Financial Licensing · UK

UK EMI Licence

An FCA-authorised Electronic Money Institution (EMI) can issue electronic money, operate prepaid wallets, and provide payment services — combining the broadest fintech product scope available in the UK under a single regulatory licence.

EMIFCAE-moneyUK FintechSafeguardingPayment Services
Overview

Why an EMI Licence?

Electronic money institutions are authorised under the Electronic Money Regulations 2011 (EMRs) to issue electronic money — storing monetary value electronically for payment purposes. This enables prepaid cards, digital wallets, stored-value accounts, and e-money products. An EMI can also provide the full range of payment services, making it the most versatile fintech licence in the UK.

Marensa Advisory advises on FCA EMI authorisation, e-money product structuring, safeguarding framework design, and ongoing compliance — from initial scoping through to authorisation and beyond.

Discuss Your EMI Application
What We Cover
  • Authorised EMI vs Small EMI determination
  • Regulatory Business Plan and e-money product description
  • Safeguarding policy: segregation or insurance model
  • AML/CFT programme including transaction monitoring
  • Capital calculation: minimum £350,000 plus 2% of outstanding e-money
  • Compliance Manual and SM&CR controlled function setup
  • FCA Connect application preparation and submission
  • Ongoing GABRIEL reporting and safeguarding audits
Key Considerations

EMI Licensing — What the FCA Expects

EMI applications are scrutinised heavily on safeguarding arrangements, AML/CFT controls, and financial sustainability. These are the areas where most applications face delays.

E-money Issuance Scope
An EMI can issue e-money (store monetary value) and provide all eight categories of payment services under the PSR 2017. This covers digital wallets, prepaid cards, money remittance, payment initiation, and account information services.
Minimum Capital
Authorised EMIs must hold minimum capital of £350,000 plus a method-specific additional requirement based on outstanding e-money and payment volumes. Capital must be in liquid, unrestricted form at all times.
Safeguarding Requirements
EMIs must safeguard all funds received in exchange for e-money issued. Safeguarding can be by segregation (separate bank account for client funds) or by an insurance or guarantee. The FCA inspects safeguarding arrangements carefully.
AML/CFT for E-money
The Money Laundering Regulations 2017 apply to EMIs. The FCA expects a risk-based CDD framework, transaction monitoring with thresholds proportionate to e-money use cases, and clear STR/SAR procedures.
Redemption Rights
E-money holders have a legal right to redeem at par at any time. EMIs must maintain sufficient liquid assets to meet redemption demands — a key prudential risk the FCA assesses during authorisation.
Technology and Resilience
FCA expects EMIs to have an operational resilience framework, IT security policy, and business continuity plan. For e-money platforms serving significant customer volumes, third-party risk management is also scrutinised.
Our Process

How We Work

01
Product & Scope Definition
We map your e-money product and payment services to the EMR/PSR regulatory categories and confirm the correct authorisation type.
02
Application Preparation
We produce all FCA-required documentation: RBP, e-money product description, safeguarding policy, AML/CFT programme, capital calculation, and compliance framework.
03
FCA Submission & Liaison
We submit via FCA Connect, manage all case handler correspondence, and prepare for any FCA requests for clarification or interviews.
04
Safeguarding & Banking
We assist with identifying and onboarding a safeguarding bank — a practical challenge for new EMIs that we have navigated for multiple clients.
05
Post-Authorisation
We set up your GABRIEL reporting, safeguarding audit arrangements, SM&CR certification cycle, and ongoing compliance calendar.
Why Marensa

UK E-money. Built to Last.

EMI applications have a high rate of delay due to incomplete safeguarding arrangements, insufficient capital demonstration, or weak AML/CFT programmes. Each deficiency triggers an RFI cycle adding months to the process.

Marensa Advisory prepares EMI applications with the rigour the FCA expects — producing internally consistent, complete documentation packages that minimise the risk of time-consuming RFIs.

Start the Conversation
FCA
Regulator
EMR 2011
Framework
£350K
Min Capital
UK+
Market Access
FAQ

Common Questions

What is the difference between an EMI and a bank? +

An EMI issues e-money and provides payment services but cannot lend, take deposits (as defined under FSMA), or engage in credit activity. A bank can do all of these. For most fintech wallet and payment use cases, EMI authorisation is the appropriate licence.

Can an EMI passport into the EU post-Brexit? +

UK EMIs lost EU passporting rights after Brexit. To serve EU customers or operate in EU countries, UK EMIs typically establish an EU subsidiary (often in Lithuania, Ireland, or another EU member state) authorised as an EU EMI.

How long does FCA EMI authorisation take? +

Typically 12–18 months from initial submission. The FCA has significant application volumes. A complete, high-quality application — particularly around safeguarding — significantly improves processing speed.

Do I need an EMI licence to offer a prepaid card product? +

Yes. If you are issuing prepaid cards that store monetary value (e-money), you need EMI authorisation. If you are distributing prepaid products issued by a third-party EMI, you may be able to operate as an agent of that EMI — subject to FCA agent registration.

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UK Payment Institution Licence
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FCA Authorisation Overview
Full-scope FCA authorisation including investment and fund management.
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Malta MiCA Readiness
EU crypto asset regulation preparation — relevant for EMI-adjacent businesses.
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