Multipass is a financial services provider offering global business accounts, multi-currency payments, and cross-border transaction solutions.
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E-Wallet
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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.
- 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
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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.
What the regulator asks about your IT
Each requirement, what the platform gives you for it and who owns it after launch.
Architecture, hosting, access roles, two-factor login and the audit trail, written up for the IT and security sections.
Crassula drafts, you adoptTotal 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 dataMonthly exports of payment volumes, with wallet-to-wallet payments, top-ups and withdrawals split out.
Your finance team, on platform dataWhat you owe each wallet holder at any moment, exported for comparison with the balance in your safeguarding account.
Your safeguarding officerA 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 auditorWithdrawals to the customer's own bank account from the app, each recorded on the ledger with its timestamp.
Shared with your rails providerOnboarding questionnaires, identity checks through connected verification providers, verification levels and limits per level.
Your MLROService description, audit and access rights, and data export if you ever move the wallet to another platform.
You, with our input
Payment rails and providers
Rails your customers can use
Faster PaymentsBacsTransfers between walletsPrepaid card top-up
ClearBank
UK clearing bank offering EMIs safeguarding accounts, virtual accounts for each customer and direct access to Faster Payments and Bacs.
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
Dates to plan around
Rules that change what you have to build, in the order they apply.
7 May 2026
CASS 15 applies to small EMIs in full, with the same daily reconciliation and monthly return as authorised EMIs.
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.
15 business days after month end
Deadline for the monthly safeguarding return to the FCA. There is no lighter version for small firms.
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.
01
A platform you can demonstrate
A configured environment to show the regulator, not slides.
02
The technical part of your application, prepared
System and security description, outsourcing and continuity sections, and how the platform supports your safeguarding measures.
03
Providers lined up
Safeguarding accounts and Faster Payments through partners including ClearBank and Clear Junction.
Crassula provides technology and documentation support. We do not provide legal or regulatory advice and cannot guarantee the outcome of an application.
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 and the CASS 15 safeguarding guide.
Read the licence guides
FAQ
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.
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.
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.
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.
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.
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.
