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BCC runs compliance for electronic money institutions (EMIs) authorised by the Financial Conduct Authority (FCA), from safeguarding and own funds to financial crime, the Consumer Duty and regulatory returns.
Selected engagements from more than 250 licences obtained since 2013, for payment, e-money and cryptoasset firms.
Volkswagen
Payment InstitutionObtained Nexpay’s FCA Authorised Payment Institution licence.
Electronic Money InstitutionObtained Dzing Finance’s FCA Authorised Electronic Money Institution licence.
Obtained Orbital’s FCA Authorised Payment Institution licence.
The short answer
A UK electronic money institution must meet the Electronic Money Regulations 2011 (EMRs), the CASS 15 safeguarding rules, the Money Laundering Regulations 2017, the Consumer Duty, own funds requirements and FCA reporting. An EMI compliance consultant tests the firm against each, documents the gaps, remediates policies, controls and returns, and provides ongoing monitoring or outsourced compliance and MLRO roles.
An EMI issues electronic money and usually provides payment services alongside it, so it is regulated under both the EMRs and, for unrelated payment services, the Payment Services Regulations 2017 (PSRs). Authorised EMIs must hold initial capital of at least 350,000 euros under Schedule 2 to the EMRs and keep own funds above their requirement at all times. Small EMIs carry lighter requirements but remain within safeguarding, anti-money laundering (AML) and conduct rules.
The FCA reaches EMIs through the Principles for Businesses, including the Consumer Duty, the complaints rules in the Dispute Resolution sourcebook (DISP), CASS 15, the operational resilience rules in SYSC 15A and the reporting rules in the Supervision manual (SUP). E-money balances sit with the firm for longer than a single payment, which raises the stakes on safeguarding and on wind-down planning. A consultant's role is to prove, with evidence, that customer money is protected and that the firm could be wound down in an orderly way.
EMIs are not generally within the Senior Managers and Certification Regime (SM&CR). Instead, the FCA assesses directors and the persons responsible for managing the e-money business as fit and proper, using the EMD Individual form, and the firm must notify it of changes. We prepare these submissions and build the responsibilities map that shows who answers for safeguarding, financial crime and customer outcomes, which is what supervisors ask for first.
A person acquiring or increasing control of an EMI must notify the FCA and obtain approval before completing. The FCA has up to 60 working days to assess a complete notification, excluding any interruption while it requests information. EMIs are frequent acquisition targets, and deals often stall on the acquirer's source of funds or on unanswered questions about safeguarding after completion. We prepare the notification, the controller documents and the post-acquisition plan.
Every EMI is within the Money Laundering Regulations 2017 (MLRs). It needs a written business-wide risk assessment, customer due diligence scaled to risk, ongoing monitoring, sanctions screening and a process for internal and external suspicious activity reports. Regulation 21 requires a nominated officer, the money laundering reporting officer (MLRO), and where appropriate a board-level officer responsible for MLRs compliance.
E-money products such as prepaid cards, wallets and accounts with IBANs (international bank account numbers) attract mule activity and authorised push payment fraud. The FCA expects monitoring scenarios to reflect the firm's own customers and products, alerts to be cleared promptly and the MLRO to report candidly to the board. We test customer files, scenario calibration and alert backlogs, write the MLRO annual report and, where needed, provide the MLRO.
Funds received in exchange for e-money must be safeguarded from the moment of receipt. Since 7 May 2026, CASS 15, introduced by Policy Statement PS25/12, requires daily reconciliations, a monthly safeguarding return under SUP 16.14A, an annual safeguarding audit by a qualified auditor unless an exemption applies, a resolution pack and a named individual responsible for safeguarding.
For EMIs the hard questions are timing and scope: when funds are received, how outstanding e-money is calculated, how agent and distributor flows are captured, and whether insurance or guarantee arrangements are correctly documented. We trace a sample of transactions end to end, rebuild reconciliations where they rely on manual workarounds, review each monthly return and prepare the firm for its auditor.
An EMI's policies should describe how the firm really operates: issuance and redemption, safeguarding, financial crime, complaints, vulnerable customers, outsourcing and incident management. Redemption at par value and without unjustified fees is a specific EMRs requirement and a common source of complaints, so we check that the terms, the product and the process all match.
The Consumer Duty in PRIN 2A requires good outcomes on products and services, price and value, consumer understanding and consumer support, with a board review of outcomes at least annually. E-money and payment services complaints must be answered within 15 business days under DISP 1.6.2A, or 35 business days in exceptional circumstances after a holding response. We build the outcome metrics, the annual board report and the root cause analysis that connects complaints to product changes.
A risk-based compliance monitoring programme sets out what will be tested, how often and how results reach the board. For an EMI, testing should centre on safeguarding, own funds, onboarding, transaction monitoring, redemption and complaints, and the plan should be refreshed from the annual risk assessment.
EMIs report to the FCA under SUP 16.15. Authorised EMIs file the FIN060a return and small EMIs file FIN060b, covering own funds and safeguarding. EMIs that provide payment services also file the REP017 payment fraud report, and safeguarding firms file the monthly safeguarding return. These returns are compared over time by supervisors, so inconsistencies between them invite questions. We prepare or review each submission, reconcile it to the ledger and safeguarding records, and keep a reporting calendar so that no return is filed late or contradicts another.
SYSC 15A applies to EMIs. The firm must identify important business services, set impact tolerances, map dependencies and run scenario tests. The transition period ended on 31 March 2025, so supervisors now expect firms to be operating within tolerance and to show the testing evidence.
Most EMIs depend on outsourced card processing, banking, core ledger and onboarding suppliers. The EMRs require the FCA to be notified of outsourcing of operational functions, and important functions may only be outsourced where internal control, the FCA's ability to supervise and senior management responsibility are preserved. Own funds for e-money issuance are calculated under Method D in Schedule 2 to the EMRs, broadly 2% of average outstanding electronic money, with payment services calculated separately. We review the outsourcing register, key contracts and the own funds calculation together, because supplier failure is where resilience, safeguarding and capital problems meet.
Every engagement follows the same four stages, scaled to the size of the electronic money institution and the urgency of the issue.
Assessment comes first: we review your permissions, governance, policies, management information and recent FCA correspondence against the rules that apply to you. You then receive written findings, ranked by regulatory risk, with each gap tied to the specific rule it breaches and a named owner for the fix. Remediation follows: we redraft policies and procedures, rebuild monitoring plans, correct returns and prepare board papers, and we can attend FCA meetings alongside your senior managers. Finally, ongoing support keeps the position steady after remediation, through a retained monthly review, an annual compliance monitoring programme or outsourced roles such as an outsourced MLRO or compliance officer.
Buckingham Capital Consulting (BCC) was established in 2013 and has obtained more than 250 licences in over 60 countries for payment, e-money and crypto firms. We open global markets to payment, e-money and crypto businesses: the licences to enter, the banking to operate and the compliance to scale.
For EMIs, that means compliance work grounded in how the licence was won: the business plan, the safeguarding model and the wind-down arrangements the firm presented to the FCA. Supervisors measure an EMI against those commitments, and so do we.
Because BCC also arranges banking for regulated firms, our compliance work is written with the questions banks and safeguarding providers ask in mind. A firm whose controls satisfy the FCA and its bank at the same time spends less time answering the same questions twice. To discuss your firm, use the contact form and tell us your permissions, your current team and the issue you need resolved.
An EMI compliance consultant tests an electronic money institution against the EMRs, CASS 15 safeguarding, the MLRs, the Consumer Duty, own funds rules and FCA reporting. They document the gaps, fix policies, controls and returns, and often provide ongoing monitoring or outsourced MLRO and compliance roles.
An authorised EMI must hold initial capital of at least 350,000 euros under Schedule 2 to the EMRs and keep own funds at or above its requirement at all times. For e-money issuance, own funds are generally calculated under Method D, broadly 2% of average outstanding electronic money.
Authorised EMIs file FIN060a and small EMIs file FIN060b under SUP 16.15. EMIs providing payment services also file the REP017 payment fraud report, and safeguarding firms submit the monthly safeguarding return under SUP 16.14A introduced with CASS 15.
Under CASS 15, in force since 7 May 2026, safeguarding firms must obtain an annual safeguarding audit from a qualified auditor unless an exemption applies. Preparation means clean reconciliations, documented safeguarding arrangements and a current resolution pack.
Yes. The Consumer Duty in PRIN 2A applies to e-money and payment services provided to retail customers. The firm must evidence good outcomes across products, price and value, understanding and support, and its board must review those outcomes at least annually.
Yes. We prepare the change in control notification for the acquirer and then run a post-completion review of safeguarding, financial crime and governance, so the new owners know the firm's true compliance position from day one.
Tell us what you need and where you operate.