How to Get an FCA EMI Licence in the UK in 2026

An FCA EMI licence lets a UK company issue electronic money, run wallets, prepaid cards and payment accounts, and provide payment services across the UK. The Financial Conduct Authority grants it under the Electronic Money Regulations 2011, and it has no expiry date once granted.

Winning it takes real preparation. The FCA wants €350,000 of initial capital, a head office in the UK, managers who pass its fit and proper test and safeguarding that protects every customer pound. It must decide within 3 months of a complete file, yet the median payment and e-money case closed in early 2026 took 207 days. Banks are the other hurdle, as many are wary of payment firms.

This is where we come in. We form your UK company, build the application file with you and set up customer KYC and AML screening on our own compliance platform. Then we open an operating account with our fintech banking partners. One team handles all of it.

FCA EMI Licence at a Glance

An FCA EMI licence costs £5,640 to apply for in 2026, or £1,130 for a small EMI. You need €350,000 of initial capital, and the FCA must decide within 3 months of receiving a complete application.

Fees checked against the FCA's e-money and payment institution application fees page (updated 13 July 2026) and the Electronic Money Regulations 2011 on legislation.gov.uk on 22 September 2026.

Why Get an EMI Licence in the UK

Firms want the EMI licence the UK grants because it lets them issue e-money in their own name, keep control of the product, deal with a regulator bound by a legal clock and earn trust with banks, card schemes and investors.

E-Money and Payment Services Under One Authorisation

An authorised EMI can issue e-money, provide payment services linked to it and also provide payment services that are not linked to e-money, such as money remittance. The regulations also let it run other business alongside. A digital wallet, a prepaid card programme and a cross-border payments app can all sit under one authorisation.

Control of Your Product and Your Margins

With your own licence you set the product list, choose your suppliers and keep the interchange and foreign exchange margin that a sponsor would share. You also decide how customer funds are safeguarded. For a firm building a digital wallet in the UK, that control is often the reason to apply.

A Regulator Bound by a Legal Clock

Regulation 9 of the EMRs gives the FCA three months to decide a complete application and twelve months for an incomplete one. If it plans to refuse, it must send a warning notice first, and you can take a refusal to the Upper Tribunal. Few regulators give applicants that much certainty.

Credibility With Banks, Schemes and Investors

Every authorised EMI appears on the FCA's public register, and partners check it in due diligence. An authorised firm can also apply to the Bank of England for a settlement account, which opens the route to direct access to UK payment systems rather than relying on another firm.

A Route Open to Overseas Groups

Since Brexit, regulation 6 allows either a UK company or a UK branch of a company based abroad to apply, as long as part of the business is carried on in the UK. Most groups still form a UK subsidiary. Read more: the benefits of setting up a company in the UK.

Where an FCA EMI Licence Lets You Operate

The EMI licence the UK grants covers England, Wales, Scotland and Northern Ireland, but it stops at the border. UK passporting rights into the EU ended with the Brexit transition period on 31 December 2020, so EU customers need an EU licence.

Many UK firms hold a second licence in the EU to keep EU customers. See our guide to getting an EMI licence in Europe.

UK EMI Licence Types

There are two forms of EMI licence. UK firms choose between full authorisation and small EMI registration. The fees below come from the FCA's application fee categories, and the annual periodic fee is set each year by fee block.

Every application fee is paid by card on FCA Connect when you submit, and it is not refundable.

Who Needs an Electronic Money Institution Licence in the UK

You need an electronic money institution licence in the UK when customers load money that you store as a balance they can spend or send later. Wallets, prepaid and gift cards, multi-currency accounts and marketplace balances usually count. Card-based stored value and remittance services often do too. A business that only moves money without holding a balance may need a payment institution licence instead.

Authorised EMI

An authorised EMI has no cap on e-money outstanding or payment volumes. It must hold €350,000 of initial capital before authorisation and keep own funds at or above the higher of €350,000 and its own funds requirement. The authorised EMI route suits wallets, card programmes and account providers that plan to grow.

Small EMI Licence

This is a registration rather than full authorisation, for firms whose average outstanding e-money stays at or below €5 million. Payment services not linked to e-money must stay at or below a monthly average of €3 million, and account information and payment initiation services are not allowed. There is no initial capital until outstanding e-money reaches €500,000. From that point, the small EMI licence holder keeps capital of 2% of it.

Adding Payment Services to an EMI

An EMI can apply to vary its permission to add payment services later. The fee is half of category 3 or 4, so £565 or £1,410. Plan the full scope at the start if you can, because every variation is another review.

EMI or Payment Institution

The difference is stored value. An EMI can issue e-money that customers hold, while a payment institution only moves funds for a payment. An authorised payment institution needs less capital: €20,000, €50,000 or €125,000 depending on its services. See how to get an FCA payment institution licence.

Own Licence, Agent or Partner Route

Not every business needs its own EMI licence. UK firms can also launch as an agent or through a partner, depending on how fast they need to go, how much control they want and whether they can hold €350,000 of capital. The table compares the FCA fees in year one and what each route still needs.

The partner routes cost less at the start, but you pay for them in revenue share and in control.

When Your Own Licence Is the Right Route

Choose full authorisation or a small EMI licence when customer balances are the heart of the product, when you want several banks and schemes, and when you can fund €350,000 of capital. You carry the full cost and the full compliance team, but no sponsor can change your terms or close your programme.

When an Agent or Sponsor Is the Better Start

Under regulation 33, an EMI may distribute or redeem e-money through a distributor or agent, but it cannot issue e-money through them. An agent that provides payment services must be on the FCA register before it starts. The principal EMI stays responsible for you, so it sets the rules. Many fintech start-ups in the UK begin this way and apply later.

When Banking as a Service or BIN Sponsorship Fits

A banking as a service provider lets you offer accounts and payments under its licence through APIs. A BIN sponsor lets you issue cards on Visa or Mastercard without joining the scheme yourself. Both are fast, but you depend on the provider's appetite, and a change in its strategy can end your programme.

When Buying an Existing EMI Makes Sense

Buying a company that already holds authorisation can save the application, but not the checks. Every new controller must be approved by the FCA before the deal completes, and you inherit the firm's history and any safeguarding gaps.

FCA EMI Licence Requirements

Regulation 6 of the EMRs sets the conditions for authorisation. The FCA can refuse only if one is not met, so the file must show each one clearly: the company, capital, governance, fit and proper people, a business plan and safeguarding. These EMI licence requirements apply to every applicant, whatever its size or home country.

A UK Company or a UK Branch

The applicant must be a body corporate with its head office in the UK, and its registered office too if it has one. A company based abroad can apply through a UK branch instead. Either way, at least part of the e-money business must be carried on in the UK. Most founders start with a UK private limited company. Our UK company registration guide explains the filing.

Directors, Controllers and Key Persons

Directors and people responsible for managing the e-money business must be of good repute and have the knowledge and experience to run it. Each one completes an individual form, and anyone with a qualifying holding of 10% or more must be fit and proper. The FCA traces every ultimate beneficial owner in the chain. You also appoint an MLRO, usually a senior person who works in the business.

Office, Systems and Outsourcing

The FCA expects the people who run the firm to make decisions in the UK, not to approve work done elsewhere. Outsourcing is allowed, but you keep control of anything outsourced and show how you oversee it. The operational resilience rules also apply, so you map your important business services and set impact tolerances for them.

Initial Capital and Own Funds

An authorised EMI must hold €350,000 of initial capital immediately before authorisation, made up of paid-up shares, share premium, retained earnings and similar items. After that, own funds must never fall below the higher of €350,000 and the own funds requirement. For e-money that requirement is 2% of average outstanding e-money, and the FCA can move it up or down by up to 20%.

Safeguarding Customer Funds

Funds received for e-money must be kept apart from the firm's own money. If they are still held at the end of the next business day, they go into a separate account with an authorised credit institution or the Bank of England, or into secure, liquid, low-risk assets held by an authorised custodian. The other method is an insurance policy or a comparable guarantee. Funds paid by card must be safeguarded once they reach the EMI, and no later than five business days after the e-money is issued.

Fit and Proper People and a Clean Record

People with a conviction for money laundering, terrorist financing or another financial crime will not pass. The FCA also looks at regulatory history, solvency and honesty in the form itself. A past problem disclosed and explained is far safer than one the FCA finds on its own.

AML and KYC Setup

An EMI falls under the Money Laundering Regulations 2017, and the FCA is its AML supervisor. You need a firm-wide risk assessment, a customer due diligence policy with enhanced checks, sanctions and PEP screening, transaction monitoring and a process for reporting suspicions to the National Crime Agency. We set up customer KYC, screening and ongoing monitoring on our own compliance platform, so the controls in your file are already running.

Can a Foreign Owner Apply and Run It Remotely?

Yes, owners anywhere can hold an EMI licence. UK rules look at where the business is run, not where the owners live, so the owners can stay abroad but the business cannot be run from there. Every controller is checked, and the head office must be in the UK with senior people there who genuinely run it. See UK company formation for non-residents.

Before You Apply for an FCA EMI Licence

The FCA's application form mirrors the EMI licence requirements in regulation 6, and the three month clock only starts on a complete file. Settle these points before you pay the fee.

• Scope: Every e-money product and payment service listed as the regulations describe it.
• Authorised or small: Your forecast e-money outstanding and payment volumes against the €5 million and €3 million limits.
• Business plan: A realistic plan with a forecast budget for the first three years.
• Capital: €350,000 paid in, with evidence of where it came from.
• Safeguarding: The method chosen, the account or insurer lined up and a daily reconciliation process.
• Governance: A board, clear lines of responsibility and a compliance function with direct access to it.
• Individual forms: One for each director and each person managing the e-money business.
• Controllers: Every qualifying holding of 10% or more, with source of wealth for each.
• AML framework: Risk assessment, policies, screening and a named MLRO.
• Outsourcing and IT: Contracts, a security policy and an incident process for every critical supplier.
• Wind-down plan: How customers get their money back if the firm fails.
• Auditor: A statutory auditor ready to accept the appointment.

Two items matter most in an FCA EMI application: the capital must be real and traceable, and the forecasts must match the business plan line for line.

How to Get an EMI Licence in the UK

If you are working out how to get an EMI licence, follow the FCA's real stages, from first contact to the register. We run the company side ourselves and build the file with you, so each stage starts on time.

Pre-Application Contact With the FCA

The FCA offers pre-application support to some firms that are new to regulation, and it decides who gets a meeting. It will not draft the file or give legal advice, but it can point out issues early. Use the time to test your scope and your safeguarding model.

Form the UK Company and Appoint the Board

We form the UK private limited company, usually within a day of a clean online filing, and agree the board, the MLRO and the compliance lead with you. Any founder can set up a limited company in the UK, but an e-money firm also needs people the FCA will accept.

Build the File and the Forecasts

The file covers the business plan, three years of forecasts, the capital calculation, safeguarding, governance, the AML framework, IT security, outsourcing and the wind-down plan. Every document must tell the same story, with the same numbers.

Submit the FCA EMI Application on Connect

The FCA EMI application goes in through FCA Connect with the £5,640 fee, or £1,130 for a small EMI, paid by card. Individual forms and controller forms go in at the same time.

Completeness Check and Case Officer Questions

A case officer checks whether the FCA EMI application is complete and then works through it. Expect written questions on the business model, capital, safeguarding and people. Slow or partial answers are the main reason cases run long.

Warning Notice or Decision

If the FCA is satisfied, it grants authorisation and states the date it takes effect. If it proposes to refuse, it sends a warning notice, considers your response and then issues a decision notice. You can withdraw at any time before the decision, and many weak applications end that way.

Authorisation and the FCA Register

An electronic money institution licence in the UK takes effect on the date in the FCA's notice. The FCA adds the firm to its register as soon as practicable. From the effective date you can issue e-money within the permission you were granted, and partners can check your status online.

Launch With Safeguarding Live

Before the first customer pound arrives, the safeguarding account or insurance must be in place and daily reconciliations running. The first monthly safeguarding return is due within 15 business days of the end of your first month.

Documents Needed for an FCA EMI Application

Every application is judged on its documents. Each one must be consistent with the others, and the plan and forecasts must match the capital and safeguarding sections. This is the pack we build with you.

• Company: Certificate of incorporation, articles of association, group structure chart and board minutes approving the application.
• People: Individual forms, ID, proof of address, CVs, references and details of other directorships for each key person.
• Business plan and financials: The regulatory business plan, three-year forecasts, the capital and own funds calculation and evidence of funds.
• Policies: Safeguarding policy and procedures, AML and financial crime policies, the risk framework, the compliance monitoring plan and complaints handling.
• Technical: IT architecture, the security policy, incident management, business continuity, outsourcing contracts and the wind-down plan.

Company and Ownership Papers

The FCA needs a chart of every company, trust or vehicle up to the ultimate owners, with holdings and voting rights. Controllers of 10% or more complete controller forms, and corporate controllers add their accounts. Nominee holdings are disclosed with the arrangement behind them.

Business Plan and Financial Forecasts

The plan explains the products, the customers, the revenue model, the markets, the payment flows and the partners. The forecasts run for three years and show capital, own funds and safeguarded balances each month. The FCA tests the assumptions, so explain each one.

Personal Documents for Each Key Person

Each director, manager, compliance officer and MLRO provides identity and address evidence, a full CV and details of any regulatory, civil or criminal history. The FCA uses these to assess good repute and experience, and it may interview the people who will run the firm.

EMI Licence Cost in 2026

The EMI licence cost starts with £5,640 in FCA fees for full authorisation, or £1,130 for a small EMI, but capital and people drive the real budget. We form the company from €350, covering structure advice, the name check, the articles, the filing and a bank-ready file. The licence work is quoted separately.

The rest of year one depends on your model and your team.

FCA fees are fixed and public. The planning ranges are our working estimates based on typical projects, not published fees, and your written quote sets the final numbers. Salaries for the MLRO, compliance and finance staff usually decide where you land.

Capital Is Held, Not Spent

The €350,000 stays in the company as own funds, so it is a use of cash rather than a cost. It must be there immediately before authorisation and stay in the business as own funds afterwards. As e-money grows, the 2% requirement can push own funds above €350,000.

First-Year Cost by Model

The EMI licence cost differs most between models in capital and people, not in FCA fees.

Read more: the cost of setting up a UK company for the company alone.

How Long FCA EMI Authorisation Takes

By law, FCA EMI authorisation must be decided within 3 months of a complete application and within 12 months of an incomplete one. In practice, the FCA's own data shows most payment and e-money cases take far longer than 3 months.

In January to March 2026, the FCA closed 44 payment and e-money authorisation and registration cases. The median case took 207 days, and 12 cases missed its new 3 or 10 month target.

What Slows an Application Down

Missing documents, forecasts that do not match the plan, unclear safeguarding, a complex ownership chain and changes to the model mid-review are the usual causes. Each round of questions pushes back your launch, and a file the FCA treats as incomplete falls under the 12 month limit rather than the 3 month one.

From Filing to First Revenue

Plan on 6 to 12 months from filing to first revenue for an authorised EMI, and longer if the model is new. Treat FCA EMI authorisation as one milestone in the launch plan, not the finish line. Firms that start as an agent of another EMI can trade during the review and move customers across once authorised.

After the FCA EMI Licence Is Granted

Authorisation brings a fixed calendar from day one: daily reconciliations, monthly safeguarding returns, regular prudential reports, yearly audits and prior approval for key changes.

Go-Live Conditions

Before launch, the safeguarding arrangements must be live, the AML controls running and the customer terms final. The Consumer Duty applies to e-money firms, so products, prices and support must deliver good outcomes for retail customers.

Returns, Safeguarding Audits and Reporting

Since 7 May 2026, the FCA's CASS 15 rules require internal and external safeguarding reconciliations every reconciliation day. Every EMI files a monthly safeguarding return within 15 business days of the month end. Where an annual safeguarding audit is required, the first is due within 6 months of the audit period end and later ones within 4 months. You also keep a resolution pack so customers can be repaid quickly if the firm fails.

No Renewal, but Ongoing Supervision

There is no renewal date on an EMI licence. The UK regime relies on supervision instead: the FCA works through returns, periodic fees and reviews, and it can vary or cancel the permission if you stop meeting the conditions.

Key Person Changes

New directors and managers of the e-money business are assessed before they start. Tell the FCA promptly about material changes to the business, the people or the safeguarding arrangements.

Change of Control and EMI Licences for Sale

Anyone who plans to acquire or increase a qualifying holding must notify the FCA and get approval before completing. Authorisation belongs to the company, so an advert selling an EMI licence is really selling a company, and the buyer still faces the FCA's checks.

The FCA Register

Your firm appears on the FCA's public register with its permissions and any agents. Customers, banks and schemes check it, and so should you when you choose a partner.

Banking for a Licensed UK EMI

Winning the EMI licence the UK regulator grants does not open a bank account by itself, and banking is where many new EMIs stall. The firm needs two things: a safeguarding account for customer funds at an authorised credit institution, and an operating account for its own money. Under the FCA rules, safeguarded funds must sit with a bank or the Bank of England, be invested in secure assets held by a custodian, or be covered by an insurer or guarantor.

Why Banks Are Cautious With EMIs

Banks see financial crime risk, customers in many countries and heavy reporting duties, and some limit how many payment firms they take on. A refusal also makes the next application harder. Our guide to business bank accounts versus EMI accounts explains the difference.

Safeguarding Accounts and Operating Accounts

The safeguarding account must be designated as one and used only for customer funds. Your fees, payroll and supplier payments run through a separate operating account. Read what an EMI account is if these accounts are new to you, and our UK business bank account guide.

A UK bank is still where most EMIs keep safeguarded funds. Our partners win on speed, on owners abroad and on currency costs for the firm's own money. See the best business bank accounts in the UK.

Opening the Operating Account With Our Partners

We build the bank file from the same pack as the licence: company papers, the owners' KYC, the business plan and the payment flows. The account can open while FCA EMI authorisation is pending. Read how to open a UK business bank account and our guide to banking for fintech and EMI companies.

Our fintech banking partners open multi-currency business bank accounts for UK fintech and payment companies in days, with no minimum balance.

Why FCA EMI Applications Get Refused

Few applicants are formally refused an EMI licence. The UK regulator usually sees weak files withdrawn after rounds of questions, and its quarterly service metrics show how long cases take rather than an approval rate. These are the reasons files fail.

A Weak or Unclear Business Plan

A plan that does not explain the products, the customers, the payment flows and the revenue model draws long questions. The FCA wants detail it can test, not a pitch deck.

Safeguarding That Does Not Work

No safeguarding account, unclear reconciliations or a policy that does not match the flows is a common reason for delay. With CASS 15 in force since May 2026, the FCA expects the daily process to be designed before launch.

Forecasts and Capital That Do Not Add Up

Unrealistic revenue, underestimated costs and capital with no clear source all stop a file. The FCA reviews funding, liquidity and shareholder support, and it checks that own funds stay above the requirement in every month of the forecast.

People Without the Right Experience

Directors, compliance officers and MLROs without payments, compliance or risk experience weaken the case. A part-time MLRO with no real role raises the same concern.

Weak AML Controls or Unclear Outsourcing

Generic AML policies, no transaction monitoring and outsourcing contracts with no oversight suggest the firm cannot control its own risks. Controls must match the risk profile and work in practice.

A Head Office That Is Not Really in the UK

A UK company run by people and systems abroad fails the head office condition. The FCA looks at where the board meets, where decisions are taken and who does the work.

UK vs Malta, Cyprus and Ireland for an EMI Licence

Firms that need EU customers usually weigh the UK against Malta, Cyprus and Ireland. All three are EU members with the same €350,000 capital floor, so the real differences are market access, tax and the regulator's style.

An EU licence can be passported and the EMI licence the UK grants cannot, so the choice follows your customers. The UK wins on its home market and its legal clock.

UK vs Malta

The MFSA licenses EMIs under the Financial Institutions Act, and a Maltese EMI can passport across the EU. Malta's 35% headline tax falls sharply after shareholder refunds. See how to set up an electronic money institution in Malta. We form Malta companies from €1,299.

UK vs Cyprus

The Central Bank of Cyprus supervises EMIs under the Electronic Money Law of 2012, with the same €350,000 floor. Cyprus suits firms that want an EU base with lower running costs than London. See how to set up an electronic money institution in Cyprus.

UK vs Ireland

The Central Bank of Ireland authorises EMIs, and many large payment firms moved their EU base to Dublin after Brexit. Ireland is English speaking and has a 12.5% rate on trading income, but the Central Bank sets high expectations for substance. See EMI licence and payment company setup in Ireland. We form Irish companies from €1,899.

Who an FCA EMI Licence Is Wrong For

An FCA EMI licence is a poor fit for a start-up that cannot fund €350,000 of capital and a compliance team. For a first product, an agent role with an established EMI or a small EMI registration is often the better step.

It also does not suit a firm whose customers are mostly in the EU, because a UK firm cannot passport its EMI licence. The UK market alone has to justify the cost. Before deciding how to get an EMI licence, check whether you need one at all. A business that only moves money without holding balances may need a payment institution licence instead. One that wants to lend or take deposits needs a different permission, or a full banking licence if it plans to set up a neobank in the UK.

Common Mistakes When Applying for an FCA EMI Licence

These mistakes delay an EMI licence more than anything else, and each one is avoidable with a well-planned file.

Choosing the Wrong Permission

Applying as a small EMI and outgrowing it in year one, or applying for e-money when a payment institution licence would do, wastes months. Map your flows first. Firms that set up a payment processing company in the UK often need only payment services.

Treating Safeguarding as a Policy, Not a Process

A safeguarding policy with no account, no reconciliation tool and no named owner will not pass. Build the daily process first and write the policy around it.

Hiring an MLRO in Name Only

The FCA wants an MLRO who knows the business and has time for the role. A name borrowed from another firm is a quick way to raise concerns about the whole governance model.

Filing Before the Capital Is Ready

The €350,000 must be in place immediately before authorisation, and the FCA asks where it came from. Late or untraceable capital delays the decision even when the rest of the file is strong.

Bottom Line

The EMI licence the UK offers lets you issue e-money and run payment services under your own name, with no expiry date and a regulator bound by a 3 month deadline for complete files. It costs £5,640 to apply for full authorisation and needs €350,000 of capital.

Knowing how to get an EMI licence is mostly about preparation: a UK company with a real head office, the right people, traceable capital, working safeguarding and a complete file. We form the company from €350, build the file with you, set up KYC and AML on our platform and open the operating account with our fintech banking partners. If crypto is part of the plan, see how to register a crypto business with the FCA.