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Why Small Electronic Money Institutions work with us
Specialist focus
We advise firms operating as, or seeking to become, Small Electronic Money Institutions.
Small EMI application support
We help you prepare a focused Small EMI application covering your business model, programme of operations, safeguarding, financial crime controls and governance.
Download our Small EMI registration guide, covering FCA requirements, business model evidence, safeguarding, financial crime controls, governance and common application issues.
How can we help?
Let's discuss
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Fill out our form and we will get back to you, usually within 3 business hours.
List of services provided by a Small EMI / Electronic Money Institution Licence
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A Small Electronic Money Institution / Small EMI licence enables the licence holder to offer a number of services:
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issuing of electronic money e.g. prepaid cards and electronic wallets.
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services enabling cash to be placed on a payment account and all of the operations required for operating a payment account;
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services enabling cash withdrawals from a payment account and all of the operations required for operating a payment account;
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the execution of payment transactions, including transfers of funds on a payment account with the user’s payment service provider or with another payment service provider, including, execution of direct debits, including one-off direct debits; execution of payment transactions through a payment card or a similar device; execution of credit transfers, including standing orders;
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the execution of payment transactions where the funds are covered by a credit line for a payment service user, including, execution of direct debits, including one-off direct debits; execution of payment transactions through a payment card or a similar device; (iii)execution of credit transfers, including standing orders;
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issuing payment instruments or acquiring payment transactions;
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money remittance;
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payment initiation services;
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account information services.
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Definition of electronic money
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Article 2(2) of Directive 2009/110/EC, defines “e-money” as “electronically, including magnetically, stored monetary value as represented by a claim on the issuer which is issued on receipt of funds for the purpose of making payment transaction, and which is accepted by a natural or legal person other than the electronic money issuer”. Accordingly, both prepaid cards and electronic wallets are examples of electronic money.
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The UK regulator for Small Electronic Money Institutions
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The Financial Conduct Authority is the UK’s regulator for financial services, including, consumer credit, payment services, e-money, lending, insurance and investment services. The Financial Conduct Authority is the regulator for 59,000 financial services firms and financial markets in the UK.
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The following laws and regulations are applicable to Electronic Money Institutions in the UK:
- The Financial Services and Markets Act 2000
- The Payment Service Directive (Directive 2015/2366)
- The Electronic Money Regulations 2011
- Directive 2009/110/EC of the European Parliament
- The Payment Service Regulations 2017
- Payments in Euro (Credit Transfers and Direct Debits) Regulations 2012
- The SEPA Regulation (Regulation (EU) 260/2012
- The Payment Accounts Regulations 2015
- EU Payment Accounts Directive
- Guide to the UK General Data Protection Regulation (UK GDPR)
- Proceeds of Crime Act 2002 (POCA)
- Money Laundering, Terrorist Financing and Transfer of Funds 2017
- Regulation on interchange fees for card-based payment transactions (EU) 2015/751
- The Money Laundering and Terrorist Financing Regulations 2019
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The UK regulations for Small EMIs
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The Payment Service Directive 2 or PSD2 for short, is an EU Directive (Directive 2015/2366) that sets requirements for businesses wishing to provide payment services. It applies to banks, building societies, payment institutions, e-money institutions and their customers.
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The PSD2 directive aims to promote innovation within the payments sector and improve protection for consumers, whilst making payments both safer and more secure. The PSD2 directive came into force on 13 January 2018.
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Reasons for choosing the UK for your small EMI registration
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- World’s fifth-largest economy
- Low corporation tax rate
- Low business costs
- Business tax relief of up to 230% on research and development
- Access to a highly-skilled workforce
- Strong fintech growth and investment
- Strong reputation in financial services
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Key requirements to become a Small Electronic Money Institution in the UK
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Evidence that when you start trading your e-money business will not exceed a monthly average outstanding electronic money of €5m.
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Evidence that in the past 12 months prior to the application, the monthly average of any payment services transactions did not exceed €3m.
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The requirement to safeguard client funds either with a segregated client bank account or with an insurance policy.
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The management body of the electronic money institution must be of good repute and possess the relevant qualifications and experience to perform their duties.
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Documents required for the Small EMI / Electronic Money Institution application in the UK
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As part of the Small Electronic Money Institution (SEMI) licence application, you will be required to provide the following information as part of your application:
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company identification details
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programme of operations
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your e-money business in the form of a business plan and financial forecasts
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any payment services you intend to provide
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a description of your business’s organisation structure
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measures to safeguard the funds of your users
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compliance & governance arrangements and internal controls
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procedure for monitoring, handling, and following up on security incidents and security-related customer complaints
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processes for filing, monitoring, tracking and restricting access to sensitive payment data
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business continuity measures
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the principles and definitions applicable to the collection of statistical data on performance, transaction and fraud
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your security policy
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internal control mechanisms to comply with obligations in relation to money laundering and terrorist financing (AML/CTF obligations)
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details of your qualifying holdings (shareholders)
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details of any outsourcing arrangements (where applicable)
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EMI licence success stories
Project: Dzing Financial
Overview
Dzing Financial approached us to help them obtain their EMI authorisation and establish a robust compliance framework. They needed comprehensive support to ensure they met all regulatory requirements and could operate smoothly in the competitive financial markets of the UK and Europe. Our goal was to provide end-to-end assistance, from application submission to ongoing compliance management.
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Scope of our work
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Comprehensive application preparation and submission.
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Development of compliance policies and procedures.
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Risk assessment and mitigation planning.
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Integration of anti-money laundering (AML) systems.
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Staff training on regulatory compliance.
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Outcomes delivered
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Successfully secured EMI authorisation from the FCA.
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Implemented a comprehensive compliance framework tailored to regulatory requirements.
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Enhanced risk management processes to ensure ongoing compliance.
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Integrated advanced AML systems to prevent financial crimes.
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Equipped staff with the knowledge and tools to maintain compliance.
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Conclusion
By partnering with us, Dzing Financial was able to navigate the complex EMI authorisation process efficiently and effectively. Our comprehensive support ensured they not only met all regulatory requirements but also established a solid foundation for future growth. The value delivered included a seamless authorisation process, robust compliance measures, and improved operational readiness, positioning Dzing Financial for long-term success.
Overview
Hryze sought our expertise to guide them through the small EMI authorisation process and provide ongoing compliance support. As a growing e-money institution, they needed a clear regulatory roadmap and comprehensive compliance strategies to ensure sustainable growth and regulatory adherence in the UK and European markets.
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Scope of our work
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Detailed project planning and regulatory roadmap development.
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Preparation and submission of EMI authorisation application.
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Compliance audit and gap analysis.
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Implementation of compliance monitoring systems.
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Continuous compliance advisory and support.
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Outcomes delivered
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Achieved successful EMI authorisation, enabling market entry.
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Developed a clear regulatory roadmap, ensuring smooth compliance.
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Identified and addressed compliance gaps through a thorough audit.
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Implemented effective monitoring systems for ongoing regulatory adherence.
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Provided continuous support, ensuring Hryze stays compliant and up-to-date with regulations.
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Conclusion
With our guidance, Hryze successfully obtained EMI authorisation and established a strong compliance framework. Our ongoing support ensured they could navigate the regulatory landscape with confidence. The value delivered included a successful authorisation, effective compliance strategies, and the ability to focus on growth while maintaining regulatory adherence.​
Project: Hryze
Project: Europanpay
Overview
Europanpay required assistance in obtaining EMI registration and enhancing their compliance and operational frameworks. As an emerging player in the e-money sector, they needed support in navigating the regulatory requirements and implementing efficient operational processes to ensure compliance and support their growth ambitions.
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Scope of our work
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EMI registration application preparation and submission.
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Creation of robust compliance policies and procedures.
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Financial management support, including reporting and audits.
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Integration of technology solutions for compliance and operations.
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Ongoing compliance and regulatory support.
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Outcomes delivered
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Successfully obtained EMI registration, allowing Europanpay to expand.
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Established strong compliance policies and procedures.
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Improved financial management practices, ensuring regulatory compliance.
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Integrated advanced technology solutions to streamline operations.
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Provided ongoing support, maintaining regulatory compliance and operational efficiency.
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Conclusion
Through our comprehensive support, Europanpay was able to achieve EMI registration and enhance their operational and compliance frameworks. The value delivered included a smooth authorisation process, robust compliance and financial management practices, and the integration of technology solutions that supported their growth and operational efficiency. Europanpay is now well-positioned to thrive in the competitive e-money sector.
Specialists in FCA EMI registration applications and
compliance since 2013
Every engagement is led at director level. You work directly with the senior practitioners preparing your application, not a delegated team. Buckingham Capital Consulting has focused on FCA payments and e-money registration applications since 2013, with proven outcomes across e-wallet issuers, prepaid card programmes, virtual IBAN platforms, Banking-as-a-Service providers, foreign exchange firms, and money remittance operators. Our consultants combine technical command of the Electronic Money Regulations 2011 with direct insight into the FCA's review standards, ensuring applications meet the regulator's expectations at first submission.
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