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Enabling you to gain access to the UK market and offer electronic money, including electronic wallets and prepaid cards

Small EMI (SEMI) Licence
United Kingdom

Small EMI Licence UK - Small Electronic Money Institution / SEMI Licence UK

If you wish to obtain the Small EMI UK Licence / SEMI UK Licence / Small Electronic Money Institution licence in the UK, you will need to apply to the FCA for registration as a Small EMI UK institution.
Below you will find the key information about obtaining the Small E-money UK Licence / SEMI UK Licence / Small Electronic Money Institution licence in the UK. If you wish to become a Small E-money UK / Small Electronic Money Institution licence in the UK, you must meet the FCA's threshold conditions.
Buckingham Capital Consulting can help you to obtain the Small
 E-money UK Licence / SEMI UK Licence / Small Electronic Money Institution licence in the UK, by offering a full end-to-end service, from company formation to complete licence preparation and management. 

A fully managed end-to-end service

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Company Formation
Safeguarding bank account
Payment System, E-wallets & apps
Visa/MastercardCard Issuing

List of services provided by a Small EMI / Electronic Money Institution Licence

A Small Electronic Money Institution / Small EMI licence enables the licence holder to offer a number of services:

  1. issuing of electronic money e.g. prepaid cards and electronic wallets.

  2. services enabling cash to be placed on a payment account and all of the operations required for operating a payment account;

  3. services enabling cash withdrawals from a payment account and all of the operations required for operating a payment account;

  4. 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;

  5. 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;

  6. issuing payment instruments or acquiring payment transactions;

  7. money remittance;

  8. payment initiation services;

  9. account information services.

Definition of electronic money

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.


The UK regulator for Small Electronic Money Institutions

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.

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

 -  Regulation (EC) No 924/2009

 -  The SEPA Regulation (Regulation (EU) 260/2012

 -  The Payment Accounts Regulations 2015

 -  EU Payment Accounts Directive

 -  Data Protection Act 2018

 -  Guide to the UK General Data Protection Regulation (UK GDPR)

 -  Proceeds of Crime Act 2002 (POCA)

 -  Terrorism Act 2000

 -  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

The UK regulations for Small EMIs

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.

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.

Reasons for choosing the UK for your small EMI registration

     -     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

Key requirements to become a Small Electronic Money Institution in the UK

  1. Evidence that when you start trading your e-money business will not exceed a monthly average outstanding electronic money of €5m.

  2. Evidence that in the past 12 months prior to the application, the monthly average of any payment services transactions did not exceed €3m.

  3. The requirement to safeguard client funds either with a segregated client bank account or with an insurance policy.

  4. The management body of the electronic money institution must be of good repute and possess the relevant qualifications and experience to perform their duties.


Documents required for the Small EMI / Electronic Money Institution application in the UK

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:

  1. company identification details 

  2. programme of operations 

  3. your e-money business in the form of a business plan and financial forecasts 

  4. any payment services you intend to provide

  5. a description of your business’s organisation structure 

  6. measures to safeguard the funds of your users 

  7. compliance & governance arrangements and internal controls 

  8. procedure for monitoring, handling, and following up on security incidents and security-related customer complaints 

  9. processes for filing, monitoring, tracking and restricting access to sensitive payment data 

  10. business continuity measures 

  11. the principles and definitions applicable to the collection of statistical data on performance, transaction and fraud 

  12. your security policy 

  13. internal control mechanisms to comply with obligations in relation to money laundering and terrorist financing (AML/CTF obligations) 

  14. details of your qualifying holdings (shareholders) 

  15. details of any outsourcing arrangements (where applicable)


Our People

Our team of regulatory and compliance experts boasts diverse backgrounds spanning various sectors, providing a holistic understanding of our clients' challenges. With our service being led by seasoned professionals, you'll have direct access to senior experts, often at the director level, ensuring personalised attention. Combining robust regulatory knowledge with commercial insight, our team delves deep into your business to tailor unique solutions specifically suited to your needs.

Seeking something more bespoke or not listed above? Contact us to discuss your unique requirements. With our expertise and experience in financial services, chances are we can assist you effectively.

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