UK Small EMI and Small PI License in 2026
A 2026 deep dive into the UK Small EMI and Small PI regimes: GBP 5M e-money and GBP 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 volume is below GBP 3 million (averaged over 12 months). No fixed minimum initial capital.
- Small EMI. EMRs 2011. For firms with total business activities generating average outstanding e-money below GBP 5 million and total payment transactions below GBP 3 million per month.
Both routes are UK-only: no EU passport. FCA registration (not full authorisation) is lighter, faster and considerably cheaper.
Let's discuss your project and see how we can launch your UK small PI or small EMI product together
Request demoCapital, fees and process
- Initial capital. No fixed minimum under PSRs 2017 or EMRs 2011. 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 GBP 2-2.5M/month (SPI) or GBP 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 GBP 20k/50k/125k (API) or GBP 350k (EMI).
- 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
GBP 3 million monthly average payment volume over a rolling 12-month period. Above that, the firm must apply for authorised API status.
Average outstanding e-money below GBP 5 million and total payment transactions below GBP 3 million per month. Above either, apply for authorised EMI status.
No fixed minimum. 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.
