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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
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 and cryptoasset firms.

Since 2013Advising global payment firms
60+Countries licensed in
250+Licences obtained globally
Clients
ClearBankVolkswagenMacmillan Cancer SupportRoyal College of MusicStaysureOval 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 to decision.

Day oneReady to trade

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

Your teamKey people in place

We assemble your team: directors, a compliance officer and an MLRO.

Same dayWritten proposal

The licence, the requirements, the cost and the timing for your business.

How we get you licensed and live

  1. Scoping and proposal. We confirm the permissions, the capital method and the FCA fee category, and request a pre-application meeting with the FCA’s support service.
  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, ready for submission through Connect.
  3. Banking. Your safeguarding account with an authorised credit institution and your operating accounts, opened alongside the application.
  4. Regulator engagement. We answer every case officer question through to the decision; the FCA’s published median for these authorisations is 219 days.

Your team, 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 peopleWe assemble your team: directors, a compliance officer and an MLRO.
BankingSafeguarding, operating and settlement accounts, card acquiring and payment processing, opened alongside the application.
TechnologyWhite-label technology for accounts, payments, wallets and card programmes, ready to go live with the licence.

One programme, from scoping to launch. Speak to an expert about 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
  • Set up the business operations

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

Requirements, capital, timing, fees and common questions, drawn 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 EMI 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

We run this regime for you on Safeheld. Our safeguarding service sets out the full requirements.

Timing

FigureValueSource
Statutory decision period3 months from a complete application; 12 months maximumElectronic Money Regulations 2011, 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 submissionOur own figure, from the regulator’s published data and our applications

Regulator figures are quoted as published and converted to months. Our realistic timeline assumes 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; we prepare the file
Professional feesFixedQuoted 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. Our regulatory compliance service runs that programme for you, 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. We open each alongside the application, so you trade on the day the licence is granted. See banking and payment processing.

Common questions

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. We plan 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. Our marketplace lists authorised companies for sale and our 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 builds licensed payment, e-money, crypto and stablecoin businesses: the licence, the team, the technology, the bank accounts and card issuing.

This guide is general information, not legal advice. Requirements and fees change, and the regulator’s own publications take precedence.

How we work.

  • Senior-ledThe same senior team handles your application from the first call to approval, including every question the regulator raises.
  • Same dayA reply within three business hours and a written proposal the same day: the licence, the requirements, the cost and the timing.
  • ConfidentialYour plans, your application and any listing stay private. Clients are named only with their agreement.
  • Live workspaceDocuments, regulator questions, messages and progress in a shared client workspace, visible to your team at every stage.

Why firms choose BCC.

  • OperatorsWe have run regulated payment businesses, held regulator-approved roles and licensed payment firms in more than 60 countries since 2013.
  • One teamOne in-house team runs the whole programme, from the application to the day you go live.
  • ArrangedBank and safeguarding accounts, card issuing and payment processing, arranged directly through our relationships with banks, card schemes, issuers and processors.

Apply for this licence.

The licence, your team, banking and technology, delivered as one programme.