The State of Licensing 2026: Payments, E-Money and Crypto Authorisations in Numbers
By Harry Khan, Founder · Published 21 October 2026 · Last reviewed 21 October 2026
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The State of Licensing is an annual report by Buckingham Capital Consulting on the authorisation of payment, e-money, cryptoasset and money transmission businesses. It sets out how many firms apply, how many are approved, how long regulators take and what they charge, across the United Kingdom, the European Union, the United States and the main Asian and Gulf markets.
Every figure is taken from a regulator's own publication: freedom of information responses, operating metrics, registers, fee rules and legislation. Each one carries its date, and the source is listed in the references. Where a regulator does not publish a figure, the report says so rather than estimating. Facts were read on 21 October 2026, and the report is reviewed when a regulator publishes new data.
The report is written for the people who plan a licence: founders, chief executives, compliance leads, investors and the banks that serve regulated firms. It is free to cite with a link to this page.
The FCA authorises e-money institutions (EMIs) and payment institutions (PIs) under the Electronic Money Regulations 2011 and the Payment Services Regulations 2017. Its freedom of information responses give the clearest picture of what happens to an application.
Demand has settled well below the 2021 peak. The FCA received 174 EMI and PI applications in 2021, 119 in 2022 and 116 in 2023. For authorised EMIs alone, 133 applications arrived between the first quarter of 2023 and the second quarter of 2025, between 9 and 18 a quarter.
| Year | EMI applications (authorised and small) | PI applications (authorised) |
|---|---|---|
| 2021 | 105 | 69 |
| 2022 | 63 | 56 |
| 2023 | 70 | 46 |
Over ten financial years to March 2024 the FCA approved 342 authorised EMI applications and saw 217 withdrawn. Only one was formally refused and five rejected. The balance has shifted sharply since 2022: in the year to March 2023, 11 approvals stood against 77 withdrawals, and in the year to March 2024, 16 against 41.
| Financial year | Authorised EMI approved | Authorised EMI withdrawn |
|---|---|---|
| 2018-19 | 103 | 12 |
| 2019-20 | 30 | 9 |
| 2020-21 | 40 | 13 |
| 2021-22 | 28 | 54 |
| 2022-23 | 11 | 77 |
| 2023-24 | 16 | 41 |
The cohort view is the one to plan on. Of the 133 authorised EMI applications received from the start of 2023 to mid-2025, 20 had been approved, 9 rejected and 72 withdrawn by mid-2025, with 32 still in progress. Small EMI registrations closed in the same period show 0 registered, 7 rejected and 19 withdrawn.
Across all payment and crypto categories the FCA recorded 409 withdrawn applications in 2022 and 206 in 2023. In 2022 that included 180 small payment institution and 78 cryptoasset applications.
Licences given up at the firm's own request peaked at 138 in 2022 and 139 in 2023, then eased to 95 in 2024 and 39 in 2025 to mid-October. The FCA itself removed 15 licences in 2025, 13 of them small payment institutions.
What the figures say is simple: the FCA decides few applications against the applicant, and most applications that do not succeed are withdrawn before a decision, usually after the FCA's questions show the business is not ready. The work that decides the outcome is done before submission. Our UK EMI licence and UK payment institution licence guides set out what the FCA looks for.
The statutory standard for payment and e-money authorisations is a decision within three months of a complete application, or ten months of an incomplete one, in 95% of cases. The FCA's own operating metrics for April to June 2026 show 38 payment and e-money cases closed, 7 of them past the deadline: 81.6% within standard, up from 72.1% and 72.7% in the two previous quarters, and still short of the target.
| Measure, April to June 2026 | Payment and e-money authorisations | New firm authorisation (all sectors) |
|---|---|---|
| Cases closed | 38 | 287 |
| Within statutory deadline | 81.6% | 92.0% |
| Median end-to-end days | 219 | 131 |
| Upper quartile days | 268 | 190 |
A median of 219 days is a little over seven months from submission to decision, which is why we plan EMI and PI authorisations at six to eight months after submission. Variations of permission for existing payment firms ran faster: 8 cases closed, all within deadline, median 164 days. Agent notifications, 1,652 of them in the quarter, were all closed within the two-month standard.
FCA application fees follow a ten-category pricing table, updated on 30 September 2026. The regulator's fee is small next to the capital a firm must hold and the cost of building the business the FCA expects to see.
| Application | FCA fee | Minimum initial capital |
|---|---|---|
| Authorised EMI | £5,640 | €350,000 |
| Small EMI | £1,130 | None set by the EMRs |
| Authorised PI, services (a) to (e) | £5,640 | €125,000 |
| Authorised PI, money remittance only | £2,820 | €20,000 |
| Authorised PI, payment initiation only | £2,820 | €50,000 |
| Small PI or registered AISP | £1,130 | None |
| Cryptoasset MLR registration | £11,260 | Not applicable |
Varying an EMI authorisation to add services costs half the category 5 fee, £2,820; varying a PI authorisation costs £1,410. An authorised PI's ongoing own funds under Method B are 4% of the first €5 million of monthly payment volume, falling in bands to 0.25% above €250 million.
From 7 May 2026 every firm that safeguards customer money has been under the FCA's CASS 15 rules. On 10 October 2025 that population was 695 firms: 384 authorised payment institutions, 275 e-money institutions and 36 small payment institutions that opted in. Firms that have held more than £100,000 of relevant funds at any point in the year must arrange an annual safeguarding audit and submit it within four months of the period end. Our safeguarding page covers the regime.
Since January 2020 cryptoasset firms have registered with the FCA under the money laundering regulations. The numbers show a market that has largely sorted itself: applications fell from 195 in 2020 to 20 in 2025, and the FCA approved 62 in six years. Of the 2020 cohort, 147 were withdrawn.
| Year | Applications received | Approved (average days to approval) |
|---|---|---|
| 2020 | 195 | 36 (465) |
| 2021 | 63 | 4 (496) |
| 2022 | 51 | 4 (321) |
| 2023 | 28 | 4 (378) |
| 2024 | 29 | 8 (243) |
| 2025 | 20 | 6 (217) |
The regime is now changing. The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 were made on 4 February 2026, the FCA published its final rules on 30 June 2026, and the application gateway opened on 30 September 2026. It closes on 28 February 2027. The new regime starts on 25 October 2027.
Three points matter for every firm on the current register. There is no automatic conversion: a registered firm must apply for and obtain FSMA authorisation. A firm that applies inside the window may keep trading until its application is decided. A firm that does not apply must wind down its UK business before 25 October 2027. Fees for the new activities run from £2,820 for arranging deals to £11,260 for dealing as principal, safeguarding or issuing a qualifying stablecoin and £28,150 for operating a trading platform. Our UK cryptoasset authorisation guide sets out the application.
The grandfathering period under the Markets in Crypto-Assets Regulation ended on 1 July 2026. ESMA's interim register, last updated on 31 August 2026, lists 377 active crypto-asset service providers (CASPs). 216 of those entries were authorised or notified in 2026, 146 in 2025 and 4 in 2024, so most of the EU's licensed crypto sector is less than two years old. ESMA's separate list of non-compliant entities carries 178 names.
| Home Member State | Active CASP entries |
|---|---|
| Germany | 109 |
| France | 36 |
| Netherlands | 28 |
| Cyprus | 24 |
| Malta | 23 |
| Spain | 16 |
| Luxembourg | 13 |
| Austria, Czechia, Ireland, Liechtenstein, Latvia | 12 each |
| Italy | 10 |
| Lithuania | 6 |
Twenty-five issuers hold e-money token (stablecoin) entries, led by the Netherlands with 10 entries, France with 8 and Germany with 6. Our MiCA CASP authorisation and stablecoin licensing guides cover the routes.
Lithuania supervises 80 EMIs and 43 PIs. Its state levy is €1,463 for an EMI licence and €898 for a PI licence, with a statutory examination period of three months from a complete file. Cyprus lists 32 licensed EMIs, four of them authorised in 2026, and 10 PIs; its EMI application fee is €10,000 after a €5,000 pre-application stage. Ireland's registers show 29 authorised EMIs and 26 authorised PIs, and 12 CASPs authorised under MiCA since June 2025. Malta's regulator processed 1,094 applications across all sectors in 2025, approving 1,023, but does not publish payments figures separately.
A US money transmitter registers once with FinCEN, the federal financial crime agency, and is then licensed by each state in which it serves customers. The two layers are different in scale.
FinCEN's registrant list, counted on 21 October 2026, holds 34,276 money services businesses. 23,428 of them are registered as money transmitters, 27,166 as check cashers and 8,599 as dealers in foreign exchange. Registration lasts two calendar years, and the list shows 10,176 money transmitter registrations signed in 2025 and 6,873 so far in 2026. 1,211 registrants give a location outside the United States. Registration is free and carries no capital requirement; it is not a licence, and our FinCEN MSB registration guide explains what it does and does not permit.
The state layer is far smaller and far more concentrated. NMLS, the licensing system used by 49 states, reported for 2024 that 599 companies held 8,858 approved money transmitter licences, an average of 15 states each. Those companies reported $4.06 trillion of money transmission in the year. Virtual currency exchange companies in the system numbered 149, averaging 29 states each.
| State | Application fee | Surety bond |
|---|---|---|
| Texas | $10,000 | $100,000 to $500,000 |
| California | $5,000 | Set by statute, not stated on the regulator's page |
| New York | $3,000 | Set by regulation, not stated on the regulator's page |
| Washington | $1,000 | $10,000 to $550,000 by volume |
| Florida | $375 | $50,000 to $2 million |
Texas requires tangible net worth of the greater of $100,000 or 3% of total assets for firms under $100 million of assets; Florida requires $100,000 plus $10,000 per additional location; Washington sets net worth at $10,000 per $1 million of annual volume up to $3 million. Our US money transmitter licence guide covers the state-by-state plan.
The GENIUS Act, enacted on 18 July 2025, creates a federal licence for payment stablecoin issuers. The Treasury's proposed rule of 17 August 2026 gives the expected effective date as 18 January 2027, from which a person may not issue a payment stablecoin in the United States without a federal or state licence. From 18 July 2028 digital asset service providers may only offer stablecoins from licensed issuers. The OCC's application rules were proposed in February 2026 and neither set of rules was final at the date of this report.
Singapore's directory lists 245 major payment institutions and 13 standard payment institutions, the largest licensed payments population in Asia. Dubai's VARA register shows 59 active virtual asset service provider licences, 18 of them issued in 2026. Hong Kong's SFC has licensed 13 virtual asset trading platforms, the latest in May 2026. AUSTRAC records 5,112 registered remitters and 417 digital currency exchanges in Australia, and has cancelled, suspended or refused renewal to 9 since January 2024. Canada's FINTRAC does not publish a total count of registered money services businesses; registration carries no fee.
| Market | Register count | What is counted |
|---|---|---|
| Singapore (MAS) | 245 | Major payment institutions |
| Dubai (VARA) | 59 | Active VASP licences |
| Hong Kong (SFC) | 13 | Licensed virtual asset trading platforms |
| Australia (AUSTRAC) | 5,112 | Registered remitters |
| Lithuania (Bank of Lithuania) | 80 | Supervised EMIs |
Four conclusions follow from the data.
In the UK the application is decided by readiness, not by the regulator's appetite. The FCA refuses or rejects a handful of e-money applications a year. The 72 withdrawals in the recent cohort are firms that submitted before the business, the people and the safeguarding arrangements could stand up to questions. A firm that submits a complete application with the capital in place, the MLRO and directors appointed and the safeguarding account arranged is planning on the 219-day median, not on a withdrawal.
The UK crypto window is short and final. Five months, 30 September 2026 to 28 February 2027, with no conversion for registered firms and a wind-down for those that miss it. Firms that have not started should treat the application as the business priority for the winter.
In the EU the question is which Member State, not whether. With 377 CASPs authorised and grandfathering over, a new entrant is competing with licensed firms from day one. Germany, France and the Netherlands hold the largest populations; Lithuania and Cyprus remain the fastest-growing EMI centres on fee and timeline.
In the US the licence is a programme, not an event. The average money transmitter holds 15 state licences, each with its own fee, bond, net worth and reporting cycle, and the GENIUS Act adds a federal issuer licence from January 2027. Firms that plan the state sequence from the outset, starting with the states where their customers are, reach national coverage at a fraction of the cost of licensing all fifty at once.
Buckingham Capital Consulting has obtained more than 250 licences and registrations in more than 60 countries since 2013. Send us the business, the countries and the date you need to be live, and you will have a written proposal the same day.
16 authorised EMI applications were approved in the year to March 2024 and 11 the year before, against 41 and 77 withdrawn. The FCA refused one and rejected five across ten years; withdrawal is the usual outcome for an application that does not succeed.
The FCA's own metrics for April to June 2026 give a median of 219 days from submission to decision, with an upper quartile of 268 days, and 81.6% of cases closed within the statutory deadline.
£5,640 for an authorised EMI or a full-scope authorised PI, £2,820 for a money remittance, payment initiation or account information PI, and £1,130 for a small PI, small EMI or registered AISP, under FCA fee rules updated on 30 September 2026.
28 February 2027. It opened on 30 September 2026, the new regime starts on 25 October 2027, and firms registered under the money laundering regulations are not converted automatically.
ESMA's interim register listed 377 active crypto-asset service providers at its 31 August 2026 update, led by Germany with 109, France with 36 and the Netherlands with 28.
FinCEN's list holds 23,428 registered money transmitters among 34,276 money services businesses. At state level, NMLS reported 599 companies holding 8,858 money transmitter licences for 2024.
The Treasury's proposed rule gives 18 January 2027 as the expected date from which a payment stablecoin may not be issued in the United States without a licence, and 18 July 2028 for the restriction on offering unlicensed stablecoins.
Yes. Cite it as the BCC State of Licensing 2026 with a link to this page. Every figure is sourced to the regulator's own publication in the references.
Buckingham Capital Consulting has obtained more than 250 licences and registrations for payment, e-money and cryptoasset firms in more than 60 countries since 2013, including FCA authorisations for Nexpay, Orbital, Oval, Dzing Finance and Hryze and a Central Bank of Ireland EMI authorisation for Own Solutions. The State of Licensing is published each year from regulators' own data.
Speak to an expert: WhatsApp +44 7563 115980, Telegram @buckinghamcapital or [email protected].
This article is general information, not legal advice. Requirements change, and the regulator’s own publications take precedence.