Financial Licensing · UK

UK Payment Institution Licence

A UK FCA-authorised Payment Institution (PI) can provide payment initiation, account information, money remittance, merchant acquiring and other regulated payment services across the UK and beyond.

FCAPayment InstitutionPSR 2017UK PaymentsSafeguarding
Overview

UK Payment Services Regulation

The Payment Services Regulations 2017 (PSR 2017) implement PSD2 in the UK and require FCA authorisation for firms providing payment services commercially. Regulated activities include payment account services, payment initiation, account information, money remittance, and merchant acquiring. The FCA distinguishes between Authorised Payment Institutions (full scope) and Small Payment Institutions (below transaction thresholds).

Marensa Advisory advises on FCA PI authorisation, safeguarding policy design, operational resilience frameworks, and ongoing regulatory reporting — from initial application through to post-authorisation compliance.

Discuss Your PI Application
What We Cover
  • Authorised PI vs Small PI determination
  • Regulatory Business Plan and financial projections
  • Safeguarding policy and account setup
  • AML/CFT programme and Payment Services AML obligations
  • Operational resilience and business continuity framework
  • Compliance Manual aligned with PSR 2017 and FCA guidance
  • FCA Connect application preparation and submission
  • Ongoing REP reporting and incident notification management
Key Considerations

UK PI Licensing — Key Considerations

The FCA scrutinises safeguarding arrangements and AML controls most heavily in PI applications. Getting these right before submitting saves significant time.

Authorised vs Small PI
Small PIs are below defined transaction thresholds and have reduced capital/reporting requirements. Authorised PIs have no transaction limits but must maintain minimum capital of £125,000 and meet full operational requirements.
Safeguarding
PI firms must safeguard customer funds at all times — by segregation in a designated account at a UK credit institution or by an insurance guarantee. Safeguarding failure is the FCA's primary enforcement concern for PSPs.
AML/CFT for Payment Services
PSPs are subject to the Money Laundering Regulations 2017. The FCA scrutinises CDD procedures, transaction monitoring, and correspondent banking relationships — particularly for cross-border remittance businesses.
Open Banking (PSD2 APIs)
PIs providing payment initiation or account information services must interact with UK banks via Open Banking APIs under the Competition and Markets Authority (CMA) Open Banking Order and PSD2 API standards.
Operational Resilience
FCA-authorised PSPs must comply with operational resilience requirements — identifying important business services, setting impact tolerances, and testing resilience to disruption scenarios.
Passporting into EEA
Post-Brexit, UK-authorised PIs do not have automatic EU passporting rights. Serving EEA clients or operating in EEA countries typically requires local licences or establishment in an EU member state.
Our Process

How We Work

01
Category Determination
We determine whether Authorised PI or Small PI is appropriate based on transaction volumes, geographic scope, and planned service lines.
02
Application Preparation
We produce the RBP, financial projections, safeguarding policy, AML/CFT programme, operational resilience framework, and all FCA-required documentation.
03
FCA Submission
We submit the application via FCA Connect, manage all case handler correspondence, and respond to RFIs efficiently.
04
Safeguarding & Banking
We assist with identifying a safeguarding bank and preparing the account opening package — a common practical bottleneck for new PI applicants.
05
Post-Authorisation
We establish your quarterly REP reporting, incident notification procedures, and ongoing AML/CFT review cycle.
Why Marensa

UK Payments. Properly Licensed.

FCA PI applications are frequently delayed by incomplete safeguarding arrangements, weak AML/CFT programmes, or poorly structured business plans. The FCA issues detailed RFIs and expects comprehensive responses.

Marensa Advisory prepares PI applications with the rigour the FCA expects — covering safeguarding, AML, operational resilience and financial projections in a single coherent package.

Start the Conversation
FCA
Regulator
PSR 2017
Framework
£125K
Min Capital (API)
UK+
Market Access
FAQ

Common Questions

Can I provide payment services in the UK without FCA authorisation? +

No. Providing regulated payment services commercially in the UK without FCA authorisation or registration is a criminal offence under the PSR 2017. Small PIs must at minimum register with the FCA.

How long does FCA PI authorisation take? +

Typically 9–15 months from a complete application. The FCA has a 3-month determination period once it deems an application complete, but reaching "complete" status can take several months of back-and-forth.

Do I need a UK PI licence to serve UK customers from abroad? +

If you are providing regulated payment services to UK customers from outside the UK, you may fall within FCA jurisdiction depending on the service type and where the regulated activity is deemed to occur. UK regulatory advice should be sought.

What is the difference between a PI and EMI? +

A Payment Institution can provide payment services but cannot issue electronic money (store value). An Electronic Money Institution (EMI) can do both. If your product involves prepaid wallets or stored value, you likely need EMI authorisation, not PI.

Related Services

You May Also Need

UK EMI Licence
Electronic Money Institution authorisation — for products involving stored value.
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FCA Authorisation Overview
Full-scope FCA authorisation for UK investment and payment firms.
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AML/CFT Compliance Framework
AML/CFT programme design for UK-regulated payment services businesses.
Learn more →
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