--- title: "E-Wallet Platform for UK Small EMIs | FCA Registered" description: "White-label e-wallet for FCA-registered small EMIs: top-ups, wallet-to-wallet payments, limits by verification level, CASS 15 data and a route to full EMI." url: "https://crassula.io/solutions/e-wallet/uk-small-emi/" lang: "en" image: "https://crassula.io/static/images/og/crassula-default.d7d01fb8a962.jpg" alternates: "en": "https://crassula.io/solutions/e-wallet/uk-small-emi/" "de": "https://crassula.io/de/solutions/e-wallet/uk-small-emi/" "es": "https://crassula.io/es/solutions/e-wallet/uk-small-emi/" "fr": "https://crassula.io/fr/solutions/e-wallet/uk-small-emi/" "x-default": "https://crassula.io/solutions/e-wallet/uk-small-emi/" index: "https://crassula.io/llms.txt" --- United Kingdom · Small EMI # E-wallet platform for UK small e-money institutions A small EMI lives inside two caps written in euros: EUR 5 million of average outstanding e-money and EUR 3 million a month in payment transactions. Your wallet ledger already holds the end-of-day balances the first figure is built from, so you see the cap coming long before the FCA does. [Request demo](https://crassula.io/request-demo/) [E-Wallet →](https://crassula.io/solutions/e-wallet/) Your market**United Kingdom**Small EMI - Branded wallet apps for iOS, Android and web - Payments between users by phone or email - Limits per verification level - End-of-day e-money totals for the cap test Rails your customers can use **Faster Payments****Bacs****Transfers between wallets****Prepaid card top-up** What the regulator asks about your IT**8** ![ClearBank](https://crassula.io/static/images/solutions/connector-logos/clearbank.02d614737cef.png)Clear Junction Case Studies ## See what teams build with Crassula. ![Multipass](https://crassula.io/static/images/solutions/cases/logo-multipass.7fb14a8eede7.png) - Multi-currency accounts - Cross-border payments - BaaS connections Live on Crassula ### [Custom financial products for global businesses.](https://crassula.io/cases/multipass/) Global business accounts, multi-currency payments and cross-border solutions, supported by Crassula APIs and BaaS connections. [Read case study: Multipass](https://crassula.io/cases/multipass/) ![LuxPay](https://crassula.io/static/images/solutions/cases/logo-luxpay.7d1fa138b9ba.png) - IBAN · SEPA - Card issuing - KYC onboarding Live on Crassula ### [A connected banking platform for modern financial services.](https://crassula.io/cases/luxpay/) Account details, SEPA payments, card issuing, KYC onboarding and multi-currency exchange in one financial product. [Read case study: LuxPay](https://crassula.io/cases/luxpay/) E-Wallet · Small EMI ## What a small EMI can launch as a wallet ### Stored-value wallets GBP balances issued at par when money arrives and paid back at par whenever the customer asks, with available and reserved amounts shown separately in the app. ### Top-ups by bank transfer Each customer gets named account details through your safeguarding and rails provider, so a Faster Payments top-up lands on the right wallet without anyone matching it by hand. ### Wallet-to-wallet payments Customers find each other by phone number, email or account number and pay instantly inside your system, confirming each payment with a second factor. ### Tiered onboarding Up to six verification levels, from unverified upwards, each with its own client limits, so a new user can try the wallet with small amounts while identity checks run. ### A prepaid card on the wallet Move money from the wallet onto a card and back again, with a dry run that shows the result first. You contract the card issuer, the platform runs the card. ### What this licence does not cover - Growing past EUR 5 million average outstanding e-money or EUR 3 million a month in payment transactions. Above either cap you need full authorisation as an EMI. - Account information or payment initiation services of your own. Small EMI registration excludes both. - Interest on wallet balances, or any other benefit tied to how long money stays in the wallet. The EMRs ban both. - Operating in EU countries on the strength of your FCA registration. It gives no rights outside the UK. Your market ## What the regulator asks about your IT Each requirement, what the platform gives you for it and who owns it after launch. 1 Systems and security description for the registration file Architecture, hosting, access roles, two-factor login and the audit trail, written up for the IT and security sections. Crassula drafts, you adopt 2 Staying under EUR 5m average outstanding e-money Total wallet balances at the end of each day, exported so finance can work out the six-month average on the first of every month. Your finance team, on platform data 3 Staying under EUR 3m a month in payment transactions Monthly exports of payment volumes, with wallet-to-wallet payments, top-ups and withdrawals split out. Your finance team, on platform data 4 CASS 15 daily reconciliation and monthly safeguarding return What you owe each wallet holder at any moment, exported for comparison with the balance in your safeguarding account. Your safeguarding officer 5 Annual safeguarding audit, or evidence that you qualify for the exemption A history of daily safeguarded totals, which shows whether you stayed under GBP 100,000 for 53 weeks, and an audit trail for the auditor if you did not. You and your auditor 6 Redemption at par on request Withdrawals to the customer's own bank account from the app, each recorded on the ledger with its timestamp. Shared with your rails provider 7 Customer due diligence under the Money Laundering Regulations Onboarding questionnaires, identity checks through connected verification providers, verification levels and limits per level. Your MLRO 8 Outsourcing arrangements and an exit plan Service description, audit and access rights, and data export if you ever move the wallet to another platform. You, with our input United Kingdom ## Payment rails and providers Rails your customers can use Faster Payments Bacs Transfers between wallets Prepaid card top-up ![ClearBank](https://crassula.io/static/images/solutions/connector-logos/clearbank.02d614737cef.png) ### ClearBank UK clearing bank offering EMIs safeguarding accounts, virtual accounts for each customer and direct access to Faster Payments and Bacs. Clear Junction ### Clear Junction FCA-authorised EMI that gives regulated firms GBP accounts, named virtual IBANs for their customers and UK payment rails. **24/7**real-time processing, no batch window **60+**payment and provider integrations connected **150+**companies run on Crassula **15+**languages the platform speaks United Kingdom ## Dates to plan around Rules that change what you have to build, in the order they apply. 1. **7 May 2026** CASS 15 applies to small EMIs in full, with the same daily reconciliation and monthly return as authorised EMIs. 2. **1st of every month** Recalculate average outstanding e-money: the average of end-of-day e-money over the previous six months, applied for that month. 3. **15 business days after month end** Deadline for the monthly safeguarding return to the FCA. There is no lighter version for small firms. Small EMI ## Registering with the FCA as a small EMI? Name us in your file. Small EMI registration is lighter than full authorisation, but the FCA still checks your systems, your safeguarding and your governance. We give you a working wallet and the technical write-up, and your advisers take care of the rest of the file. [Talk to us about your application](https://crassula.io/request-demo/) Crassula provides technology and documentation support. We do not provide legal or regulatory advice and cannot guarantee the outcome of an application. 1. 01 ### A platform you can demonstrate A configured environment to show the regulator, not slides. 2. 02 ### The technical part of your application, prepared System and security description, outsourcing and continuity sections, and how the platform supports your safeguarding measures. 3. 03 ### Providers lined up Safeguarding accounts and Faster Payments through partners including ClearBank and Clear Junction. ![A customer paying with his phone at a market stall.](https://crassula.io/static/images/features/people/market-1200.9009561ec1ca.webp) E-Wallet ## How a launch usually runs Picture a Manchester team building a wallet for students who split rent and bills. They register as a small EMI, because the projections stay far below EUR 5 million of e-money for the first years, and we launch the wallet in their brand with Faster Payments top-ups and instant payments between friends. New users start at the lowest verification level with tight limits and move up once their ID check clears. Every month the finance lead takes the end-of-day totals from the platform and updates the six-month average. When it passes EUR 3 million, the team starts its application for full EMI authorisation, and the wallet stays on the same platform throughout. For the rules behind the caps, read our [UK small EMI and small PI guide](https://crassula.io/guides/licenses/uk-small-emi-pi/) and the [CASS 15 safeguarding guide](https://crassula.io/guides/licenses/uk-safeguarding-cass-15/). Guides ## Read the licence guides ![UK Small EMI and Small PI License in 2026](https://crassula.io/static/images/guides/uk-small-emi-pi/london-pillar-box-preview-960.68603146a3aa.jpg) ### [UK Small EMI and Small PI License in 2026](https://crassula.io/guides/licenses/uk-small-emi-pi/) ![FCA Safeguarding Rules in 2026: CASS 15 Guide for EMIs and Payment Institutions](https://crassula.io/static/images/guides/uk-safeguarding-cass-15/safeguarding-boxes-preview-960.2782fe508dd7.jpg) ### [FCA Safeguarding Rules in 2026: CASS 15 Guide for EMIs and Payment Institutions](https://crassula.io/guides/licenses/uk-safeguarding-cass-15/) ![UK EMI License in 2026: The Complete FCA Authorised EMI Guide](https://crassula.io/static/images/guides/uk-emi/london-shard-preview-960.3d95fe51ab3d.jpg) ### [UK EMI License in 2026: The Complete FCA Authorised EMI Guide](https://crassula.io/guides/licenses/uk-emi/) ![White-Label Digital Wallet in 2026: The Complete Guide](https://crassula.io/static/images/guides/white-label-digital-wallet/digital-wallet-folio-preview-960.ebf91485d967.jpg) ### [White-Label Digital Wallet in 2026: The Complete Guide](https://crassula.io/solutions/e-wallet/guides/white-label-digital-wallet/) [**Explore all guides**Licensing, payments, cards and core banking, explained by our team.](https://crassula.io/guides/) United Kingdom · Small EMI ## FAQ The questions teams ask us before a first call. [**Not covered here?**Bring your question to a demo with our team.](https://crassula.io/request-demo/) What are the limits for a UK small EMI? Regulation 13 of the Electronic Money Regulations 2011 sets two caps in euros: average outstanding e-money of no more than EUR 5 million, and a monthly average of payment transactions over 12 months of no more than EUR 3 million. Above either one you need full authorisation as an EMI. How is average outstanding e-money calculated? It is the average of the e-money in issue at the end of each calendar day over the previous six months, worked out on the first day of each month and used for that month. The platform gives you the end-of-day totals, and your finance team does the calculation. Does a small EMI need capital? Once average outstanding e-money reaches EUR 500,000, the EMRs require initial capital of at least 2% of it. Below that there is no fixed amount, but the FCA still checks that your finances are sound for the business plan you submit. Does a small EMI need a safeguarding audit? Yes, unless it has not had to safeguard more than GBP 100,000 at any time over at least 53 weeks. Daily reconciliation and the monthly return apply either way. The daily totals on the platform show whether you are still under the exemption threshold. Can we reward customers for keeping money in the wallet? No. E-money issuers may not pay interest or give any benefit linked to how long money is held. Rewards tied to spending, such as cashback, are a separate question for your advisers. The platform supports cashback if you decide to offer it. What happens when we outgrow the small EMI caps? You apply to the FCA for full authorisation, with initial capital of at least EUR 350,000, and tell the FCA early about the change in your circumstances. The wallet, customer data and history stay on the same platform, so the upgrade is a regulatory project rather than a migration. United Kingdom · Small EMI ## What a small EMI can launch as a wallet Tell us your licence and country. We will map the rails, providers and documents you need. [Request demo](https://crassula.io/request-demo/) [**Know what you pay**One setup fee and a monthly plan with accounts and transactions included.*See pricing →*](https://crassula.io/prices/) [**Start with the API**Documented endpoints for accounts, payments, cards and customers.*Explore the API →*](https://crassula.io/features/api/)