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Electronic Money Institution Authorisation (licence)

Since 2013, we have combined deep expertise and experience to help electronic money institutions become authorised and provide regulated financial services.

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Why leading firms choose us as their partner.

"We are thrilled with the exceptional service provided by Buckingham Capital Consulting throughout our journey to obtain the Electronic Money Institution license. Their expertise and guidance have been invaluable, resulting in outstanding outcomes for our business. them, we successfully acquired the license within a reasonable time-frame. Their in-depth knowledge of regulatory compliance and meticulous attention to detail ensured that our documentation was well prepared and aligned with the FCA's requirements."

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We highly recommend Buckingham Capital Consulting to any business seeking to obtain an EMI license. Their professionalism, knowledge, and commitment to excellence have exceeded our expectations. Partnering with them has been a game-changer for our business, and we are grateful for their invaluable support."

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Electronic Money Institution Authorisation Guide

Introduction

At Buckingham Capital Consulting, we specialise in navigating the complex regulatory landscape surrounding e-money EMI / electronic money institution authorisation to help firms register with the FCA. Our team of experts possess a strong understanding of the intricacies involved in obtaining and maintaining electronic money institution (EMI) authorisation. We are adept at staying abreast of the latest regulatory developments and can provide with the expertise needed to obtain the authorisation and ensure compliance.

Our e-money EMI / electronic money institution authorisation service is designed to take the burden off your shoulders. We guide you through each step of the authorisation process, from initial application to ongoing compliance requirements. By leveraging our in-depth knowledge and experience, we streamline the process, saving you valuable time and resources. With Buckingham Capital Consulting as your trusted partner, you can focus on what you do best – running your business – while we handle the intricacies of the authorisation process.

Definition of e-money

As per Article 2(2) of Directive 2009/110/EC, “e-money” means “electronically, including magnetically, stored monetary value as represented by a claim on the issuer which is issued on receipt of funds for the purpose of making payment transaction, and which is accepted by a natural or legal person other than the electronic money issuer”. Prepaid cards and electronic wallets are examples of electronic money.

Documents required for an electronic money institution (EMI) authorisation licence application

To apply for the e-money EMI / electronic money institution authorisation, you will be required to complete the application form, as well as the supplementary forms and evidence and submit them to the financial regulator. Buckingham Capital Consulting can prepare and manage these documents on your behalf to strengthen your application.

As part of your e-money EMI / electronic money institution authorisation application, you will be required to prepare the following information:

1. Business plan, including financial forecasts for a period covering 3 years
2. A programme of operations
3. A description of your business organisation
4. Evidence of your initial capital. 
5. Details of how you will safeguard the funds of your users
6. Compliance & governance arrangements and internal controls 
​7. Procedure for monitoring, handling, and following up on security incidents and security-related customer complaints 
8. Processes for filing, monitoring, tracking and restricting access to sensitive payment data 
9 .Business continuity measures 
10. Details on your data collection methodology concerning performance, transaction and fraud-related data.
11. A copy of your security policy 
12. Your financial crime policy, entailing your internal control mechanisms to comply with anti-money laundering and countering-terrorist financing (AML/CTF obligations) 
13. Details of your qualifying holders (shareholders holding or controlling 10% or more in the applicant firm) 
14. Details of any outsourcing arrangements
15. Details of people responsible for the management of your firm


Registering management team members or directors
 
You will need to submit individual forms for each person responsible for the management of your electronic money institution (EMI). This typically includes the money laundering reporting officer and other head of function holders. 


Registering people with qualifying holdings 

You will be required to submit the details of any person or firm holding or controlling 10% or more capital or voting rights in the company. You must also inform the financial regulator of any changes to the qualifying holdings. 


Registering agents 

In order to engage an agent for the distribution of e-money or the provision of payment services on your behalf, it is mandatory to register them.

Having agents to distribute e-money on your behalf will make you a principal firm. As the principal entity, it will be your responsibility to ensure that your agent acts in compliance with relevant regulations. Therefore, it is crucial to establish suitable systems and controls to effectively supervise their activities. By doing so, you can effectively oversee and take accountability for any actions or omissions carried out by your appointed agent(s).

Time frame to obtain the e-money (EMI) licence

Financial regulators are required by the European Banking Authority to assess and make a decision on an electronic money institution authorisation application within three months of receiving a complete application.

You are required to submit specific information as part of your application. We can help ensure that you avoid any delays by preparing and submitting a complete application and making sure that you meet all the regulatory conditions and requirements. 

Services you can offer as an electronic money institution 

Electronic money institutions can issue electronic money I.e. cards and e-wallets. They can also offer payment services, as below:

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  1. Issuing of electronic money e.g. prepaid cards and electronic wallets;

  2. Services enabling cash to be placed on a payment account and all of the operations required for operating a payment account;

  3. Services enabling cash withdrawals from a payment account and all of the operations required for operating a payment account;

  4. The execution of payment transactions, including transfers of funds on a payment account with the user’s payment service  provider or with another payment service provider, including, execution of direct debits, including one-off direct debits; execution of payment transactions through a payment card or a similar device; execution of credit transfers, including standing orders;

  5. Execution of payment transactions where the funds are covered by a credit line for a payment service user,   including, execution of direct debits, including one-off direct debits; execution of payment transactions through a payment card  or a similar device; (iii)execution of credit transfers, including standing orders;

  6. Payment instruments or acquiring payment transactions;

  7. Money remittance;

  8. Payment initiation services; and,

  9. Account information services.

Initial and ongoing capital requirements for the EMI licence

The initial capital required for an e-money EMI / electronic money institution is €350,000.

The ongoing capital required for an electronic money institution (EMI) licence is calculated at 2% of the outstanding electronic money a firm has issued.

key requirements for the EMI licence

  • A minimum capital requirement of €350,000 is required to establish an electronic money institution (EMI) business.

  • The requirement is to safeguard client funds either with a segregated client bank account or with an insurance policy.

  • The management body of the electronic money institution must be of good repute and possess the relevant qualifications and experience to perform their duties.

  • Initial and ongoing capital requirements (as described above).

  • Meeting any local/national requirements set by the country e.g. the Threshold Condition as set by the FCA for the UK EMI authorisation.

 

Our People

Our team of regulatory and compliance experts boasts diverse backgrounds spanning various sectors, providing a holistic understanding of our clients' challenges. With our service being led by seasoned professionals, you'll have direct access to senior experts, often at the director level, ensuring personalised attention. Combining robust regulatory knowledge with commercial insight, our team delves deep into your business to tailor unique solutions specifically suited to your needs.

How we will support your Electronic Money Institution authorisation application

Step 1

We will spend time to understand your business, people, culture and business requirements.

Step 2

We will advise you on the regulatory requirements and help you meet them. We will then prepare and develop your application, working closely with you.

Step 3

We will submit your application and manage any additional information requested by the regulator, ensuring a smooth and successful outcome.

Sectors we serve

Payment services

We partner with startups and unicorns, providing tailored assistance for license authorisation, compliance, and support across the UK & Europe.

E-money

We assist businesses, from startups to established firms, with UK & EU EMI licensing, compliance, training, policy, and more.

Banking 

We help retail, private and investment banks with authorisation applications, PRA & FCA compliance, financial crime and training.

Consumer credit

We assist firms with FCA authorisation applications, compliance and training, providing support with regulatory obligations.

Insurance

We provide comprehensive assistance to general insurers and Lloyd's of London brokers across compliance, training and authorisation.

Mortgage providers & brokers

We offer a range of services including compliance, training, and authorisation support, tailored for mortgage providers and brokers.

Cryptoassets

We help clients with regulatory licence authorisation applications as well as risk and compliance, across a number of countries.

Investment services

We work with UK and European regulators and can help you become authorised to offer investment services as a regulated business.

Open banking

We assist open banking firms, including AISPs and PISPs, with compliance, training, regulatory authorisation, and regulatory support.

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