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| Dimension |
Pinned 🇬🇮 Gibraltar partly open Verified 2026-10-01
|
🇬🇧 United Kingdom
Free in full
Verified 2026-10-01
|
|---|---|---|
| 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. | HM Treasury's Modernising Payment Services Regulation consultation, published 14 July 2026 and open until 6 October 2026, proposes modernising the Payment Services Regulations 2017 and Electronic Money Regulations 2011, including moving detailed firm-facing requirements into the FCA rulebook and adapting the framework for tokenised deposits and UK qualifying stablecoins. |
| Difficulty rating | Gibraltar difficulty rating is included in the £349 pass. | 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.
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