EMI licence in the UKOverview
E-money issuers in the UK are authorised or registered by the FCA under the Electronic Money Regulations 2011 (EMRs). An EMI may also provide payment services under the Payment Services Regulations 2017, and the FCA is its supervisor for anti-money laundering purposes under the Money Laundering Regulations 2017. Applications are made through the FCA's Connect system, and a non-refundable fee, varying by firm type and pricing category, must accompany the application; filings with an incorrect fee are rejected without assessment.
There are two routes. An authorised EMI (AEMI) is required where projected average outstanding e-money exceeds EUR 5 million, or where the firm wishes to provide account information or payment initiation services. It must hold initial capital of at least EUR 350,000 and maintain ongoing own funds. A small EMI (SEMI) may register where average outstanding e-money stays at or below EUR 5 million and average monthly payment transactions do not exceed EUR 3 million; SEMIs cannot offer account information or payment initiation services.
The FCA expects complete, firm-specific applications: tailored policies rather than templates, a main contact who works for the firm rather than an adviser, evidence that the people running the business have payments or e-money experience, balance sheet forecasts with stress-tested scenarios where applicable, and arrangements for capital, safeguarding, wind-down and professional indemnity insurance. The FCA's own published data show that a minority of e-money applications were approved or registered in 2023 and 2024, rising in 2025, which underlines the value of preparation.
The new safeguarding regime took effect on 7 May 2026 after a nine-month deferral. It requires daily checks that the correct amount is safeguarded, monthly safeguarding returns, an annual safeguarding audit by a qualified auditor for firms holding more than GBP 100,000 of customer funds, and stronger planning so that customers are repaid quickly if a firm fails. HM Treasury is also reviewing the wider payments framework, so the legislative basis may evolve further.
Key benefits
- Access to one of the largest and most innovative consumer and business payments markets
- An FCA authorisation recognised by banks, card schemes and investors worldwide
- Small EMI route with lighter requirements for early-stage businesses
- Pre-application support service (PASS) for meetings with the FCA before filing
- Strong safeguarding standards that enhance customer and partner confidence
- English-law contracts and a deep professional and technology talent market
Requirements
- UK-incorporated company with its head office and genuine management in the UK
- Initial capital of EUR 350,000 for an authorised EMI, with ongoing own funds
- Directors and managers of e-money services who are of good repute with appropriate knowledge and experience
- Controller forms for anyone holding a qualifying holding, with source of funds evidence
- Safeguarding arrangements meeting CASS 15, including daily checks, monthly returns and annual audit where applicable
- AML/CTF framework under the Money Laundering Regulations 2017, including a nominated MLRO
- Wind-down plan and, where relevant, professional indemnity insurance for AIS or PIS
- Financial forecasts, balance sheet projections and stress-tested scenarios
- Risk assessment of any unregulated activities carried on alongside e-money
- Robust governance, internal controls, operational resilience and complaints handling
Licence options & capital
Authorised EMI (AEMI)
EUR 350,000 initial capital
Required above EUR 5 million average outstanding e-money or to offer account information or payment initiation services. Full range of e-money and payment services in the UK.
Small EMI (SEMI)
Up to EUR 5 million average outstanding e-money
Registration route for smaller issuers, with average monthly payment transactions capped at EUR 3 million and no AIS or PIS permissions.
Agent or distributor model
Firms not ready for their own authorisation may operate as an agent or distributor of an existing EMI, which remains responsible for compliance.
Step-by-step process
- 1
Scoping and PASS
We confirm whether the model requires AEMI or SEMI status and, where useful, request a pre-application meeting with the FCA.
- 2
Company, people and capital
The UK company is set up, capital is injected, and experienced directors, compliance and MLRO roles are filled.
- 3
Application on Connect
Forms, policies, forecasts, controller and individual forms are submitted with the correct non-refundable fee.
- 4
Case officer review
A case officer is allocated within 20 working days and works through questions, often including interviews with management.
- 5
Determination
The FCA authorises or registers the firm, or the application may be withdrawn or refused if concerns remain.
- 6
Go-live and ongoing compliance
Safeguarding accounts, daily reconciliation, monthly returns and audit arrangements are put in place before launch.
Typical documents
- Completed Connect application with explanations for any questions marked not applicable
- Business plan and programme of operations
- Financial forecasts, balance sheet projections and stress scenarios
- Evidence of initial capital
- Individual forms, CVs and evidence of experience for directors and managers
- Controller forms and group structure chart
- Safeguarding policy, flow of funds diagram and customer journey
- AML/CTF policies, risk assessment and MLRO details
- Wind-down plan and professional indemnity insurance, if applicable
- Governance, risk management, outsourcing and operational resilience policies
How Legal Wealth helps
Legal Wealth helps clients approach the FCA with an application that reflects how the business will really operate. We assist with choosing between AEMI and SEMI status, assembling an experienced UK management team, designing safeguarding to the new CASS 15 standard, and preparing forecasts, policies and controller information. Personal and financial details are handled discreetly throughout, and we plan with clients for life after authorisation, including audits and reporting. Contact info@legalwealthglobal.com to discuss your plans in confidence.
Enquire with Legal WealthFrequently asked questions
What is the difference between an authorised and a small EMI?
An authorised EMI has no volume ceiling, needs EUR 350,000 initial capital and may provide account information and payment initiation. A small EMI is limited to EUR 5 million average outstanding e-money and EUR 3 million average monthly payment transactions, and cannot provide AIS or PIS.
Can a UK EMI passport into the EU?
No. Since Brexit, UK authorisation gives no EEA access. Firms wanting EU clients need a separate licence in an EU Member State.
What changed on 7 May 2026?
The FCA's new safeguarding rules took effect, requiring daily checks of safeguarded amounts, monthly returns, annual safeguarding audits for firms holding over GBP 100,000 of customer funds, and better failure planning.
How long does FCA authorisation take?
A case officer is allocated within 20 working days. Determination time depends on quality and completeness; the FCA publishes average determination times in its operating service metrics, and well-prepared applications typically take many months.
Is AML registration separate?
EMIs are supervised for AML by the FCA as part of their authorisation, and must comply with the Money Laundering Regulations 2017 from day one.
Can the founders be based outside the UK?
Ownership can be international, but the head office must be in the UK and the FCA expects senior management to direct the business from there.
Last reviewed: 2026-10. Requirements, fees and timelines change. Information is general, reviewed on the date shown, and is not legal or tax advice.