UK EMI License in 2026: The Complete FCA Authorised EMI Guide

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, 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.

Capital 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 adds a much stricter layer of rules on top of the existing safeguarding provisions in the EMRs 2011 and PSRs 2017, set out in 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. Carried out by a qualified auditor (not necessarily your statutory auditor). There is no final FRC standard yet: the FRC issued interim, non-mandatory guidance for safeguarding auditors on 17 March 2026 and plans a dedicated standard later.
• CASS 10A resolution pack retrievable within 48 hours. Ready for an insolvency practitioner, the FCA or the Bank of England at short notice.
• No statutory trust yet. PS25/12 only adopted the interim rules. The statutory trust over client funds proposed in CP24/20 was deferred: it depends on HM Treasury legislation and further FCA consultation.

CASS 15 applies to authorised and small EMIs alike from 7 May 2026. Small EMIs also need the annual safeguarding audit, unless they have not been required to safeguard more than GBP 100,000 at any time over at least 53 weeks. Firms that fail to have audit arrangements, daily reconciliation tooling and resolution packs in place will face enforcement in the second half of 2026.

For the full rulebook, see our CASS 15 safeguarding guide.

Authorisation process and timeline

1. Pre-application. FCA offers informal pre-application meetings via the Innovation Pathways and Regulatory Sandbox for innovative firms. Strongly recommended.
2. Connect registration. Firms file via the FCA Connect online system.
3. 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.
4. Statutory clock. 3 months from a complete file; 12 months maximum for an incomplete file.
5. FCA statutory target. From 2026, the FCA processes complete FSMA applications in 4 months (was 6); incomplete applications in 10 months (was 12).
6. Real timeline. 6 to 12 months end-to-end for a well-prepared EMI file.
7. 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

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.

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