The licensing matrix

Authorised EMI (AEMI) or Small EMI (SEMI) under the Electronic Money Regulations 2011.

Financial Conduct Authority (FCA).

AEMI GBP 350,000 initial plus own funds 2% of average outstanding e-money. SEMI no initial capital, capped below EUR 5m outstanding.

About 6 to 12 months including pre-application (statutory 3 months from a complete application).

UK entity with UK mind and management, MLRO, adequate local staffing.

FCA application fee (order of GBP 5,000 for AEMI) plus roughly GBP 75k to 200k professional.

FCA periodic fees, annual safeguarding audit, compliance headcount.

None after Brexit, no EEA passport.

Around 338 e-money firms on the FCA register including small EMIs, the largest EMI population in Europe.

No interest on e-money, no deposit-taking; a SEMI cannot provide AIS or PIS.

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.

FCA safeguarding reform live from 7 May 2026; HM Treasury payments-law reform expected later in 2026.

4. Rigorous on financial crime and safeguarding, very large market.

EMI licence (unrestricted) or Restricted EMI, via the Bank of Lithuania.

Bank of Lithuania (Lietuvos bankas).

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.

Instituicao de Moeda Eletronica under the RJSPME (Decree-Law 91/2018).

Banco de Portugal.

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.

No EMI. IFPE (Institucion de Fondos de Pago Electronico) under the Ley Fintech.

CNBV together with Banco de Mexico (Banxico).

Continuing CNBV and Banxico secondary rules.

E-Money Institution or Small E-Money Institution under the European Communities (Electronic Money) Regulations 2011.

Central Bank of Ireland (CBI).

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.

Electronic Money Institution under the Financial Institutions Act (Cap. 376).

Malta Financial Services Authority (MFSA).

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. Ongoing reputational rebuild after FATF grey-listing (delisted 2022).

Etablissement de monnaie electronique.

ACPR (part of the Banque de France). Not the AMF, which handles markets and crypto.

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.

E-Geld-Institut under the ZAG.

BaFin, with the Deutsche Bundesbank.

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.

No EMI. Closest is the FINMA FinTech licence (Banking Act Art. 1b), deposits up to CHF 100m, no interest, no lending. Larger operations need a banking licence.

FINMA.

Government proposed in late 2025 to replace the FinTech licence with two new licences, a payment institution licence (including stablecoins) and a crypto institution licence.

No EMI. Stored Value Facility (SVF) licence and Retail Payment Services under the Retail Payment Services and Card Schemes Regulation, federal.

Central Bank of the UAE (CBUAE). Separate from Dubai VARA, which regulates crypto.

Transition deadline 16 Sep 2026 for in-scope entities.

No EMI. Major Payment Institution (MPI) licence under the Payment Services Act, covering e-money issuance and account issuance. Standard PI for smaller volumes.

Monetary Authority of Singapore (MAS).

Continuing MAS refinements to the PSA.

No EMI. Stored Value Facility (SVF) licence under the Payment Systems and Stored Value Facilities Ordinance (Cap. 584).

Hong Kong Monetary Authority (HKMA). Not the SFC, which handles the crypto VATP regime.

Ongoing HKMA supervision, with a separate HK stablecoin and crypto regime developing.

Authorised EMI or Registered EMI under the Financial Services (Electronic Money) Regulations 2011. A real EMI regime, unlike the pure analogues.

Gibraltar Financial Services Commission (GFSC).

Alignment with the UK market-access regime; separate DLT provider framework since 2018.