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UK Small EMI and Small PI License in 2026

A 2026 deep dive into the UK Small EMI and Small PI regimes: EUR 5M e-money and EUR 3M/month transaction caps, FCA registration, no fixed minimum capital, opt-in PS25/12 safeguarding and the upgrade path to authorised EMI/API.

The UK small regimes

The UK offers two light-touch alternatives to full authorisation:

Small Payment Institution (SPI). Regulation 14 of PSRs 2017. For firms whose monthly average payment transactions over the preceding 12 months do not exceed EUR 3 million. No fixed minimum initial capital.
Small EMI. EMRs 2011. For firms whose total business activities generate average outstanding e-money of no more than EUR 5 million. If the firm also runs payment services unrelated to e-money, those transactions must average no more than EUR 3 million a month over the preceding 12 months.

Both routes are UK-only: no EU passport. FCA registration (not full authorisation) is lighter, faster and considerably cheaper.

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Policy document prepared for a licence application

Capital, fees and process

Initial capital. No fixed minimum under PSRs 2017 or EMRs 2011. A Small EMI with average outstanding e-money of EUR 500,000 or more must hold initial capital of at least 2% of that amount (EMRs 2011, Schedule 2, paragraph 3). FCA assesses whether the firm has adequate financial resources on a case-by-case basis. Practical working capital: GBP 20k to GBP 50k for a seed-stage SPI.
Application fee. GBP 500 for SPI registration; GBP 1,000 for Small EMI.
Statutory clock. 3 months from complete file.
Real timeline. 4 to 6 months end-to-end.
Governance. MLRO, directors fit-and-proper, sound business plan, adequate governance. Lighter than full API/EMI but non-trivial.

PS25/12 and the safeguarding opt-in

Under PS25/12, Small EMIs are automatically covered by the new CASS 15 safeguarding regime in force from 7 May 2026. Small PIs (SPIs) can opt in to the regime if they choose to safeguard customer funds voluntarily. Many do, because banking partners prefer to see CASS 15 evidence on a counterparty.

Opting in brings daily reconciliation, monthly FCA returns, annual safeguarding audits and CASS 10 resolution packs. Small firms can face proportional application depending on complexity, but the direction is clear: safeguarding is converging toward bank-grade for every UK PI or EMI.

The upgrade path: SPI to API, Small EMI to Authorised EMI

Monitor the cap. Track 12-month rolling volume. Start the upgrade file at EUR 2-2.5M/month (SPI) or EUR 3-4M outstanding (Small EMI).
Notify FCA. Regulations require notification when the cap is approaching breach.
Upgrade file. Submit a full authorised application. FCA treats SPI/Small-EMI history as a partial credit but the Authorised file is materially deeper.
Capital top-up. Paid-up capital raised to EUR 20k/50k/125k (API, PSRs 2017 Schedule 3) or EUR 350k (authorised EMI, EMRs 2011 Schedule 2).
Timeline. 6 to 12 months. Plan it 6 to 9 months before the cap breach.

Ship a UK small PI or Small EMI product with Crassula

Crassula provides a platform that scales cleanly from SPI/Small EMI through to authorised API/EMI: ledger, UK accounts, cards, Faster Payments, KYC and AML, CASS 15-ready safeguarding (available at registration for firms that opt in) and FCA-ready reporting.

FAQ

A monthly average of EUR 3 million in payment transactions over the preceding 12 months (PSRs 2017, regulation 14). Above that, the firm must apply for authorised API status.

Average outstanding e-money of no more than EUR 5 million, and payment transactions unrelated to e-money averaging no more than EUR 3 million a month over 12 months (EMRs 2011, regulation 13). Above either, apply for authorised EMI status.

No fixed minimum. A Small EMI whose average outstanding e-money reaches EUR 500,000 needs initial capital of at least 2% of it. Beyond that, FCA assesses adequate financial resources case by case. Practical working capital GBP 20k to 50k for seed-stage firms.

Small EMIs are covered automatically. Small PIs can opt in. Many do because banking partners prefer CASS 15 evidence on counterparties.

Statutory 3 months from a complete file. Real-world 4 to 6 months end-to-end. Application fees: GBP 500 SPI, GBP 1,000 Small EMI.

Crassula provides a platform that scales from SPI/Small EMI through to authorised API/EMI: ledger, accounts, cards, Faster Payments, KYC/AML, CASS 15-ready safeguarding and FCA-ready reporting.