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UK EMD Agent and PSD Agent Registration in 2026

A 2026 deep dive into the UK EMD Agent and PSD Agent registers: working under an authorised EMI or PI, no separate licence, fit-and-proper, responsibility of the principal, and when the agent model is the right structure.

Agent vs authorised firm

The UK recognises two ways to provide payment or e-money services without holding a full authorisation:

PSD Agent. A person that provides payment services on behalf of an authorised PI or EMI under a written agency agreement. Registered in the FCA's public register but not individually authorised.
EMD Agent. A person that provides payment services on behalf of an authorised EMI. Registered in the FCA's public register. An EMD agent cannot issue e-money. Distributing or redeeming e-money for an EMI is a separate role (the distributor), and distributors are not registered with the FCA.

The principal (the authorised EMI or PI) remains fully responsible for the agent's regulated activity. The agent is not a substitute for authorisation and cannot perform activities outside the principal's scope.

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Policy document prepared for a licence application

When an agent structure makes sense

BaaS distribution. A fintech wants to offer a branded payment product without holding a licence. It becomes an EMD/PSD agent of an authorised EMI/PI (a BaaS partner) that provides the regulated rails.
Retail distribution. Remittance operators work through networks of shops registered as their agents. E-money issuers often use shops as distributors that load or redeem e-money. Distributors are not registered, but the EMI remains responsible for what they do.
Testing the market. Founders validate a product as an agent before investing in a full authorisation.
Avoided complexity. Agents do not carry capital, safeguarding, SMCR or CASS 15 obligations directly (those sit with the principal).

Agent status is not a workaround for permissions the principal does not hold. If the principal is a PI, its agent cannot issue e-money. If the principal is an EMI, the agent works within the EMI's permissions.

Process and fit-and-proper

Agency agreement. Signed between the authorised principal and the agent. Covers scope, reporting, AML, complaints, terminations.
Principal due diligence. The principal conducts fit-and-proper on the agent and its directors. Regulation 34 PSRs 2017 and Regulation 34 EMRs 2011 provide the framework.
Principal application to FCA. Principal applies to register the agent via Connect. An EMI that did not say in its authorisation application that it would use agents must first file a SUP 15 notification and receive the FCA's confirmation that it has no material concerns with the EMI's framework for overseeing agents. If its conditions of authorisation restrict onboarding agents, it must apply to vary its permission first.
FCA register. Agent appears on the FCA public register under the principal's entry, usually within 30 to 60 days.
Ongoing oversight. Principal monitors AML, complaints, agent performance, and reports to FCA.

The agent holds no capital and runs no separate safeguarding. Those duties stay with the principal.

Limits and risks of the agent model

Dependent on the principal. If the principal loses its authorisation, agents stop trading.
No independent brand on the register. FCA register shows the agent under the principal.
Revenue split. Principals charge platform and volume fees, compressing agent margins.
Operational control. Principal sets AML, conduct and complaint rules the agent must follow.
Upgrade path. Agents that grow typically apply for their own authorised EMI or API licence.

Ship an agent-distributed UK product with Crassula

Crassula provides the platform for both sides of the agent model. A licensed EMI or PI acting as principal runs its ledger, customer accounts, onboarding with connected KYC providers, cards and FPS/Bacs/CHAPS payments on Crassula, with transaction records and exports its compliance team can use for safeguarding, AML and agent oversight. An agent can run a branded product on top of a principal that uses Crassula. Compliance decisions, including how agents are overseen, stay with the principal's team.

FAQ

A person that provides payment services on behalf of an authorised UK EMI. Registered in the FCA's public register under the principal EMI. Not individually authorised, and cannot issue e-money. A person that only distributes or redeems e-money for an EMI is a distributor, which is not registered.

A person that provides payment services on behalf of an authorised UK PI under a written agency agreement. Registered in the FCA's public register under the principal PI.

No. Capital, safeguarding, SMCR and CASS 15 obligations sit with the principal (the authorised EMI or PI).

30 to 60 days for the FCA to process an agent application from an authorised principal. An EMI that did not declare agents in its authorisation application first needs the FCA's "no material concerns" confirmation on a SUP 15 notification, which adds time.

When volumes support it, when brand autonomy matters, when the principal's margin compression becomes material, or when you need permissions the principal does not hold.

Crassula runs the principal's core banking (ledger, accounts, payments, cards) and keeps the records and exports its compliance team needs to oversee agents. When an agent later gets its own authorisation, it can run the same platform under its own licence. Compliance decisions stay with the regulated firm.