Bank licences compared

It depends on the country. In the EU the legal minimum for a credit institution is €5 million, and Lithuania offers a specialised bank from €1 million. Luxembourg asks for €8.7 million paid up, Switzerland CHF 10 million, and in the UK a small specialist bank may start at the higher of €1 million and £1 million.

Among the markets on this page, Lithuania, with €1 million for a specialised bank that can passport across the EEA. Switzerland’s fintech licence allows public deposits up to CHF 100 million with capital of 3% of deposits and at least CHF 300,000, but it does not allow lending of those deposits.

In the UK and the EU the law sets six months from a complete application and twelve months at most. In practice pre-application work adds several months before that clock starts. In the US a new bank must open within 18 months of the OCC’s preliminary approval.

No. An e-money institution safeguards customer funds and may not lend them or pay interest. A bank accepts deposits, lends them and is covered by deposit protection.

The FCA must decide within three months of a complete application; its published median is 219 days, so plan for six to eight months after submission.

It is 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.

Before anything is drafted we advise on whether this is the right authorisation for the business, or whether another route would serve it better.

Seven to ten months from instruction to licence for a prepared applicant, most of it the FCA’s assessment.

1. Confirm the route1 to 2 weeks. Map the product to e-money issuance and the payment services in Schedule 1 to the Payment Services Regulations 2017, choose between an authorised and a small EMI, and fix the fee category (£5,640, category 5) and the capital method.
2. Request a pre-application meeting2 to 6 weeks, optional. The FCA’s Pre-Application Support Service is free. The request, made through Connect, sets out the proposed application and the questions to discuss, and a case officer outlines the FCA’s expectations.
3. Appoint the people4 to 8 weeks, in parallel. Directors and managers of good repute with payments experience, a compliance officer and a money laundering reporting officer (MLRO), the nominated officer the Money Laundering Regulations 2017 require.
4. Write the business plan and policies6 to 10 weeks. Programme of operations, flow of funds, three-year forecasts with two stress scenarios, the wind-down plan, and policies written for the business: anti-money laundering, safeguarding, outsourcing, operational resilience and complaints.
5. Arrange the capital and the safeguarding account6 to 12 weeks, in parallel. €350,000 of initial capital paid in and evidenced, and a safeguarding account with an authorised credit institution, with the acknowledgement letter CASS 15 requires.
6. Answer the case officer3 to 12 months. The FCA must decide within 3 months of a complete application and 12 months of an incomplete one. Its median in April to June 2026 was 219 days.
7. Go liveFirst 30 days. Daily safeguarding reconciliations, the monthly safeguarding return, the first periodic fee charged pro rata to the months left in the fee year, and the plan for the annual safeguarding audit.

• Issue and redeem at par. E-money is issued at par value, without delay, on receipt of funds, and the holder may redeem it at par value at any time (regulation 39).
• No interest. An issuer may not award interest, or any other benefit linked to how long the holder keeps the e-money (regulation 45). Product rewards tied to balances held over time fall within the ban.
• Ancillary services. Alongside e-money and payment services, an EMI may provide operational and closely related ancillary services, including foreign exchange services, safekeeping and data processing, and may operate payment systems (regulation 32).
• Excluded products. Value usable only within a limited network, such as a store card accepted only at one retailer’s outlets, and certain payments through electronic communications networks fall outside the regime. A business relying on the limited network exclusion notifies the FCA once its transactions pass €1 million in any 12 months; the FCA charges a pricing category 1 fee of £280 for each exclusion notification.

Before committing €350,000 of capital, test the business against the three points the FCA checks first.

1. The fee and the minimum information. Can you pay the correct fee and answer every question on the form today? An application with the wrong fee or missing minimum information is rejected without assessment, and the applicant starts again.
2. Policies written for your business. Can your policies describe your own products, customers, flows and controls, rather than a template? The FCA treats generic policies as an incomplete application.
3. A flow of funds a case officer can follow. Can you show, account by account, where customer money is received, held, safeguarded and paid out each day? An unclear flow of funds stops the clock while the FCA asks.

If the answer to any of the three is no, or the capital, the MLRO and the safeguarding bank are not yet in place, one of the alternatives below is usually the faster route to market.

An EMI licence is the right answer for a business that will hold customer balances at scale. Four other routes reach the market sooner or at lower cost.

• Become an agent of an existing EMI or payment institution. An agent provides payment services, or distributes and redeems e-money, under the principal’s licence once the principal registers it with the FCA. An EMI may not issue e-money through an agent (Electronic Money Regulations 2011, regulation 33). The FCA closed all 1,652 agent notifications it received in April to June 2026 within its two-month standard.
• Distribute e-money for an EMI. A distributor sells or redeems the EMI’s e-money, for example on a prepaid card programme, without a licence of its own. The EMI remains the issuer and remains responsible for safeguarding.
• Start with an EU licence. Where the first customers are in the European Economic Area, an EU EMI licence, for example in Ireland or Lithuania, comes first. It does not permit UK business, which still needs FCA authorisation.

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.

The two routes are not convertible. A small EMI that wants to become authorised, or an authorised EMI that wants to register instead, submits a new application rather than a variation of its permission, and the FCA rejects an application made on the wrong form.

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.

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

Schedule 1 to the Electronic Money Regulations 2011 sets the information the application must contain. The FCA rejects without assessment any submission that lacks its minimum information or the correct fee.

Programme of operations

Each e-money and payment service envisaged

Business plan

A forecast budget for the first three financial years, showing the systems, resources and procedures to operate soundly

Evidence of initial capital

The €350,000 held for authorisation

Safeguarding measures

How e-money holders’ and payment service users’ funds are protected under regulation 20

Governance and internal control

Administrative, risk management and accounting procedures

Incident and complaints procedure

How security incidents and security-related complaints are handled and reported

Sensitive payment data

How access to sensitive payment data is filed, monitored, tracked and restricted

Business continuity

Critical operations, contingency plans and how they are tested

Statistical data

The principles used to collect data on performance, transactions and fraud

Individuals and controllers forms

An EMD Individual form for each director and manager, and the controller forms

The main contact named on the application must be an individual at the applicant firm, not a third-party adviser, and the policies must be written for the applicant’s own business rather than taken from templates.

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.

Safeguarding reconciliations

At least once each reconciliation day (CASS 15.8.19)

Monthly safeguarding return

Within 15 business days of each month end (SUP 16.14A.3)

EMI annual return (FIN060)

Annually, within 30 business days of the accounting reference date

Payments fraud report (REP017)

Twice a year for authorised firms, annually for small payment institutions and small EMIs; within 2 months of the end of each period (30 June and 31 December)

Operational and security risk report (REP018)

At least once each calendar year, and no more than once a quarter

Complaints return

New consolidated return from the reporting period 1 January to 30 June 2027, first submitted from 1 July 2027 (PS25/19)

Safeguarding audit

Annually, unless exempt

Notifications

Advance notice of changes to name, directors and managers, controllers, agents, distributors and material outsourcing

Anyone acquiring control of an EMI needs FCA approval before completion, so an EMI can be sold to a buyer the FCA assesses as fit and proper.

HM Treasury consulted for 12 weeks, closing on 6 October 2026, on modernising payment services and e-money regulation. It proposes moving detailed requirements from the Payment Services Regulations and the Electronic Money Regulations into the FCA Handbook, restructuring the list of payment activities, and asks whether senior managers of payment and e-money institutions should carry enhanced accountability. Any changes will be made by secondary legislation, with implementation details to follow the consultation; until then applications are made and assessed under the current regulations.

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.

1. Scoping. 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.

You will need directors with payments experience, a compliance officer, a senior manager to run the e-money and payment services, and an MLRO.

• Dzing Finance, Electronic money institution · FCA: EMI licence granted by the FCA.
• Hryze Finance, Electronic money institution · FCA: EMI licence granted by the FCA.
• EuroPanPay, Electronic money institution · FCA: EMI licence approved for operations across the UK and Europe.