What is required to become an authorised e-money institution in the UK?

You must satisfy the requirements under the Electronic Money Regulations (EMRs) which include having appropriate governance, capital requirements, risk management, safeguarding (how you protect e-money), AML / CFT controls, reporting obligations, conduct of business standards and complying with the FCA Handbook.

What is the difference between a small EMI and a full authorised EMI?

A 'Small Electronic Money Institution' (SEMI) has reduced requirements under certain regulatory obligations (like lower capital or reporting burden) compared to a full authorised EMI. But both types must meet the core EMR standards for conduct, safeguarding and AML controls. The specific thresholds depend on your business volume and model.

What are safeguarding obligations under EMRs?

Safeguarding refers to how e-money issuers must protect customer funds. You should segregate or otherwise ring-fence customer funds, have proper reconciliation, controls over access, oversight and reporting to ensure that customer funds can be returned even if the business fails.

How often do I need to report to the FCA once authorised as an e-money institution?

Reporting obligations include periodic regulatory returns (financial, accounting, business conduct) and any notifications of material events, changes in circumstances. Frequency and content depend on your authorisation type (full or small), the EMRs, and FCA rules.

Can I use agents or passport the EMoney licence?

Yes. EMIs can use agent networks for certain services, and in some cases passporting or establishing branches or unions with other jurisdictions may be possible depending on legislation and regulatory equivalence. However, you must ensure agents comply with the same regulatory, AML and safeguarding obligations.

What happens if I fail to keep up with EMR compliance obligations after authorisation?

Non-compliance can lead to regulatory action by the FCA, including penalties, fines, enforcement actions, or in severe cases revocation of authorisation. Operational risk and reputational damage are also likely.

eMoney FCA Authorization | Emoney Licence Support

Overview

EMIs issue electronic money (stored value) and provide payment services under the Electronic Money Regulations 2011 and Payment Services Regulations 2017.

Authorisation Process:

Define Scope: Decide between Small Electronic Money Institution (SEMI) and Authorised Electronic Money Institution (AEMI) based on business volume.
Safeguarding Measures: Demonstrate protection of customer funds, typically through segregated accounts or insurance.
Capital Requirement Calculation: Must meet initial and ongoing capital requirements (e.g., €350,000 for AEMI).
Governance & AML Controls: Appoint key individuals and create AML, risk management, and complaints policies.
IT & Operational Resilience: Submit details on platforms, cybersecurity, outsourcing, and incident reporting.
FCA Application Dossier: Submit through FCA Connect, including financial forecasts, organisational chart, and risk framework
FCA Vetting: In-depth assessment of directors, beneficial owners, business model, and financials.
Post-Approval Obligations: Annual reports, safeguarding audits, regulatory returns, and ongoing supervision.

Overview

Authorisation Process:

We cover the following areas under Electronic Money Institutions (EMIs):