Authorised Electronic Money Institution (AEMI) (United Kingdom)

At a glance

What it lets you do, and where

What does a UK Authorised Electronic Money Institution licence let you do, and where can you serve clients?

A UK AEMI licence lets you issue e-money and, under EMRs Reg 32, carry on payment services, ancillary services, payment systems and other business. Passporting is not available: the FCA Approach Document Chapter 6 confirms the UK's participation in the passporting regime ended on 31 December 2020, and Schedule 2 paragraph 10 of the Electronic Money, Payment Services and Payment Systems (Amendment and Transitional Provisions) (EU Exit) Regulations 2018 revoked passporting rights.²⁶⁹²⁷

Activities it covers

Where it is valid

Do you need it, and is United Kingdom the right choice?

What is a UK Authorised Electronic Money Institution licence and do you actually need one?

An Authorised Electronic Money Institution (AEMI) is an EMI authorisation under the Electronic Money Regulations 2011 (SI 2011/99). EMRs 2011 Reg 5 sets the application for EMI authorisation or variation. The Payment Services Regulations 2017 (SI 2017/752) Schedule 1 defines the authorised payment services scope. FCA guidance distinguishes AEMI status from Small EMI based on €5m average outstanding e-money and €3m monthly turnover.⁸²⁸²⁹

Is a UK AEMI the right licence for your model, and when is the UK the wrong choice?

An AEMI authorises e-money issuance and payment services under EMRs 2011 and PSRs 2017. A Small EMI is available under EMRs 2011 Regulation 13, which sets conditions and financial ceilings. Payment-only models fall under PSRs 2017 Regulation 6 authorisation as a payment institution. The FCA Authorisations Guide requires applicants to be ready, willing and organised to comply with regulatory standards.³⁰³¹²⁵

Small EMI or full Authorised EMI in the UK, what happens above the statutory limits?

EMRs 2011 Regulation 13 sets registration criteria and a €5m average outstanding e-money ceiling for Small EMIs. Under EMRs 2011 Regulation 16, a small electronic money institution must apply for full authorisation within 30 days of becoming aware of a change in circumstances. FCA authorisation fees set Small EMI registration at Category 3 (£1,130) and Authorised EMI at Category 5 (£5,640).³⁰³²¹⁵

What happens to customer money if a UK EMI fails, does safeguarding protect it?

Safeguarding duties are set out in EMRs 2011 Regulation 24(1), (2), (4) and (5), and FCA CASS 15 handbook rules cover records, accounts and reconciliations. However, the Court of Appeal held in Ipagoo LLP [2022] EWCA Civ 302 that the EMRs create no statutory trust over safeguarded funds, so that protection does not take the form of a trust.³³³⁴

Can a UK AEMI issue its own IBANs and access payment systems directly?

The Bank of England Settlement Account policy outlines direct clearing criteria for non-bank payment service providers. The European Payments Council confirms UK payment institutions remain eligible participants in SEPA schemes post-Brexit. A Mambu guide details that becoming a SEPA indirect participant requires regulatory tasks, commercial selection of a sponsor bank, and technical integration.³⁵³⁶³⁷

Do you need your own Visa/Mastercard principal membership or is a BIN sponsor enough?

Visa and Mastercard Principal Members hold direct network connections and settlement risk, while associate members rely on a sponsoring Principal Member. An Enfuce analysis confirms BIN sponsorship suits companies prioritising rapid card product launch, speed and lower operational complexity over direct licensing.³⁸³⁹

What is changing under the UK safeguarding reform (CASS 15) vs EU PSD3?

The FCA Payments and Electronic Money (Safeguarding) Instrument 2025 (FCA 2025/38) brings CASS 15 into force on 7 May 2026. The European Parliament and Council struck a political deal on the EU payment services package (PSD3 and PSR) on 27 November 2025. CASS 15 requires internal safeguarding reconciliation at least once each reconciliation day.¹²⁴⁰

What it really takes

How much capital do you really need for a UK Authorised Electronic Money Institution?

Initial capital for an authorised electronic money institution is €350,000 under EMRs 2011 Schedule 2 Part 1 Paragraph 2. Ongoing own funds use Method D, defined as 2% of average outstanding electronic money under EMRs 2011 Schedule 2 Part 2 Paragraph 23. FCA guidance on preparing financial information advises submitting 3 years of forecasts in Excel format as best practice.⁴¹⁴²

Who do you have to hire for a UK AEMI, and where must they be based?

EMRs 2011 Regulation 6(4)(a) requires a UK body corporate with its head office and, if it has one, its registered office in the UK; Regulation 6(4A) requires carrying on at least part of its business in the UK. The FCA Approach Document Section 3 requires directors and persons responsible for AML and management to be of good repute and appropriate experience. The Barclay Simpson 2026 Salary Guide records Head of Financial Crime / MLRO salaries of £150k to £300k.¹⁹⁴³

Applications must be submitted to the FCA through the Connect portal in English, as its portal terms and application procedures require. Separately, FCA application guidance, not EMRs Schedule 1, requires criminal-check evidence to be available in English on request.⁴²²⁵

Application contents are governed by EMRs 2011 Regulation 5 and Schedule 1, and the FCA's EMI application guidance details the required supporting materials, financial spreadsheets and individual forms.¹⁰²⁹

The legal framework

The procedure under the law

How long it takes

How long does getting a UK Authorised Electronic Money Institution licence really take?

Under EMRs 2011 Regulation 9, statutory decision deadlines are 3 months from a complete application and 12 months from an incomplete one. According to FCA Authorisations Operating Service Metrics (Q4 2025/26), median determination time for payment services and e-money applications is 207 calendar days (interquartile range 124 to 269 days).⁴⁴⁴⁵

The FCA must determine a complete AEMI application within 3 months under EMRs 2011 Regulation 9(1). Where the application is incomplete, Regulation 9(2) sets a 12-month determination deadline. FCA Authorisations Operating Metrics confirm that the statutory clock is keyed to complete applications, subject to case officer requests.⁴⁴⁴⁵

Statutory: 3 months from receipt of a complete application, or 12 months from receipt of an incomplete application under Regulation 9 of EMRs 2011². Observed: Median elapsed determination time of 207 calendar days (Lower Quartile: 124 days, Upper Quartile: 269 days) across 44 payment services and e-money applications (PS1-4) determined in Q4 2025/26⁵. The statutory clock usually starts only when the regulator treats the application as complete, and pauses while it waits for answers to its questions.

What it costs

What does a UK Authorised Electronic Money Institution licence cost in total?

The FCA application fee for an Authorised Electronic Money Institution is £5,640 (Category 5). Under FCA FEES 4 Annex 11R (Instrument FCA 2026/34), the G.10 periodic minimum fee is £2,063 plus a variable tariff on average outstanding e-money. The FCA Payments and Electronic Money (Safeguarding) Instrument 2025 requires an independent annual audit under SUP 3A for balances over £100,000.¹⁵¹⁷¹²

Approval odds and who can own it

What are the real approval odds for a UK AEMI, and why do applications fail?

Approval odds are low but improving: FCA data shows EMI approval at between 15% and 20% in 2023 and in 2024, rising to between 40% and 45% in 2025. Under EMRs 2011 Regulation 9(3), applicants may withdraw an application before it is determined.²⁹⁴⁴

Directors and managers must be of good repute and have appropriate knowledge and experience (EMRs 2011 Regulation 6(6)(b)). Under FSMA s.189(1), the appropriate regulator must act under s.185 within a 60 working-day assessment period, which begins when it acknowledges a section 178 notice.¹⁹²³

After you get the licence

Three further regimes apply alongside a UK AEMI licence. The FCA is opening an FSMA Part 4A authorisation gateway for cryptoasset firms, running from 30 September 2026 to 28 February 2027. Payment Systems Regulator Specific Requirement 1 mandates APP fraud reimbursement up to £85,000 effective 7 October 2024. FCA Principle 12 Consumer Duty rules apply to all payments and e-money institutions serving UK retail consumers.⁴⁶⁴⁷⁹

Will a UK Authorised Electronic Money Institution get a bank account and payment processing?

Banking access is not guaranteed. The FCA Approach Document Chapter 16 confirms banks have no absolute obligation to grant payment accounts to payment institutions, as access remains a commercial decision. For card processing, Visa and Mastercard Principal Membership is a direct licence giving financial institutions ownership of BINs and direct settlement capabilities.⁹³⁸

To keep the licence, FCA SUP 16 requires electronic regulatory reporting through the Gabriel/RegData online system, with frequencies including annual returns such as FIN060a and FIN060b. The FCA can cancel authorisation under EMRs 2011 Regulation 10 if the business does not start within 12 months or ceases for 6 months. What is changing is the FCA Payments and Electronic Money (Safeguarding) Instrument 2025 (FCA 2025/38), which brings CASS 15 into force on 7 May 2026.⁴⁸¹²

Yes. Before a refusal takes effect, the FCA Authorisation Refusal Process lets you make representations at the Warning Notice stage, followed by a Decision Notice if the refusal is maintained. Under EMRs 2011 Regulation 9(6) to (8) and Regulation 70, you can refer the decision to the Upper Tribunal. Upper Tribunal Rules 2008 Schedule 3 paragraph 2(2) sets a 28-day deadline to lodge the reference from the decision notice.⁴⁹⁴⁴⁵⁰

Prior approval is required for qualifying holding changes crossing 10%, 20%, 30%, or 50% under FSMA Part XII (Sections 178 to 191G), and to add or alter payment permissions through a formal Connect application. Under EMRs 2011 Regulation 10, authorisation may be cancelled if e-money is not issued within 12 months of authorisation, or business ceases for more than 6 months.⁴⁸²³⁵¹

EMI, PI or a banking licence in the UK, which do you need?

It turns on the activities. FSMA 2000 Part 4A Section 55A governs statutory applications for permission to carry on regulated financial activities. EMRs 2011 Regulation 2 and PSRs 2017 Regulation 2 set the statutory boundary between payment services and e-money issuance, and FCA PERG 3A and PERG 15 define the activity perimeters for e-money versus payment institutions.⁵²⁵³⁵⁴

Why won't UK clearing banks open a safeguarding account for a licensed EMI?

Banks decide case by case: the FCA Approach Document Chapter 16 says credit institutions assess PSP payment account access individually, not by category. The EBA Opinion on de-risking (EBA/Op/2022/01) covers refusal of entire categories of customers, including payment institutions, and says this can be unwarranted and a sign of ineffective ML/TF risk management.⁹⁵⁵

Buying a company that already holds it

Prior approval required. Acquirers must obtain FCA approval prior to acquiring or increasing control in an FCA or PRA authorized firm; acquiring control without approval constitutes a criminal offence under FSMA 2000 Section 191F. For Directive firms (including banks, MiFID investment firms, UCITS Mancos, payment institutions, and electronic money institutions), control thresholds are 10%, 20%, 30%, and 50% of shares or voting rights, or becoming a parent undertaking. For non-Directive firms (such as non-MiFID investment firms, general insurance intermediaries, and full-scope AIFMs), a single 20% or more threshold applies. For cryptoasset firms under MLRs Schedule 6B (amended 30 June 2026), a 25% beneficial owner threshold applies, alongside FSMA bands if no beneficial owner exists. The statutory assessment period is 60 business days from complete notification acknowledgment (FSMA Section 189), pausable once for up to 30 business days if further information is requested.⁶

Ready-made companies holding this licence: see verified positions.

EMI in other countries

Values come from each licence's page, where every figure has its source.

Laws behind it

• The Electronic Money Regulations 2011: S.I. 2011/99