Informational only — not legal advice. Verify with qualified counsel before acting. Full disclaimer

🇬🇮 Gibraltar vs 🇬🇧 United Kingdom: e-money licensing compared

Public comparisonOpenlicence, regulator and recent changes
Full comparisonWith accessvalues, sources and verification dates
Evidence statusCurrentboth sides dated
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.
Verified 2026-08-15 Source: FCA, Apply to become an electronic money or a payment institution: https://www.fca.org.uk/firms/apply-emoney-payment-institution
Regulator Gibraltar Financial Services Commission (GFSC).
Verified 2026-08-15 Source: GFSC, Regulated Entities Register, E-money Institutions: https://www.fsc.gi/regulated-entities/e-money-institutions-17
Financial Conduct Authority (FCA).
Verified 2026-08-15 Source: FCA, Apply to become an electronic money or a payment institution: https://www.fca.org.uk/firms/apply-emoney-payment-institution
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.
Verified 2026-07-02 Source: FCA
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).
Verified 2026-07-02 Source: estimate
Local substance Gibraltar local substance is included in the £349 pass. UK entity with UK mind and management, MLRO, adequate local staffing.
Verified 2026-07-02 Source: FCA
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.
Verified 2026-08-15 Source: FCA application fees: https://www.fca.org.uk/firms/authorisation/apply/fees; ECB reference rate for 14 August 2026, GBP 0.85450 per EUR: https://www.ecb.europa.eu/stats/eurofxref/eurofxref-daily.xml
Ongoing cost Gibraltar ongoing cost is included in the £349 pass. FCA periodic fees, annual safeguarding audit, compliance headcount.
Verified 2026-07-02 Source: FCA
Passporting Gibraltar passporting is included in the £349 pass. None after Brexit, no EEA passport.
Verified 2026-07-02 Source: FCA
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.
Verified 2026-07-02 Source: thebanks.eu directory, cross-checked to FCA register and EBA register
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.
Verified 2026-07-02 Source: EMRs 2011
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.
Verified 2026-08-15 Source: FCA, Safeguarding requirements for payment institutions and electronic money institutions: https://www.fca.org.uk/firms/emi-payment-institutions-safeguarding-requirements
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.
Verified 2026-08-15 Source: HM Treasury, Modernising Payment Services Regulation consultation: https://www.gov.uk/government/consultations/modernising-payment-services-regulation
Difficulty rating Gibraltar difficulty rating is included in the £349 pass. 4. Rigorous on financial crime and safeguarding, very large market.
Verified 2026-07-02 Source: owner rating

Unlock the pass to see each gated figure with its source and verification date.

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.