Licence type
Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011.
Regulator
Financial Conduct Authority (FCA).
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 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.
Recent changes
FCA safeguarding reform live from 7 May 2026; HM Treasury payments-law reform expected later in 2026.
Difficulty rating
4. Rigorous on financial crime and safeguarding, very large market.
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