UK EMI License in 2026: The Complete FCA Authorised EMI Guide
A 2026 deep dive into the UK Authorised EMI licence: FCA authorisation under EMRs 2011, GBP 350k initial capital, new PS25/12 safeguarding regime in force 7 May 2026, 6-12 month timeline and the post-Brexit landscape.
Why the UK is still the biggest EMI market outside the EU
The UK lost the EU passport on 31 December 2020 but remains the deepest EMI market in Europe, with hundreds of authorised EMIs (Revolut UK, Wise, Monzo pre-bank, Modulr, Curve and many more) serving roughly 70 million consumers. The Financial Conduct Authority (FCA) is the sole regulator for EMIs under the Electronic Money Regulations 2011 (EMRs 2011).
The UK is the right home for an EMI that serves UK consumers, partners with UK banks or card schemes, or wants a tier-1 supervisor stamp without the CBI-Ireland timeline. The trade-off: no EU passport and a tighter safeguarding regime from 2026.
Let's discuss your project and see how we can launch your UK EMI e-money product together
Request demoCapital and scope
- Initial capital. GBP 350,000 per EMRs 2011, paid up and held in the authorised entity.
- Ongoing own funds. Method A, B or C under EMRs plus the EMD2 2% of average outstanding e-money.
- Scope. Issue, redeem and distribute electronic money. Full PSD2 payment services (covered by the PSRs 2017). No deposit-taking or own-balance-sheet lending.
- Small EMI alternative. EMD2 Article 9 track available (outstanding e-money under GBP 5 million, transactions under GBP 3M/month). Lower bar but UK-only.
The PS25/12 safeguarding overhaul - in force 7 May 2026
The most consequential UK EMI development in a decade is Policy Statement PS25/12 (published August 2025, in force 7 May 2026). PS25/12 replaces the light-touch safeguarding regime with a bank-style client-money framework under the new CASS 15 chapter of the FCA Handbook.
Why: FCA data show EMIs were safeguarding around GBP 26 billion and PIs around GBP 6 billion daily by 2024. In firm failures between 2018 and 2023, the average safeguarding shortfall was 65%. PS25/12 is a direct response to that gap.
Key obligations under the new regime:
- Mandatory daily reconciliations. Full reconciliation each business day, documented, evidenced.
- Monthly FCA safeguarding return. New supervisory report, including the firm's safeguarding position and any breaches.
- Annual safeguarding audit. Conducted by a qualified statutory auditor under the new FRC CASS 15 auditing standard.
- CASS 10 Resolution Pack retrievable within 48 hours. Ready for insolvency administrator at short notice.
- Trust structure. Statutory trust over client funds, modelled on CASS 7 for investment firms.
Small EMIs can opt in to the full regime, and many do. Authorised EMIs and PIs have no choice - PS25/12 applies automatically from 7 May 2026. Firms that fail to have audit arrangements, daily reconciliation tooling and resolution packs in place will face enforcement in the second half of 2026.
Authorisation process and timeline
- Pre-application. FCA offers informal pre-application meetings via the Innovation Pathways and Regulatory Sandbox for innovative firms. Strongly recommended.
- Connect registration. Firms file via the FCA Connect online system.
- File preparation. Business plan, programme of operations, governance, AML/CFT (MLRs 2017), CASS 15-ready safeguarding plan, ICT framework, outsourcing register, fit-and-proper files.
- Statutory clock. 3 months from a complete file; 12 months maximum for an incomplete file.
- FCA statutory target. From 2026, the FCA processes complete FSMA applications in 4 months (was 6); incomplete applications in 10 months (was 12).
- Real timeline. 6 to 12 months end-to-end for a well-prepared EMI file.
- Application fees. Approximately GBP 5,000 for an authorised EMI application.
Substance, SMCR and DORA-equivalent rules
- Senior Managers and Certification Regime (SMCR). FCA imposes individual accountability on senior managers. Key function holders certified individually.
- Substance. UK company, at least one UK-resident senior manager, real UK office, meaningful UK staffing.
- Operational resilience. PS21/3 operational resilience rules require identification of important business services, impact tolerances and testing (in force since 31 March 2022, full phase-in by March 2025).
- ICT and cyber. FCA and PRA expectations aligned with DORA (though DORA applies only to EU firms). UK regime focuses on governance, third-party risk and incident reporting.
- Consumer Duty. In force since 31 July 2023. EMIs serving retail consumers must deliver good outcomes against four outcomes (products, price, consumer understanding, consumer support).
UK EMI vs EU EMI
| Dimension | UK FCA Authorised EMI | EU Authorised EMI |
|---|---|---|
| Capital | GBP 350k | EUR 350k |
| Passport | UK only (post-Brexit) | Full EEA passport |
| Safeguarding | CASS 15 bank-grade (from 7 May 2026) | PSD2 segregation; tighter under PSD3 |
| Supervisor | FCA (sole) | NCA (BaFin, Bank of Lithuania, CBI, MFSA, etc.) |
| Regime trajectory | Post-Brexit UK-specific evolution | PSD3 merger of PI and EMI by 2027 |
Ship a UK EMI product with Crassula
Crassula provides the core-banking platform tuned to UK EMI expectations: ledger, UK accounts, card issuing (BIN-sponsor ready), Faster Payments, Bacs, CHAPS, SEPA, KYC and AML (MLRs 2017), CASS 15-ready safeguarding reconciliation and FCA-ready regulatory reporting.
FAQ
An Authorised Electronic Money Institution authorised by the FCA under the Electronic Money Regulations 2011, permitted to issue, redeem and distribute e-money and provide payment services in the UK.
GBP 350,000 initial capital for an Authorised EMI. Small EMIs (outstanding e-money under GBP 5 million, transactions under GBP 3M/month) have no fixed initial capital but sized FCA discretionary own-funds requirement.
FCA Policy Statement 25/12, published August 2025, creates a new CASS 15 safeguarding regime for payments and e-money firms. In force 7 May 2026. Mandatory daily reconciliations, monthly FCA returns, annual safeguarding audits and 48-hour CASS 10 resolution packs.
No. The UK lost the EU passport on 31 December 2020. UK EMIs that serve EU residents need either a parallel EU EMI authorisation or a reverse-solicitation model.
Statutory 3 months from a complete file; 12 months maximum for an incomplete file. FCA statutory target from 2026: 4 months complete, 10 months incomplete. Real-world 6 to 12 months end-to-end.
Crassula provides the UK EMI core: ledger, UK accounts and cards (BIN-sponsor ready), Faster Payments, Bacs, CHAPS, SEPA, MLRs 2017-aligned KYC/AML, CASS 15-ready safeguarding and FCA reporting.
