What is the minimum capital for a UK EMI licence?

The minimum initial capital for an Authorised Electronic Money Institution is €350,000. EMIs must also maintain ongoing own funds calculated as the higher of the initial capital requirement and 2% of the average outstanding electronic money issued.

What is the difference between an EMI and a bank?

An EMI can issue electronic money and provide payment services. A bank, or credit institution, can take deposits and lend on its own account, in addition to providing payment services. EMIs cannot take deposits or lend customer funds; client money must be safeguarded at all times under CASS 15. The EMI regime is governed by the Electronic Money Regulations 2011, while banks are authorised under the Financial Services and Markets Act 2000.

Can an EMI lend money or hold customer deposits?

No. Lending on its own account and taking deposits are activities reserved for authorised credit institutions, or banks. An EMI must safeguard all customer funds and may not commingle them with its own balance sheet.

What is the difference between an EMI and a payment institution (API)?

An EMI can issue electronic money, including prepaid cards, e-wallets, and stored value accounts, in addition to providing payment services. An API can provide payment services only. EMIs have a higher minimum capital requirement of €350,000 compared to £20,000 to £125,000 for APIs, and are governed by the Electronic Money Regulations 2011 rather than the Payment Services Regulations 2017.

What is the difference between an Authorised EMI and a Small EMI?

An Authorised EMI is FCA-authorised, has no limit on outstanding electronic money, must hold €350,000 in initial capital, and could passport into the EEA pre-Brexit. A Small EMI is FCA-registered, limited to €5 million in outstanding electronic money on average over six months, requires no minimum initial capital, and cannot passport.

Can a UK EMI licence be passported into the EU?

No, following Brexit. Firms wishing to issue electronic money or provide payment services in EEA member states require a separate EU EMI licence in an EEA jurisdiction. We support clients on EU EMI applications across Ireland, Lithuania, the Netherlands, and other jurisdictions.

UK Electronic Money Institution
(EMI) Licence

Authorisation support for firms seeking an Electronic Money Institution licence.

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Clients we have helped

Why Electronic Money Institutions (EMIs) work with us

Specialist focus

We advise payment and e-money firms on UK and European authorisation, compliance and regulator engagement.

Experience since 2013

We have supported applicant and regulated firms across Electronic Money Institution, Small EMI and Payment Institution authorisation projects for over a decade.

Senior-led support

Your matter is handled by experienced regulatory specialists, from initial strategy through to submission and regulator engagement.

Download our FCA EMI licence guide, covering application requirements, safeguarding, governance, financial crime controls, regulatory evidence and common issues raised during assessment.

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FCA EMI licence guide

Frequently asked questions regarding UK EMI licence

Specialists in FCA e-money authorisation since 2013

Every engagement is led at director level. You work directly with the senior practitioners preparing your application, not a delegated team. Buckingham Capital Consulting has focused on FCA payments and e-money authorisations since 2013, with proven outcomes across e-wallet issuers, prepaid card programmes, virtual IBAN platforms, Banking-as-a-Service providers, foreign exchange firms, and money remittance operators. Our consultants combine technical command of the Electronic Money Regulations 2011 with direct insight into the FCA's review standards, ensuring applications meet the regulator's expectations at first submission.

EMI licence success stories

Project: Dzing Financial

Overview

Dzing Financial engaged Buckingham Capital Consulting in relation to its FCA EMI authorisation. Our work included application preparation, compliance documentation, governance evidence, risk assessment, AML controls and support with the regulatory submission.

Scope of our work

Prepared the EMI application pack and supporting regulatory evidence.
Development of compliance policies and procedures.
Risk assessment and mitigation planning.
Integration of anti-money laundering (AML) systems.
Staff training on regulatory compliance.

Outcomes delivered

FCA EMI authorisation obtained.
Strengthened compliance, governance and financial crime evidence for the application.
Enhanced risk management processes to ensure ongoing compliance.
Prepared AML and financial crime control documentation.
Equipped staff with the knowledge and tools to maintain compliance.

Conclusion

The engagement helped Dzing present stronger regulatory evidence, evidence its compliance arrangements and prepare for post-authorisation obligations following FCA approval.

Overview

Hryze engaged Buckingham Capital Consulting for support with its EMI authorisation and compliance arrangements. Our work included regulatory route planning, application preparation, compliance documentation, gap analysis and post-authorisation support.

Scope of our work

Detailed project planning and regulatory roadmap development.
Preparation and submission of EMI authorisation application.
Compliance audit and gap analysis.
Implementation of compliance monitoring systems.
Continuous compliance advisory and support.

Outcomes delivered

Achieved successful EMI authorisation, enabling market entry.
Developed a clear regulatory roadmap, ensuring smooth compliance.
Identified and addressed compliance gaps through a thorough audit.
Implemented effective monitoring systems for ongoing regulatory adherence.
Provided continuous support, ensuring Hryze stays compliant and up-to-date with regulations.

Conclusion

The engagement supported EMI authorisation, strengthened the firm’s regulatory evidence and helped prepare the business for ongoing FCA expectations.

Project: Hryze

Project: Europanpay

Overview

Europanpay engaged Buckingham Capital Consulting in relation to its EMI application and supporting compliance arrangements. Our work included application preparation, policies and procedures, regulatory reporting support, financial crime documentation and ongoing compliance advice.

Scope of our work

EMI registration application preparation and submission.
Creation of robust compliance policies and procedures.
Financial management support, including reporting and audits.
Prepared AML and financial crime control documentation.
Ongoing compliance and regulatory support.

Outcomes delivered

Successfully obtained EMI registration, allowing Europanpay to expand.
Established strong compliance policies and procedures.
Improved financial management practices, ensuring regulatory compliance.
Provided ongoing support, maintaining regulatory compliance and operational efficiency.

Conclusion

The engagement supported EMI registration and helped strengthen the firm’s compliance documentation, reporting arrangements and financial crime controls for regulated e-money activity.

UK Electronic Money Institution
(EMI) Licence