How Much Does an FCA PI or EMI Licence Cost in 2026? Fees, Capital and Real Application Costs

How Much Does an FCA PI or EMI Licence Cost in 2026? Fees, Capital and Real Application Costs

The cost of obtaining an FCA Payment Institution or Electronic Money Institution licence is considerably more than the application fee paid to the regulator. A business needs to budget separately for the FCA application fee, regulatory capital, professional application support, management and compliance resources, technology and operational infrastructure, safeguarding arrangements and the ongoing cost of operating as a regulated financial institution. Confusing these different costs can lead founders to significantly underestimate the funding needed to reach authorisation and launch.

In 2026, the FCA application fee for an Authorised Electronic Money Institution is £5,640. An Authorised Payment Institution application costs either £2,820 or £5,640 depending on the payment services requested, while Small Payment Institution and Small Electronic Money Institution applications fall within the £1,130 pricing category. These fees are non-refundable and represent only the amount paid to the FCA to assess the application.

Regulatory capital is separate and usually much more significant. An Authorised Payment Institution can require initial capital of €20,000, €50,000 or €125,000 depending on its regulated activities, while an Authorised Electronic Money Institution requires at least €350,000. Unlike an FCA fee or professional cost, regulatory capital is not money paid to the regulator, but it must remain available to the regulated business and satisfy ongoing own-funds requirements after authorisation.

FCA PI and EMI costs at a glance

Cost	API	AEMI	SPI	SEMI
FCA application fee	£2,820 or £5,640 depending on permissions	£5,640	£1,130	£1,130
Initial regulatory capital	€20,000, €50,000 or €125,000 depending on activities	€350,000 minimum	No equivalent fixed initial capital requirement	Can require 2% of average outstanding e-money where applicable
Professional application support	Depends on complexity and scope	Depends on complexity and scope	Usually lower than full authorisation	Depends on proposed e-money model
Compliance and governance	Required	Required	Proportionate requirements	Proportionate requirements
Safeguarding infrastructure	Required where relevant	Required	Depends on safeguarding status	Required where relevant
Ongoing FCA fees	Yes	Yes	Yes	Yes
Safeguarding audit	Can apply once relevant threshold is exceeded	Can apply once relevant threshold is exceeded	Generally outside mandatory SUP 3A regime	Can apply depending on status and threshold
Ongoing capital requirement	Yes	Yes	Different regime	Depends on scale and applicable requirements

The table separates the principal cost categories because they should not be added together without understanding what each represents. The FCA fee is an irrecoverable regulatory charge, professional and operational expenditure is a genuine business cost, while regulatory capital remains within the company subject to the applicable restrictions and ongoing capital requirements. A realistic funding plan needs to account for all three.

What is the FCA application fee for an Authorised Payment Institution in 2026?

The FCA charges an API application fee according to the payment services for which the firm seeks authorisation. In 2026, applications involving payment services in paragraphs (a) to (e) of Schedule 1 to the Payment Services Regulations fall within FCA pricing Category 5, currently £5,640. These activities include services enabling cash to be placed on or withdrawn from payment accounts, execution of payment transactions, payment transactions involving credit facilities, issuing payment instruments and acquiring payment transactions.

An API applying only for activities falling within paragraphs (f) to (h), which include money remittance, payment initiation and account information services, falls within Category 4, currently £2,820. The precise fee should always be confirmed against the permissions being requested because a business seeking several activities may fall into the higher applicable category. The FCA will reject an application without assessment if the correct application fee is not paid.

For many API applicants, the application fee is one of the smallest parts of the overall project. The more significant financial considerations are usually regulatory capital, preparing the authorisation framework, recruiting suitable people and establishing the systems and third-party relationships needed to operate compliantly after approval.

The FCA’s current authorisation and registration fee schedule confirms the applicable 2026 pricing categories.

What is the FCA application fee for an EMI licence?

An application for authorisation as an Authorised Electronic Money Institution falls within FCA pricing Category 5. The application fee in 2026 is therefore £5,640, payable when the application is submitted and non-refundable regardless of whether the application is approved, withdrawn or refused.

The EMI fee does not increase simply because the applicant intends to provide several payment services alongside issuing electronic money. An AEMI can provide payment services within the scope of its authorisation without separately becoming authorised as a PI, although the applicant still needs to identify the relevant payment services and demonstrate appropriate systems, governance, safeguarding and financial resources for the complete model.

The application fee should not be confused with the €350,000 initial capital requirement for an AEMI. The £5,640 fee is paid to the FCA and is spent permanently, whereas regulatory capital remains within the authorised business and forms part of its financial resources.

For a serious EMI project, the difference between the two is fundamental. A founder who says an “EMI licence costs £5,640” is describing only the FCA filing charge and not the actual financial commitment required to establish an authorised e-money institution.

How much initial capital does an Authorised Payment Institution need?

The initial capital requirement for an API depends on the payment services it intends to provide. A firm providing money remittance only requires minimum initial capital of €20,000, while a firm providing payment initiation services requires €50,000. An API providing one or more of the payment services in paragraphs (a) to (e) of Schedule 1 requires minimum initial capital of €125,000.

Those higher-capital activities include payment account services, cash placement and withdrawal, execution of Direct Debits, card transactions and credit transfers, certain payment transactions using credit lines, issuing payment instruments and merchant acquiring. Where an applicant seeks several permissions carrying different initial capital requirements, the highest applicable initial capital amount applies rather than adding each threshold together.

For example, a business providing money remittance and merchant acquiring would not add €20,000 and €125,000 to reach €145,000. Because merchant acquiring sits within the group of activities subject to the €125,000 requirement, the applicable initial capital floor would be €125,000.

Account information services do not carry an equivalent fixed initial capital requirement, although professional indemnity insurance or a comparable guarantee can be required depending on the permission structure. Firms should also distinguish initial capital from ongoing own funds, because an API may be required to maintain more than its original capital floor once its business grows.

How much capital does an EMI need?

An applicant seeking authorisation as an AEMI must hold at least €350,000 of initial capital. This requirement applies to the authorised e-money institution itself and must be evidenced before authorisation is granted, although the FCA may allow the applicant to provide final capital evidence later in the assessment process rather than requiring the full amount to be injected on the first day the application is submitted.

The €350,000 requirement does not increase simply because the AEMI also provides payment services related to issuing electronic money. An EMI commonly combines e-money issuance with wallets, cards, payment execution and other functionality, and those related payment activities sit within the wider EMI regulatory model.

The position becomes more complicated where an AEMI provides payment services unrelated to its e-money issuance. Although there is no additional initial capital requirement merely for adding those unrelated services, separate ongoing own-funds calculations can apply to that part of the business.

Applicants therefore need to model capital after launch rather than assuming that maintaining exactly €350,000 permanently will always be sufficient. Growth in outstanding e-money, payment activity or other relevant metrics can increase the ongoing capital requirement.

Regulatory capital is not the same as a licence fee

This distinction is one of the most commonly misunderstood aspects of FCA payment and e-money authorisation. If a business needs €350,000 of initial capital for an AEMI, it does not pay €350,000 to the FCA or lose that money when the licence is granted. The capital remains an asset of the authorised company, but it must qualify as eligible regulatory capital and remain available to support the regulated business.

The same principle applies to an API’s €20,000, €50,000 or €125,000 initial capital requirement. The FCA will expect evidence that the applicant genuinely holds the required capital and that it has not been artificially recycled, temporarily borrowed merely for the purpose of the application or otherwise structured in a way that undermines its availability.

Capital also cannot normally be treated as money that can immediately be withdrawn by shareholders after authorisation. The firm must continue to meet its ongoing own-funds requirements, and those requirements can exceed the initial regulatory minimum as the business develops.

A founder budgeting for authorisation should therefore treat regulatory capital as committed balance-sheet funding rather than as an ordinary operating expense. It supports the business but is constrained by the requirement to maintain adequate financial resources continuously.

What are the ongoing capital requirements for an API?

Authorised Payment Institutions are subject to continuing own-funds requirements after authorisation. For most APIs, the firm must maintain own funds equal to or greater than both the applicable initial capital floor and the amount produced by the FCA-directed ongoing capital calculation, so the higher figure effectively determines the minimum that must be maintained.

The Payment Services Regulations provide methods A, B and C for calculating ongoing own funds. Method A is broadly linked to fixed overheads, while methods B and C use payment volume or income-related measures according to the applicable methodology. The FCA determines which method the firm must use, taking into account the nature and scale of the business and the applicant’s proposed approach.

This means the capital needed by a fast-growing payment institution can increase significantly after launch. A firm authorised with a €125,000 initial requirement may later need more than that because its payment volumes or other relevant metrics generate a higher ongoing own-funds calculation.

Financial forecasts submitted with the application should therefore model regulatory capital over the entire forecast period. The FCA will expect the funding plan to show that the firm can remain adequately capitalised as transaction volumes, staffing and operating costs increase.

What are the ongoing capital requirements for an AEMI?

An AEMI must maintain own funds of at least €350,000 and also satisfy the applicable ongoing capital calculation. For e-money issuance and payment services related to that issuance, the principal calculation under Method D is based on a percentage of average outstanding electronic money, subject to the detailed requirements of the Electronic Money Regulations.

Where an AEMI also provides unrelated payment services, additional ongoing capital requirements can arise under the payment-services methodologies. The firm therefore needs to distinguish between activities related directly to e-money issuance and payment services that operate independently from the e-money business.

This distinction can be particularly important for diversified fintechs. An EMI that issues wallets and cards but also operates a separate merchant-acquiring or remittance business may need a more sophisticated capital model than an issuer whose payment services exist solely to support its e-money product.

The FCA expects these calculations to be reflected in credible financial forecasts. An applicant projecting substantial growth without showing the resulting capital requirements may create doubts about whether the business is adequately funded.

How much does an SPI or Small EMI application cost?

An application to register as a Small Payment Institution falls within FCA pricing Category 3, which is £1,130 in 2026. A Small Electronic Money Institution application also falls within Category 3 and therefore carries the same £1,130 FCA application fee.

The lower regulatory fee does not mean these routes are simply cheap versions of API or AEMI authorisation. They operate under different statutory regimes with limitations on scale and, in the case of small payment institutions, restrictions on the services that can be provided.

A Small EMI can also become subject to an initial capital requirement depending on the scale of its e-money business. Where average outstanding e-money reaches or is projected to reach €500,000 or more, the applicable rules require capital equal to at least 2% of average outstanding e-money, whereas a smaller SEMI below that threshold does not have the same fixed initial capital obligation.

Businesses should choose SPI or SEMI status because the model genuinely fits the small-institution regime, not simply because the FCA fee and initial funding requirements appear lower. A fintech expecting rapid growth can create unnecessary regulatory work if it obtains a small registration and then needs to apply for full authorisation shortly afterwards.

Professional application costs can exceed the FCA filing fee

A serious API or AEMI application requires a substantial body of regulatory work. The exact professional cost depends on the complexity of the business, the permissions requested, how much of the regulatory framework already exists and whether the applicant needs end-to-end support or only a limited review.

A full application commonly requires a regulatory business plan, programme of operations, financial forecasts, capital calculations, governance arrangements, safeguarding framework, enterprise and operational risk management, financial crime controls, outsourcing arrangements, complaints processes, wind-down planning and a substantial set of supporting policies and procedures. The application also needs ownership and controller information, evidence relating to senior management and detailed descriptions of how technology, customer funds and regulated activities operate.

These documents should not be produced independently by different advisers without a single coherent regulatory model. The FCA will compare the business plan, application forms, financial forecasts, safeguarding methodology and policies, and inconsistencies between them can create significant questions and delay.

Professional costs therefore reflect more than completing an online form. The real work is designing and documenting a regulated business that can satisfy the FCA’s authorisation conditions and operate compliantly once permission is granted.

The cost of management and compliance is often underestimated

The FCA expects an authorised PI or EMI to have governance arrangements and senior management appropriate to the nature, scale and complexity of the business. A startup cannot assume that it can obtain authorisation with a nominal board and one outsourced compliance policy while every substantive decision is made by founders or developers with no regulated-financial-services experience.

The required team varies according to the model. A straightforward remittance API will have different needs from an AEMI offering multi-currency accounts, cards, merchant services and international payment products, but both need credible responsibility for compliance, financial crime, risk, finance and operational oversight.

Some applicants already have experienced management and therefore incur relatively little additional recruitment cost before submission. Others need to recruit a compliance lead, MLRO, finance expertise or independent directors before the FCA can be satisfied that the governance structure is appropriate.

These personnel costs can materially exceed the FCA application fee during the authorisation period. They also continue after authorisation and should therefore be included in the firm’s financial forecasts as ongoing operating expenditure rather than treated as one-off licensing costs.

Safeguarding creates both setup and ongoing costs

Firms handling relevant customer funds need safeguarding arrangements capable of meeting the strengthened regime introduced under PS25/12 and CASS 15 from 7 May 2026. Applicants should therefore budget for the operational infrastructure required to identify relevant funds correctly, segregate them, perform daily internal and external reconciliations, monitor third-party institutions, maintain resolution packs and submit required regulatory information.

Banks and other safeguarding institutions may charge onboarding, account or transaction fees, and obtaining a suitable safeguarding relationship can take considerable time. The commercial cost varies significantly according to the firm’s jurisdictional exposure, customer profile, expected volumes and business model, so there is no standard FCA-prescribed price for obtaining a safeguarding account.

The regulatory cost extends beyond the bank account itself. The firm needs systems and processes capable of producing accurate daily data, staff responsible for reconciliations and exceptions, governance oversight and records sufficient to demonstrate compliance.

Relevant institutions can also become subject to mandatory annual safeguarding audits. Our CASS 15 and safeguarding services support firms with the design and implementation of the safeguarding framework required both for authorisation and ongoing compliance.

Banking and infrastructure costs are separate from FCA authorisation

An FCA authorisation does not automatically provide access to banking, payment schemes, cards, IBANs or other infrastructure. The regulated firm still needs commercial partners capable of supporting its operating model, and those providers conduct their own onboarding and due diligence independently from the FCA.

An EMI may need safeguarding and operational bank accounts, card issuing or processing partners, core ledger technology, foreign exchange providers and payment rails. An API may require banking connectivity, scheme access, processors or specialist infrastructure depending on the services it provides.

The commercial arrangements vary widely and can include setup fees, minimum monthly commitments, transaction charges, reserve requirements or prefunding. These are business costs rather than regulatory fees, but they can materially affect the amount of funding needed before the business reaches sustainable transaction volumes.

Applicants should therefore model infrastructure costs before submitting the FCA application. A regulatory business plan that assumes commercially unrealistic banking or processing economics can undermine the credibility of the financial forecasts.

Technology can be one of the largest pre-launch costs

The FCA does not prescribe that an API or EMI must build its own technology platform. Many firms use third-party core banking, payment, card or compliance infrastructure, while others develop significant parts of their systems internally.

Whichever model is chosen, the applicant remains responsible for the regulated service. Outsourcing technology does not outsource regulatory accountability, and the firm needs appropriate due diligence, contracts, oversight, access rights, security and business continuity arrangements.

The cost therefore depends heavily on the product. A relatively simple money-transfer model can require much less infrastructure than a multi-currency EMI offering customer accounts, virtual and physical cards, foreign exchange, APIs and merchant services.

Technology expenditure should also include regulatory functionality. Transaction monitoring, sanctions screening, safeguarding reconciliations, regulatory reporting, complaints, fraud controls and management information all need reliable systems even where the customer-facing product appears relatively simple.

Financial crime compliance carries a real operating cost

Payment and e-money firms are particularly exposed to money laundering, fraud, sanctions and other financial crime risks because they sit directly within the movement of funds. The FCA therefore expects the financial crime framework to be proportionate to the specific customers, products, jurisdictions and transaction flows of the proposed business.

Applicants may need customer identification and verification technology, sanctions and PEP screening, transaction monitoring, fraud controls, case management and regulatory reporting capability. The precise cost varies according to transaction volumes, customer type and the extent to which systems are developed internally or purchased from specialist vendors.

Human oversight remains necessary even where much of the process is automated. Alerts need investigation, higher-risk customers require enhanced due diligence and the MLRO needs sufficient information and resources to oversee the framework properly.

A business that budgets only for onboarding software but not the people and processes needed to operate financial crime controls is likely to underestimate both its application readiness and its ongoing cost base.

Insurance can be required for certain payment services

Certain payment-service models, particularly payment initiation and account information services, can require professional indemnity insurance or a comparable guarantee. The amount and terms depend on the regulatory requirements and the scale and risk characteristics of the firm.

Insurance premiums are commercial costs rather than FCA charges, and pricing varies according to the insurer’s assessment of the business. New fintechs can sometimes find specialist coverage more difficult or expensive to obtain because they lack an operating history.

Applicants should therefore identify insurance requirements early. Discovering shortly before authorisation that appropriate cover cannot be obtained on the assumptions used in the business plan can delay launch or require changes to financial forecasts.

The policy must also satisfy the regulatory requirements rather than simply being a generic technology or professional liability policy. Coverage, exclusions and limits should be reviewed against the payment services being provided.

Ongoing FCA fees continue after authorisation

Payment Institutions and Electronic Money Institutions pay annual regulatory fees after becoming authorised or registered. These periodic fees are separate from the one-off application fee and are calculated under the FCA’s annual fee framework using the applicable fee blocks and tariff measures.

The amount therefore varies according to the type and scale of the regulated firm. The FCA publishes new fee rates for each regulatory year, and payment and e-money firms can also be subject to applicable levies associated with bodies such as the Financial Ombudsman Service.

Annual regulatory fees are generally not the largest operating expense for a fintech, but they should still be included in forecasts. Regulatory businesses incur a continuing compliance cost rather than a one-off fee to obtain a licence and then operate without further regulatory expenditure.

The 2026/27 FCA fee framework was finalised in July 2026, and firms should use the current tariff rules when budgeting their periodic regulatory charges.

Regulatory reporting and audits create recurring costs

Authorisation brings ongoing reporting obligations. Depending on its status and activities, a PI or EMI can need to submit capital, transaction, fraud, operational risk, safeguarding and other regulatory information to the FCA, with additional event-driven notifications when material circumstances change.

These obligations require reliable data and internal ownership. A firm that builds regulatory reporting manually from several disconnected systems may find the process increasingly expensive and error-prone as the business scales.

CASS 15 has also introduced monthly safeguarding reporting and mandatory safeguarding audits for relevant institutions above the applicable exemption threshold. The firm therefore needs to budget for external audit costs as well as the internal compliance and finance time required to prepare evidence and remediate findings.

Our guide to FCA regulatory reporting for payment and e-money firms explains the principal returns and reporting obligations that regulated firms need to plan for after authorisation.

What does an FCA licence really cost before launch?

There is no single honest figure because two businesses applying for the same regulatory category can have completely different operating models. A money-remittance API with a small experienced team and established infrastructure can require substantially less investment than an AEMI building consumer wallets, cards, multiple currencies and complex cross-border services.

The correct budget should separate six areas: the FCA application fee, regulatory capital, professional regulatory support, management and compliance resources, technology and operational infrastructure, and sufficient working capital to fund the business through authorisation and early operation. Each should be calculated independently rather than using a generic “licence cost” advertised online.

Regulatory capital is often the largest visible figure, particularly for an AEMI, but working capital can be equally important. A company may satisfy the €350,000 regulatory capital requirement while still lacking enough unrestricted cash to fund salaries, technology, advisers and infrastructure during a lengthy authorisation period.

The safest approach is to prepare a detailed funding model before starting the application. This allows the founders to understand not merely whether they can afford the FCA fee, but whether they can finance a viable regulated business through authorisation and into commercial operation.

Why very cheap “licence packages” can be misleading

Businesses searching for an FCA licence frequently encounter providers advertising low-cost packages that appear to include the complete authorisation process. The price may cover application forms and standard policy templates but exclude financial modelling, regulatory structuring, safeguarding design, substantive revisions, FCA information requests or implementation support.

This creates a false comparison between providers because the underlying scopes can be completely different. A £5,000 document package and an end-to-end regulatory authorisation project are not equivalent services simply because both are described as “FCA licence support”.

The greater risk is regulatory rather than financial. Generic documentation that does not correspond with the applicant’s real business model can create inconsistencies that delay the FCA assessment and require substantial remediation after submission.

Applicants should therefore understand exactly what is included, who is designing the regulatory framework and whether support continues through FCA questions and determination. The cheapest initial proposal can become considerably more expensive if the application has to be rebuilt later.

Applying yourself can reduce professional fees but not regulatory requirements

There is no legal requirement to appoint a consultant or law firm to submit an FCA Payment Institution or EMI application. A business can prepare and manage its own application directly through FCA Connect, and experienced regulatory teams may be capable of doing so effectively.

Self-submission does not reduce the regulatory standard. The applicant still needs to produce the required business plan, financial forecasts, governance, safeguarding, financial crime, risk, outsourcing, wind-down and other documentation and demonstrate that its management and systems satisfy the applicable requirements.

The financial saving therefore depends on whether the business already has the expertise and capacity internally. A team with deep payments compliance experience may reasonably perform much of the work itself, whereas founders learning the regulatory framework from scratch can spend significant time producing documentation that later requires substantial revision.

The decision should be based on capability rather than the belief that using an adviser is itself an FCA requirement. The regulator assesses the applicant, not the brand of consultant that prepared the documents.

Buying an existing PI or EMI is not necessarily cheaper

Some businesses consider acquiring an existing authorised firm rather than making a new FCA application. An acquisition can provide a faster route in the right circumstances, but it should not be assumed to reduce the total cost.

The buyer pays for the regulated company itself and may incur legal, regulatory and due diligence costs in addition to the purchase price. A qualifying acquisition can require FCA Change of Control approval, and planned changes to permissions, management or the business model can create additional regulatory work.

The buyer also inherits the target’s regulatory history, systems and potential weaknesses. A low-priced EMI with poor safeguarding arrangements, weak financial crime controls or significant remediation requirements can be materially more expensive than establishing a new firm properly.

BCC supports both buyers and sellers of regulated payment and e-money businesses, including regulatory due diligence, buyer-seller matching and management of the FCA Change of Control process. The choice between acquisition and new authorisation should therefore be based on time, regulatory fit, cost and risk rather than purchase price alone.

How should founders budget for an API application?

An API budget should begin with the applicable FCA application fee and regulatory capital requirement based on the requested payment services. The founder should then add the full cost of preparing the application, employing or retaining the required management and compliance resources and building the operational infrastructure needed to deliver the proposed services.

Working capital should cover the authorisation period and a realistic period after launch. As our guide to FCA PI and EMI authorisation timelines explains, applicants should not assume that a complete project will be finished within the statutory three-month determination period.

The forecasts should include downside scenarios in which authorisation takes longer, customer growth is slower or infrastructure costs are higher than expected. Regulatory capital should not be counted twice as unrestricted cash available to cover every operating expense because the firm must continue meeting its own-funds requirements.

A properly funded API application is therefore not simply one where the founders can provide €20,000 or €125,000 on request. It is one where the company has enough resources to reach authorisation, launch and continue meeting its obligations without immediately becoming dependent on uncertain future fundraising.

How should founders budget for an AEMI application?

An AEMI requires a larger financial commitment because the €350,000 initial capital floor sits alongside a regulatory and operational framework capable of supporting electronic money issuance. Wallets, accounts, cards and related payment functionality can also create substantial technology, banking, safeguarding and compliance costs before the business earns meaningful revenue.

The capital plan should distinguish regulatory own funds from operational working capital. If the business has exactly enough funding to inject €350,000 and nothing left to pay staff, technology providers and advisers during authorisation, it is not adequately funded merely because it can technically meet the initial capital threshold.

Forecasts should also model how outstanding e-money and unrelated payment services affect future capital requirements. A fast-growing EMI can need additional own funds as the scale and composition of its business change.

Investors should therefore evaluate the funding requirement against the complete regulatory operating model. The objective is not merely to obtain the EMI authorisation but to establish a firm capable of remaining compliant and financially sustainable after authorisation.

What should be included in a realistic FCA licensing budget?

A realistic budget should begin before the regulatory application is submitted and extend beyond the expected authorisation date. It should include one-off regulatory and professional expenditure, recurring operating costs and capital that must remain available within the regulated entity.

The model should account for the FCA application fee, regulatory capital, application preparation, management and compliance staff, technology, safeguarding and banking, financial crime systems, insurance where relevant, legal and corporate work, external audit requirements and annual regulatory fees. It should also provide contingency for FCA information requests, changes to commercial partners and a longer-than-expected authorisation period.

The biggest mistake is to budget only for costs that are obvious on day one. A regulated fintech can spend months preparing for authorisation and several more months under FCA assessment before generating regulated revenue, while still incurring staff and infrastructure costs throughout that period.

A credible financial model therefore answers two different questions: how much is required to obtain the licence, and how much funding is required to build and sustain the business that will use it. The second figure is usually the more important one.

How Buckingham Capital Consulting can help

Buckingham Capital Consulting has specialised in payment and electronic money regulation since 2013 and supports fintech businesses through API, SPI, AEMI and SEMI applications in the UK and payment and e-money authorisations across Europe. We assess the proposed model first so that founders understand the correct regulatory route, permissions, capital requirements and likely project scope before committing substantial expenditure.

For full authorisation projects, we prepare and manage the complete regulatory application, including the business plan, programme of operations, financial forecasts, regulatory capital calculations, governance, safeguarding, financial crime, risk management, outsourcing, wind-down planning and supporting policies and procedures. We also manage FCA questions through the assessment process, helping ensure that responses remain consistent with the original regulatory strategy and application documents.

Where a business is comparing a new authorisation with acquiring an existing regulated firm, we can assess both options. BCC also works with buyers and sellers of APIs, EMIs and other regulated financial businesses, supports regulatory due diligence and manages FCA Change of Control and post-acquisition regulatory work.

The appropriate cost should be determined from the actual business the founders want to operate rather than from a generic licence package. To discuss an API, AEMI, SPI or SEMI application and obtain a scope based on your proposed business model, contact Buckingham Capital Consulting.

Frequently asked questions

How much is the FCA application fee for an Authorised Payment Institution in 2026?

An API application costs either £2,820 or £5,640 depending on the payment services requested. Applications involving payment services in paragraphs (a) to (e) of Schedule 1 to the Payment Services Regulations fall within the £5,640 Category 5 fee, while applications limited to services in paragraphs (f) to (h) fall within Category 4 at £2,820. The application fee is non-refundable and separate from regulatory capital and all other business setup costs.

How much is the FCA application fee for an Electronic Money Institution?

An application for authorisation as an AEMI falls within FCA pricing Category 5, which is £5,640 in 2026. The FCA fee should not be confused with the €350,000 minimum initial capital requirement. The application fee is paid to the regulator, while regulatory capital remains within the authorised company and must continue to satisfy the applicable own-funds rules.

How much capital is required for an FCA Payment Institution?

The minimum initial capital depends on the payment services provided. Money remittance requires €20,000, payment initiation services require €50,000 and payment services in paragraphs (a) to (e) of Schedule 1, including merchant acquiring and payment account activities, require €125,000. Where several activities apply, the highest relevant initial capital requirement generally determines the minimum rather than adding the individual amounts together.

Is €350,000 the total cost of obtaining an EMI licence?

No. €350,000 is the minimum initial regulatory capital for an AEMI and is not a fee paid to the FCA. The business must separately fund the £5,640 FCA application fee, professional application work, management and compliance, technology, safeguarding and banking arrangements, financial crime systems and sufficient working capital to operate through the authorisation period and after launch.

What is the real total cost of an FCA PI or EMI licence?

There is no single total because the cost depends on the permissions, complexity, existing team, technology and infrastructure required. A realistic budget should separate the FCA fee, regulatory capital, professional support, staffing, technology, banking and safeguarding, compliance systems, insurance where applicable and ongoing regulatory costs. The FCA application fee itself is generally only a small part of the total financial commitment required to establish a viable regulated payment or e-money business.