Pin and benchmark
Pin the jurisdiction you are leaning towards, then line up to 5 rivals against it. Every unlocked figure shows where a peer beats it or loses to it on capital, timeline, cost and difficulty, so one screen tells you whether your first choice actually holds up.
| Dimension |
Pinned 🇬🇧 United Kingdom Verified 2026-07-03
|
🇱🇹 Lithuania
partly open
Verified 2026-07-03
|
|---|---|---|
| Licence type | Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011. | EMI licence (unrestricted) or Restricted EMI, via the Bank of Lithuania. |
| Regulator | Financial Conduct Authority (FCA). | Bank of Lithuania (Lietuvos bankas). |
| 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. | |
| Timeline to authorisation | About 6 to 12 months including pre-application (statutory 3 months from a complete application). | |
| Local substance | UK entity with UK mind and management, MLRO, adequate local staffing. | |
| Application cost | FCA application fee (order of GBP 5,000 for AEMI) plus roughly GBP 75k to 200k professional. | |
| Ongoing cost | FCA periodic fees, annual safeguarding audit, compliance headcount. | |
| Passporting | None after Brexit, no EEA passport. | |
| EMIs authorised | Around 338 e-money firms on the FCA register including small EMIs, the largest EMI population in Europe. | |
| Key restrictions | No interest on e-money, no deposit-taking; a SEMI cannot provide AIS or PIS. | |
| Safeguarding | Segregation or insurance or comparable guarantee. FCA Supplementary safeguarding regime (Policy Statement PS25/12, published 7 August 2025) in force from 7 May 2026: daily reconciliations, monthly regulatory reporting, annual safeguarding audit by a qualified auditor, resolution pack, third-party due diligence; audit exemption below GBP 100k. Stage 2 CASS-style statutory trust (Post-Repeal Regime) still under FCA review, not yet confirmed. | |
| Recent changes | FCA safeguarding reform live from 7 May 2026; HM Treasury payments-law reform expected later in 2026. | 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. |
| Difficulty rating | 4. Rigorous on financial crime and safeguarding, very large market. |
Informational only, not legal advice. A delta compares the sortable figure only (capital, timeline, cost, difficulty, passporting, approvals); it is not a judgement on overall suitability. Verify with qualified counsel before acting.