Head-to-head comparison

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Crypto (CASP) E-Money (EMI)

Dimension	🇬🇧 United Kingdom Verified 2026-07-02	🇱🇹 Lithuania partly open Verified 2026-07-02
Licence type	Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011. Verified 2026-07-02 Source: EMRs 2011 / FCA	EMI licence (unrestricted) or Restricted EMI, via the Bank of Lithuania. Verified 2026-07-02 Source: Bank of Lithuania
Regulator	Financial Conduct Authority (FCA). Verified 2026-07-02 Source: FCA	Bank of Lithuania (Lietuvos bankas). Verified 2026-07-02 Source: Bank of Lithuania
Capital requirement	AEMI GBP 350,000 initial plus own funds 2% of average outstanding e-money. SEMI no initial capital, capped below EUR 5m outstanding. Verified 2026-07-02 Source: FCA
Timeline to authorisation	About 6 to 12 months including pre-application (statutory 3 months from a complete application). Verified 2026-07-02 Source: estimate
Local substance	UK entity with UK mind and management, MLRO, adequate local staffing. Verified 2026-07-02 Source: FCA
Application cost	FCA application fee (order of GBP 5,000 for AEMI) plus roughly GBP 75k to 200k professional. Verified 2026-07-02 Source: FCA fees + estimate
Ongoing cost	FCA periodic fees, annual safeguarding audit, compliance headcount. Verified 2026-07-02 Source: FCA
Passporting	None after Brexit, no EEA passport. Verified 2026-07-02 Source: FCA
EMIs authorised	Around 338 e-money firms on the FCA register including small EMIs, the largest EMI population in Europe. Verified 2026-07-02 Source: thebanks.eu directory, cross-checked to FCA register and EBA register
Key restrictions	No interest on e-money, no deposit-taking; a SEMI cannot provide AIS or PIS. Verified 2026-07-02 Source: EMRs 2011
Safeguarding	Segregation or insurance or comparable guarantee. FCA Supplementary safeguarding regime in force 7 May 2026 (monthly reporting, annual safeguarding audit, enhanced reconciliation, resolution pack; audit exemption below GBP 100k). Stage 2 CASS-style statutory trust to follow. Verified 2026-07-02 Source: FCA PS on safeguarding
Recent changes	FCA safeguarding reform live from 7 May 2026; HM Treasury payments-law reform expected later in 2026. Verified 2026-07-02 Source: FCA	PSD3 and PSR merge the payment institution and EMI regimes into one payment institution licence that can issue e-money. Final texts published 23 Apr 2026, OJ expected mid to late 2026, PSR applies about 20 days after publication, PSD3 transposition within 18 months (applicability ~Q2/Q3 2028). Existing EMIs are grandfathered but must update their file. Continued AML tightening. Verified 2026-07-02 Source: EU
Difficulty rating	4. Rigorous on financial crime and safeguarding, very large market. Verified 2026-07-02 Source: owner rating

Informational only, not legal advice. Verify with qualified counsel before acting.