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

End-to-end FCA licence authorisation support for electronic money institutions.

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Last updated: 11 May 2026

Clients we have helped

Why Buckingham Capital Consulting

What you can expect from working with us.

Experience

Our team has advised electronic money institutions across the UK and Europe since 2013. Each engagement is led at director level by senior consultants with extensive experience in FCA authorisation.

Expertise

Our specialism is FCA e-money licensing and regulatory compliance. We combine technical command of the regulatory framework with direct insight into the FCA's review standards, ensuring applications meet the regulator's expectations at first submission.

Outcomes

We have secured FCA EMI authorisations for e-wallet issuers, prepaid card programmes, virtual IBAN platforms, Banking-as-a-Service providers, and foreign exchange firms. Selected client outcomes are set out in our case studies below.

Download our free guide for FCA electronic money institution (EMI) licence authorisation and how to ensure a successful outcome with your application.

FCA EMI licence guide

FAQs

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 approached us to help them obtain their EMI authorisation and establish a robust compliance framework. They needed comprehensive support to ensure they met all regulatory requirements and could operate smoothly in the competitive financial markets of the UK and Europe. Our goal was to provide end-to-end assistance, from application submission to ongoing compliance management.

Scope of our work

Comprehensive application preparation and submission.
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

Successfully secured EMI authorisation from the FCA.
Implemented a comprehensive compliance framework tailored to regulatory requirements.
Enhanced risk management processes to ensure ongoing compliance.
Integrated advanced AML systems to prevent financial crimes.
Equipped staff with the knowledge and tools to maintain compliance.

Conclusion

By partnering with us, Dzing Financial was able to navigate the complex EMI authorisation process efficiently and effectively. Our comprehensive support ensured they not only met all regulatory requirements but also established a solid foundation for future growth. The value delivered included a seamless authorisation process, robust compliance measures, and improved operational readiness, positioning Dzing Financial for long-term success.

Overview

Hryze sought our expertise to guide them through the EMI authorisation process and provide ongoing compliance support. As a growing e-money institution, they needed a clear regulatory roadmap and comprehensive compliance strategies to ensure sustainable growth and regulatory adherence in the UK and European markets.

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

With our guidance, Hryze successfully obtained EMI authorisation and established a strong compliance framework. Our ongoing support ensured they could navigate the regulatory landscape with confidence. The value delivered included a successful authorisation, effective compliance strategies, and the ability to focus on growth while maintaining regulatory adherence.

Project: Hryze

Project: Europanpay

Overview

Europanpay required assistance in obtaining EMI registration and enhancing their compliance and operational frameworks. As an emerging player in the e-money sector, they needed support in navigating the regulatory requirements and implementing efficient operational processes to ensure compliance and support their growth ambitions.

Scope of our work

EMI registration application preparation and submission.
Creation of robust compliance policies and procedures.
Financial management support, including reporting and audits.
Integration of technology solutions for compliance and operations.
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.
Integrated advanced technology solutions to streamline operations.
Provided ongoing support, maintaining regulatory compliance and operational efficiency.

Conclusion

Through our comprehensive support, Europanpay was able to achieve EMI registration and enhance their operational and compliance frameworks. The value delivered included a smooth authorisation process, robust compliance and financial management practices, and the integration of technology solutions that supported their growth and operational efficiency. Europanpay is now well-positioned to thrive in the competitive e-money sector.