not just promised, typically via an audited account statement or public register certifying the amount. Small EMI is the lighter-touch alternative: no minimum capital, but outstanding e-money is capped at €5 million, and you lose access to account information and payment initiation services. Beyond the initial figure, e-money-only firms also have to calculate ongoing own funds under "Method D" (EMR 2011, Sch. 2, Part 2) — a running requirement, not a one-off injection you never revisit.
Directors
There's no FCA-mandated minimum board size beyond the Companies Act's bare floor of one director. In practice, though, the good-repute and governance-structure requirements — a clear organisational structure with well-defined lines of responsibility — push firms toward more than a sole director. A single-director structure is a common reason applications stall.
Governance & people
Every director and manager has to satisfy the FCA's “good repute” test — evidenced honesty and integrity, relevant competence, and financial soundness — and anyone acquiring 10%+ of the business goes through a separate “fit and proper” controller assessment. In practice this is two distinct tracks, each with its own form: qualifying controllers (10%+ holders) file an EMD Individual Controller form, management files a separate EMD Individual form — both demanding a full ten-year employment history with every gap explained, and a criminal record check (a standard DBS check, or an equivalent for those based outside the UK) no older than six months. Worth correcting directly, since a lot of licensing guides get this wrong: EMIs are not subject to the Senior Managers & Certification Regime (SM&CR) unless they separately hold other FCA permissions. You do still need a formally appointed MLRO under the Money Laundering Regulations 2017 — just not as an SM&CR-badged role.
Ongoing obligations
Authorisation isn't a one-off event. Authorised EMIs are allocated to FCA fee-block G.10, with periodic fees and levies calculated from your own projected average outstanding e-money — plus FOS industry block I18 unless you qualify for an exemption. You'll need the ability to file regulatory returns through RegData, agree to supply financial information at set intervals, and — where a statutory auditor is required under UK company law — name them as part of your application. None of this shows up in the headline capital figure, but it's real, ongoing cost and process from day one of authorisation.
Not sure this is the right permission?
A scoping call maps your regulatory perimeter and confirms which regime actually applies — before any documentation work starts.
Time & cost
What actually drives both.
Three months is the statutory decision period, but it only runs while your application is complete — every information request pauses the clock. What follows is what actually sets the pace.
The statutory clock stops, repeatedly
The FCA has three months to determine a complete application. In practice each query pauses it, which is why a well-prepared file runs nine to twelve months and a thin one runs considerably longer. Preparation quality is the single biggest lever you control.
Capital must be evidenced, not promised
The €350,000 has to be in place and demonstrable before authorisation is granted — typically an audited account statement or a public register certificate. This is a pre-commencement condition, so it gates the final step rather than the first.
Safeguarding arrangements take bank time
You need a segregated safeguarding account, or an insurance policy or comparable guarantee from a provider outside your group. Opening the account is a bank onboarding process with its own timetable, and it cannot start meaningfully until your model is settled.
Individual forms are slower than firm forms
Every director and manager files an EMD Individual form and each 10%+ controller an EMD Individual Controller form — a full ten-year employment history with every gap explained, plus a criminal record check no older than six months. These are external processes that expire, so timing them is its own exercise.
Initial capital
€350,000Held and evidenced before authorisation. Small EMI carries no minimum capital but caps outstanding e-money at €5 million and excludes account information and payment initiation services.
FCA application fee
Payable on filingA non-refundable application fee is paid through the Connect portal when you submit. The current figure is set by the FCA's published fee schedule and confirmed at scoping rather than quoted from memory here.
Ongoing
AnnualPeriodic fees under FCA fee-block G.10, calculated from your projected average outstanding e-money, plus a Financial Ombudsman Service levy unless exempt, RegData reporting, and a statutory auditor where UK company law requires one.
Our fee
Scoped and fixed before documentation work begins, once the first call has established whether you are issuing e-money or only moving it, which Schedule 1 services you need, and whether AIS or PIS are in scope. No hourly drift.
Process & timeline
From scoping to authorisation.
3 months statutory · 9–12 months practical
Document preparation & approval
Full build-out of the documentation suite with you, reviewed and signed off before submission. Preparation quality here is the single biggest driver of speed.
Review & query management
Submission via Connect and the FCA's review. The statutory clock pauses for each information request, so a well-prepared file typically resolves in six to nine months.
Pre-commencement & authorisation
Final conditions — capital injection, safeguarding account and final signed documents — then formal authorisation and go-live under ongoing supervision.
What we prepare
The documentation suite.
54 documents, illustrative — the exact set is tailored to your model. CASS-based safeguarding items are UK-specific.
AML/CTF Programme
The firm's approach to customer due diligence, monitoring, screening and suspicious activity reporting.
+ supporting forms and registers
Safeguarding Programme
Your funds-protection method — segregation or insurance/comparable guarantee — under the FCA's CASS 15 safeguarding regime, plus the resolution pack and governance that sit around it.
CASS 15/10A safeguarding regime is UK-specific. + supporting forms and registers
Governance Framework
The firm's structure, reporting lines, responsibilities and internal control environment.
+ supporting forms and registers
IT & Cybersecurity Programme
The firm's approach to systems, security controls, access management, incident response and mandatory fraud reporting.
+ supporting standards and registers
Business & Operational Documentation
The commercial and operational backbone of the application — how the business runs and is governed.
+ supporting documentation and charts
We build this pack, not a template of it.
Every document is written against your actual services, customers and jurisdictions — which is what makes it survive a regulator’s review and a bank’s due diligence alike.
Who does the work
Senior people, start to finish.
Every application is scoped, built and submitted by senior team members who understand fintech and this specific regime — never delegated to a junior bench.
FAQ
Questions worth asking up front.
No — not unless you separately hold other FCA permissions beyond e-money issuance. This is one of the most commonly repeated mistakes in licensing guides. You still need a formally appointed MLRO under the Money Laundering Regulations 2017, but it isn't an SM&CR-badged Senior Management Function.
Yes, via the branch route — a UK branch of a foreign parent can be authorised. The trade-off is real: a branch-authorised EMI is restricted to business connected to e-money issuance, a narrower permitted scope than a UK-incorporated subsidiary carries. Most firms that want full flexibility incorporate a UK company instead.
There's no FCA-mandated number beyond the Companies Act's floor of one. But the “good repute” and governance-structure tests make a sole-director structure a real risk factor for delay — in practice, most successful applicants have a properly resourced board, not a single controlling individual.
The FCA has three months to decide a complete application, but “complete” is the operative word — the clock pauses every time they raise a query. A well-prepared file typically runs nine to twelve months end to end; a poorly prepared one can run well past that.
It depends on your growth plan, not just your current size. Small EMI needs no minimum capital and is faster to obtain, but caps you at €5 million outstanding e-money and excludes account information and payment initiation services — if you'll outgrow that cap within a year or two, or need those services, it's usually cheaper in the long run to go straight for full authorisation. Neither route carries EU/EEA passporting either way — that ended for UK firms with Brexit, and now requires a separate EU authorisation.
Not cheaply. If you don't select AIS or PIS at application, the FCA writes a standing restriction onto your Register entry stating you're required to refrain from providing them indefinitely. Adding either later means a full Variation of Authorisation application, run essentially as a second authorisation process — not a quick amendment. If there's a realistic chance you'll want either within a few years, it's almost always cheaper to scope them in from the start, even if you don't launch with them.
More than a background-check box-tick. Anyone with a 10%+ qualifying holding files a separate EMD Individual Controller form; each director or manager responsible for the business files their own EMD Individual form. Both demand a full ten-year employment history with every gap explained, a criminal record check (a standard DBS check, or an equivalent for anyone based outside the UK) no older than six months, and — for controllers specifically — disclosure of politically exposed persons links and exactly how the cost of their holding was funded. Incomplete answers are one of the most common causes of stalled applications.
A few that catch firms off guard: periodic FCA fees calculated from your own projected average outstanding e-money (fee-block G.10), a FOS industry-block levy unless you qualify for an exemption, mandatory regulatory reporting via RegData, and — where UK company law requires one — a named statutory auditor. None of these are large individually, but they're recurring, not one-off, and worth budgeting for alongside the €350,000 capital figure, not as an afterthought once you're live.
Other regimes
Not the right fit? See the others.
Secure your UK EMI,
secure your future.
Book a scoping call and we’ll map your fastest, most defensible path to authorisation.