Electronic money institution authorisation in the United Kingdom
The FCA authorises electronic money institutions under the Electronic Money Regulations 2011. A UK EMI has no EU passport, so it serves the UK market only. Since 7 May 2026 the CASS 15 safeguarding rules apply, adding daily reconciliations, monthly safeguarding returns and an annual safeguarding audit.
Facts under review · last checked 2026-10-08 · confirm figures with the regulator before relying on them
Regulator · Financial Conduct Authority (FCA) ↗
Key facts
- Minimum initial capital
- €350,000EMRs-2011-Sch-2-para-2as of 2026-10-08Source ↗
- FCA application fee
- £5,640 (pricing category 5) for an authorised EMI; £1,130 for a small EMIas of 2026-10-08Source ↗
- Statutory decision period
- 3 months from a complete application; any application must be decided within 12 months of receiptEMRs-2011-reg-9as of 2026-10-08Source ↗
- Safeguarding rules (CASS 15)
- In force from 7 May 2026 for all EMIs, introduced by policy statement PS25/12as of 2026-10-08Source ↗
Realistic timeline
Who does what, and how long each phase usually takes once work starts. The regulator’s share is outside anyone’s control.
- HartsizScoping and gap analysis2–4 weeks
- YouHires, capital and application on FCA Connect8–16 weeksHartsiz drafts the pack; the client supplies people, capital and decisions
- RegulatorFCA assessment and decision16–52 weeksOutside our control; the 3-month statutory period starts only once the FCA treats the file as complete
Estimated end to end: 6–17 months. Not a guarantee.
What the regulator expects to see
- UK company with head office in the UK and senior management able to run it day to day
- Directors and senior managers assessed by the FCA for fitness and propriety
- MLRO and AML framework under the Money Laundering Regulations 2017
- Safeguarding, reconciliation and resolution-pack arrangements under CASS 15
- Operational resilience and ICT controls proportionate to the business
Questions we get
Can a UK EMI serve EU customers?
Not under a passport. Since Brexit a UK authorisation does not give access to the EU, so firms that need both markets usually hold an EU licence as well.
What changed with CASS 15?
From 7 May 2026 EMIs must follow the CASS 15 sourcebook for safeguarding customer funds, including daily reconciliations, monthly safeguarding returns and an annual audit.
Changes affecting this route
- United Kingdom · Fintech & Crypto · high impact
UK safeguarding Supplementary Regime (CASS 15) in force
The FCA's strengthened safeguarding rules for payment and e-money institutions apply from 7 May 2026. Firms must meet new reconciliation, record-keeping, audit and regulatory reporting requirements for client funds. Applicants should build these controls into their policies and systems before applying.
Source ↗