🇬🇮 Gibraltar vs 🇬🇧 United Kingdom: e-money licensing compared
Decision context and regulator route
Choosing between Gibraltar and United Kingdom for a e-money licence starts with who you will answer to: Gibraltar Financial Services Commission (GFSC). on one side, Financial Conduct Authority (FCA). on the other, via the Authorised electronic money institution or registered electronic money institution under the Financial Services (Electronic Money) Regulations 2020. This is a full e-money regime rather than an analogue. and the Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011. respectively. The public fields are shown below, with the full dated and sourced comparison included with access.
Gibraltar: verified 2026-08-15 · United Kingdom: verified 2026-08-15
| Dimension |
🇬🇮 Gibraltar
partly open
Verified 2026-08-15
|
🇬🇧 United Kingdom
Free in full
Verified 2026-08-15
|
|---|---|---|
| Licence type | Authorised electronic money institution or registered electronic money institution under the Financial Services (Electronic Money) Regulations 2020. This is a full e-money regime rather than an analogue. | Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011. |
| Regulator | Gibraltar Financial Services Commission (GFSC). | Financial Conduct Authority (FCA). |
| Capital requirement | Gibraltar capital requirement is included in the £349 pass. | 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 | Gibraltar timeline to authorisation is included in the £349 pass. | About 6 to 12 months including pre-application (statutory 3 months from a complete application). |
| Local substance | Gibraltar local substance is included in the £349 pass. | UK entity with UK mind and management, MLRO, adequate local staffing. |
| Application cost | Gibraltar application cost is included in the £349 pass. | FCA application fee GBP 5,640 for an authorised EMI (Category 5) or GBP 1,130 for a small EMI (Category 3). Professional and implementation costs are project-specific. |
| Ongoing cost | Gibraltar ongoing cost is included in the £349 pass. | FCA periodic fees, annual safeguarding audit, compliance headcount. |
| Passporting | Gibraltar passporting is included in the £349 pass. | None after Brexit, no EEA passport. |
| EMIs authorised | Gibraltar emis authorised is included in the £349 pass. | Around 338 e-money firms on the FCA register including small EMIs, the largest EMI population in Europe. |
| Key restrictions | Gibraltar key restrictions is included in the £349 pass. | No interest on e-money, no deposit-taking; a SEMI cannot provide AIS or PIS. |
| Safeguarding | Gibraltar safeguarding is included in the £349 pass. | 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 | LN 2026/053 took effect on 26 March 2026 and requires e-money institutions to notify the GFSC at least 30 days before declaring a dividend and obtain a no-objection. The Financial Services (Payment Services) (Amendment) Regulations 2026 and Financial Services (Electronic Money) (Amendment) Regulations 2026 were both made on 16 July 2026; their substantive effect remains review-needed because only their official titles and dates were retrievable. | FCA safeguarding reform live from 7 May 2026 (first monthly REP027 return fell due 21 July 2026). HM Treasury's Modernising Payment Services Regulation consultation, published 14 July 2026, proposes rebuilding the PSRs 2017 and EMRs 2011 into a single FCA-rulebook framework spanning fiat, tokenised deposits and UK qualifying stablecoins; it closes 6 October 2026. |
| Difficulty rating | Gibraltar difficulty rating is included in the £349 pass. | 4. Rigorous on financial crime and safeguarding, very large market. |
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What changed recently
🇬🇮 Gibraltar (verified 2026-08-15): LN 2026/053 took effect on 26 March 2026 and requires e-money institutions to notify the GFSC at least 30 days before declaring a dividend and obtain a no-objection. The Financial Services (Payment Services) (Amendment) Regulations 2026 and Financial Services (Electronic Money) (Amendment) Regulations 2026 were both made on 16 July 2026; their substantive effect remains review-needed because only their official titles and dates were retrievable.
🇬🇧 United Kingdom (verified 2026-08-15): FCA safeguarding reform live from 7 May 2026 (first monthly REP027 return fell due 21 July 2026). HM Treasury's Modernising Payment Services Regulation consultation, published 14 July 2026, proposes rebuilding the PSRs 2017 and EMRs 2011 into a single FCA-rulebook framework spanning fiat, tokenised deposits and UK qualifying stablecoins; it closes 6 October 2026.
Quick answers
Who regulates e-money licensing in Gibraltar and United Kingdom?
Gibraltar: Gibraltar Financial Services Commission (GFSC).. United Kingdom: Financial Conduct Authority (FCA)..
What licence do you need in Gibraltar compared with United Kingdom?
In Gibraltar the authorisation route is Authorised electronic money institution or registered electronic money institution under the Financial Services (Electronic Money) Regulations 2020. This is a full e-money regime rather than an analogue.; in United Kingdom it is Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011.. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Gibraltar vs United Kingdom comparison?
The interactive benchmark lets you pin either jurisdiction and add up to five peers; a Founder Pass or Pro subscription unlocks every gated figure with its source and verification date. This page stays free at /e-money/compare/gibraltar-vs-united-kingdom.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.