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Top 3 reasons why the FCA could refuse your EMI or API authorisation application

As the financial landscape continues to evolve, securing authorisation from the FCA is a crucial step for any business operating in the Electronic Money Institution (EMI) or the Authorised Payment Institution (API) sectors.

The Financial Conduct Authority (FCA) plays a pivotal role in ensuring the integrity and security of financial services in the UK. However, obtaining FCA authorisation can be a complex and rigorous process, and there are certain pitfalls that applicants should be aware of.

In this article, we will explore the top three reasons why the FCA could refuse your Electronic Money Institution or Authorised Payment Institution authorisation application and how Buckingham Capital Consulting can assist you in navigating these challenges.

1. Insufficiently Skilled Key Personnel

One of the most common reasons for application rejection is the inadequacy of key personnel, including directors, compliance officer and/or the Money Laundering Reporting Officer (MLRO). The FCA places great emphasis on the qualifications, skills, knowledge, and experience of these individuals. It is imperative that they possess a deep understanding of financial regulations, anti-money laundering (AML) procedures, and risk management.

How Buckingham Capital Consulting Can Help

As part of our service, we offer our clients to access our database of highly qualified and experienced candidates. Clients can either manage the hiring process themselves or we can offer them a managed service where out team can manage the entire hiring process. In doing so, our clients have the assurance that their key people will meet the requirements set out by the FCA. We can also offer comprehensive training and guidance to your key personnel, ensuring they meet the FCA's stringent requirements. We work closely with them to enhance their expertise, enabling your application to meet the FCA's expectations.

2. Neglecting the Implications of the Consumer Duty

With the introduction of the Consumer Duty, firms seeking authorisation must demonstrate a clear understanding of its implications. This includes delivering products and services that prioritise consumer interests and align with the duty's core principles, including fair value, good customer support, customer understanding and avoiding harm. Neglecting to address the Consumer Duty adequately in your application can result in rejection.

Buckingham Capital Consulting has delivered a number of Consumer Duty projects to a range of banks, Electronic Money Institutions, Authorised Payment Institutions, and retail firms. We are therefore well positioned and can provide tailored guidance on incorporating the Consumer Duty into your business model and application. Our experts offer valuable insights to help you align your products and services with this new regulatory framework, ensuring your application reflects your commitment to consumer protection.

3. Inadequate Safeguarding of Client Funds

The FCA places great importance on safeguarding client funds to protect consumers from financial loss. An application that lacks a robust plan for safeguarding client funds may be rejected. It is vital to demonstrate that your firm has appropriate measures in place to protect client funds in all circumstances.

How Buckingham Capital Consulting Can Help

Buckingham Capital Consulting works with all the major leading banks that provide agency banking and specialist services for Electronic Money Institutions and Authorised Payment Institutions. We can introduce you to our partner banking partners to help arrange client safeguarding accounts and help you segregate clients funds. We usually reach out to our partner banks early in the application preparation process to ensure no delays occur.

We assist applicants in developing and implementing rigorous client fund safeguarding measures. Our consultants work closely with clients to ensure compliance with the FCA's requirements, minimising the risk of application refusal.


Obtaining EMI or Authorised Payment Institution authorisation from the FCA demands meticulous preparation and a deep understanding of regulatory requirements. At Buckingham Capital Consulting, our mission is to empower your business with the knowledge and expertise needed to navigate these challenges successfully. We offer tailored solutions that align with your unique needs and structure, ultimately increasing the likelihood of a successful FCA authorisation application.

For more information on how we can assist you in achieving your regulatory goals, please don't hesitate to contact us on 0207 866 2512 or


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