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How to become an E-money Electronic Money Institution

In this article, we look at the process of becoming an e-money electronic money institution (EMI).

There are two types of e-money licenses firms can apply for:

A firm can apply to become a small EMI only if its money outstanding e-money does not success EUR 5m. The registration process is cheaper and more straightforward in comparison to an authorised EMI, but there are no passporting rights. Small e-money EMIs may also provide unrelated payment services I.e. money remittance or payment processing, as long as their average monthly total of payment transactions does not exceed EUR 3m.

2. Authorised EMI electronic money institution - (e-money) liceense

Authorised EMIs e-money firms are subject to capital requirements (EUR 350k), safeguarding and conduct of business rules. Authorised EMIs may also passport in Europe (EEA), which enables them to operate in other European countries without requiring additional licenses or operational/physical setup. Authorised EMIs may also provide payment services that are not related to issuing e-money (unrelated payment services).

Making an Application for the authorised EMI (e-money) license

As part of your application, you will be required to submit a number of documents, policies and procedures, including the following:

1.  A programme of operations.

2.  A business plan including a forecast budget calculation for the first three financial years.

3.  Evidence that you hold initial capital.

4.  A description of the measures taken for safeguarding electronic money service users’ funds.

5.  A description of the governance arrangements and internal control mechanisms, including risk management and accounting procedures.

6.  A description of the procedure for monitoring, handling and following up security incidents and security-related customer complaints, including an incidents reporting mechanism which takes account of the notification obligations.

7.  A description of the process for filing, monitoring, tracking and restricting access to sensitive payment data.

8.  A description of the business continuity arrangements, including clear identification of the critical operations, effective contingency plans, and a procedure for regular testing and reviewing of the adequacy and efficiency of such plans.

9.  A description of the principles and definitions used in collecting statistical data on performance, transactions and fraud.

10.  A security policy.

11.  A money laundering and countering terrorism financing policy.

12.  A description of the structural organisation, including, agents, branches, and outsourcing. 

13.  Details of shareholders and their qualifying holding.

14.  Details of directors and persons who are or will be responsible for the management of the company.

15.  The legal structure of the company. 

16.  The address of the head office of the applicant.

Making an Application for the Small EMI (e-money) license

If your business’s total business activity does not exceed EUR 5m, you can apply to become a small EMI. The application fee for a small EMI is £1,000.

As part of your application, you will be required to submit a number of documents, policies and procedures, including the following:

  • Business plan

  • Initial capital

  • where the business activities of an applicant generate average outstanding e-money of €500,000 or more, the capital requirement is at least equal to 2% of the average outstanding e-money of the institution; and

  • where the business activities of an applicant generate average outstanding e-money of less than €500,000, there is no capital requirement.

  • Governance arrangements and risk management controls

  • Qualifying holdings (shareholders)

  • Money laundering controls

E-money License requirements and conditions

Before you apply, you must meet the following license conditions

  • you are a body corporate e.g.a limited company

  • you must carry out some of your payment services in the UK

  • you have strong compliance arrangements and internal procedures and controls

  • you have a business plan

  • you are able to safeguard the funds of your users

  • If you provide payment or account initiation services (PIS/AIS) you hold adequate indemnity cover

  • your directors and managers are of good repute and with appropriate knowledge and skills to provide the service

  • your managers must not have been convicted of money laundering or any other financial crimes

  • you comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.

  • those having a qualifying holding are fit and proper to do so.

How long does it take?

The FCA must make a decision within three months of receiving a complete application.

E-money License cost

The application fee for the small (e-money) electronic money institution is £1,000. The application fee for the authorised electronic money institution is £5,000. The fee is paid when you submit your license application online.

How we can help

Buckingham Capital Consulting is a leading international consulting firm, specialising in payment services, electronic money, banking and investment services. We are able to advise you on the best course of action and strategy based upon your business plan and financial product or service. We can you with licencing, compliance, operational setup and related services, including, obtaining banking facilities. For more information, visit our website on

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