Crassula logo Request demo

Embedded finance platform for licensed EMIs

When your EMI sits behind a marketplace's wallets or a SaaS company's business accounts, the regulator sees one firm: yours. Each client brand is your programme, its end users are your customers, and anything its staff do as your agent or distributor counts as done by you.

Request demo Embedded Finance →
Case Studies

See what teams build with Crassula.

Embedded Finance · EMI

What a licensed EMI can run for its platform clients

One programme per platform client

Several brands run on one installation. Each platform client gets its own branded web and mobile apps, or only the API if it already has a front end, while you keep a single view of every programme.

Accounts for the client's end users

Multi-currency accounts and virtual IBANs for each seller, landlord or business customer, opened by API and held as named balances within your safeguarded funds.

Payouts for marketplaces

Batch transfers from a file or templates, with a second user approving before money goes out, so a marketplace can pay its sellers or couriers on a schedule.

Prices for each client and segment

Fees and FX margins in price lists by client group, so one platform client can charge its users differently from another without separate builds.

Cards through an issuer you contract

Virtual and physical Visa or Mastercard cards issued through pre-integrated issuers. You sign with the issuer, and card economics are part of that agreement.

An API for clients that build their own

Accounts, transfers, cards and KYC through one REST API, so a platform client with its own developers can keep its front end and use your licence underneath.

What this licence does not cover

  • Letting a platform client issue e-money. EMIs may distribute and redeem e-money through people acting on their behalf, but they may not issue it through agents, in the UK or in the EU.
  • Payment services through a distributor. A client that only distributes or redeems e-money is a distributor. If it provides payment services on your behalf, it must be registered as your agent first.
  • Chains of resellers. In the EU, the EBA has said only persons with a direct contract with the EMI may distribute its e-money, so a platform client cannot sign up distributors of its own for you.
  • Using agents in the UK if you did not plan for them at authorisation, until you have notified the FCA under SUP 15 and it has confirmed it has no material concerns about how you will oversee them.
Your market

What the regulator asks about your IT

Each requirement, what the platform gives you for it and who owns it after launch.

1Registering agents: FCA register via Connect in the UK, entry in the home register under Article 19 PSD2 in the EU before the agent starts

Each platform client runs as its own programme on the platform, so you can show the regulator exactly which client operates which product and where its users sit.

You
2Full liability for agents and distributors, and oversight that shows it (Article 20 PSD2; the FCA expects systems and controls over both)

Back-office roles for each client's staff, every action tied to a named user in the audit trail, and transaction data per programme for your oversight reports.

Your compliance function
3End users told that the client acts on your behalf and who their provider is

Legal documents, notices and app copy set per programme, so each brand shows your EMI as the provider.

You and your lawyers
4Safeguarding across all programmes, with daily reconciliation, a monthly return and a resolution pack under CASS 15 in the UK

An end-of-day balance for every end user, grouped by programme, exported for reconciliation against your safeguarding accounts.

Your finance team, on platform data
5Due diligence on platform clients and on each client's end users

Company onboarding with directors and beneficial owners for the platform client, onboarding questionnaires by client type and identity checks through connected providers for its users.

Your MLRO
6Transaction monitoring and sanctions screening across every programme

Transactions from all programmes in one back office, with screening and monitoring run through connected providers and controls you operate.

Your MLRO
7ICT risk and outsourcing: DORA for EU EMIs, operational resilience under SYSC 15A for UK EMIs

Technical documentation of hosting, access roles, backups, incident handling and sub-providers for your register of ICT arrangements or important business services mapping.

Crassula drafts, you adopt
8An exit plan when a platform client leaves or fails

Exports of every end user's balance and history in the departing programme, and the ability to freeze or close its accounts on a date you choose.

You
UK and EU

Payment rails and providers

Rails your customers can use

Faster PaymentsBacsCHAPSSEPASEPA InstantSWIFT

ClearBank

For UK EMIs: virtual accounts created by API under your own name and sort code for each end customer, GBP client funds held at the Bank of England, and indirect access to Faster Payments, Bacs and CHAPS.

Prefer another provider?

Crassula connects 60+ payment, banking and compliance integrations. We will check which ones fit your licence.

Explore all connectors →
24/7real-time processing, no batch window
60+payment and provider integrations connected
150+companies run on Crassula
15+languages the platform speaks
UK and EU

Dates to plan around

Rules that change what you have to build, in the order they apply.

  1. 9 Oct 2025

    EMIs in the euro area must offer Verification of Payee on credit transfers, including transfers started from a platform client's app.

  2. 7 May 2026

    CASS 15 applies to UK EMIs: daily safeguarding reconciliation, a monthly safeguarding return and a resolution pack that explains how funds move, agents and distributors included.

  3. 9 Apr 2027

    EMIs in the euro area must be able to send and receive SEPA Instant payments for the end users of every programme.

  4. 10 Jul 2027

    The EU Anti-Money Laundering Regulation applies, with one rulebook for customer due diligence on platform clients and their users.

EMI

Adding a platform model to your EMI? Bring the technology part ready.

Whether you apply for a new licence or add agents to an existing one, the regulator will ask how you see and control what each platform client does. We give you a working platform and the technical write-up, while your lawyers handle the agency agreements and the filing.

Talk to us about your application

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 with more than one programme, to show the regulator how you oversee each client, not slides.

  2. 02

    The technical part of your application, prepared

    Programme structure, data flows, access roles, safeguarding data, ICT and outsourcing sections, written for your FCA or EU regulator file.

  3. 03

    Providers lined up

    For the UK, safeguarding and virtual accounts through ClearBank. For the EU, banking, card and KYC providers from our network, matched to your licence.

A financial-product team reviewing a phone together.
Embedded Finance

How a launch usually runs

Take a London EMI with its own consumer app that signs two platform clients: a marketplace for tradespeople that wants to hold job payments and pay out on completion, and a booking software firm that wants business accounts for the gyms it serves. Its lawyers decide that the marketplace must be registered as an EMD agent, because its staff will handle payment instructions, while the software firm only shows the EMI's product in its own brand.

We set up both as separate programmes, each with its own app, price list and limits. Every tradesperson and every gym gets a named balance and a virtual account, and the finance team reconciles all programmes against the safeguarding accounts each morning. The compliance team reviews each client's activity in the same back office and keeps the evidence of oversight the FCA asks for.

For the regulatory background, read our guide to UK agent registration, the EMI licence guide and our article on banking as a service.

Guides

Read the licence guides

Explore all guidesLicensing, payments, cards and core banking, explained by our team.
UK and EU · EMI

FAQ

The questions teams ask us before a first call.

Not covered here?Bring your question to a demo with our team.
Does every platform client have to be our agent?
No. It depends on what the client does. If it provides payment services on your behalf, it must be registered as your agent. If it only distributes or redeems e-money, it acts as a distributor, which the FCA does not register but expects you to identify. If it only markets your product, it may be neither. Take legal advice for each client.
Who is liable if a client's staff get something wrong?
You are. In the EU, Article 20 PSD2 keeps an institution fully liable for its agents and for entities it outsources to. In the UK, the principal EMI is responsible for anything its agents and distributors do or fail to do. That is why oversight evidence matters as much as the contract.
Can platform clients use agents in other countries?
In the EU, an EMI using an agent or a distributor in another Member State follows the passporting notification to its home regulator. UK and EU licences no longer passport into each other, so serving both markets needs a licence on each side.
How does safeguarding work with many programmes?
All end user funds are safeguarded by your EMI, whichever brand they came through. The ledger splits them by programme and by end user, so each reconciliation shows which client's users own which part of the safeguarded total.
Can each client have its own app and pricing?
Yes. Each programme can have branded web and mobile apps or use only the API, with its own price lists, limits and onboarding questionnaires, while the ledger and back office stay shared.
Will PSD3 change the agent and distributor rules?
The PSD3 and PSR texts have been agreed but were not yet published in the Official Journal in October 2026, and they are expected to apply around 2028. Until then the current rules apply. Our PSD3 and PSR guide tracks the details.
Embedded Finance

Explore your launch market

UK and EU · EMI

What a licensed EMI can run for its platform clients

Tell us your licence and country. We will map the rails, providers and documents you need.

Request demo
Know what you payOne setup fee and a monthly plan with accounts and transactions included.See pricing → Start with the APIDocumented endpoints for accounts, payments, cards and customers.Explore the API →
Top