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 distributes and redeems e-money on behalf of an authorised EMI. Registered in the FCA's public register.
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.
Let's discuss your project and see how we can launch your UK EMD or PSD agent product together
Request demoWhen 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 and e-money distributors work through networks of shops that act as agents.
- 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 notification to FCA. Principal files the agent details to FCA via Connect. Lightweight; no substantive assessment as for a full application.
- 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.
Filing fee: typically GBP 150 per agent. No capital. No separate safeguarding. Quick path to operating.
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 infrastructure for both sides of the agent model: for BaaS principals (licensed EMI/PI) to manage an agent network, and for agents to run a branded product on top of a Crassula-powered principal. Ledger, onboarding, cards, FPS/Bacs/CHAPS, safeguarding reporting (principal side), agent-level AML and complaints workflows.
FAQ
A person that distributes and redeems e-money on behalf of an authorised UK EMI. Registered in the FCA's public register under the principal EMI. Not individually authorised.
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 notification from an authorised principal.
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 powers both sides: the principal's core banking, agent network management, agent-level compliance, and a seamless upgrade path when an agent becomes its own authorised firm.
