EMI License in the UK 2025

Although investments in fintech have fallen, the UK remains a hub of global fintech innovation. Setting up an EMI in the UK now provides the opportunity to leverage the country’s fintech expertise and tap into an unrivaled pool of skilled talent in order to create innovative solutions that will help you stay competitive in the ever-evolving e-money industry. In practice, more and more digital payment solutions are being adopted by consumers, and you stand to get ahead by pinpointing specific market needs or underserved segments. This approach can actually help your EMI reach a niche that will guarantee the sustainability and strength of your business over the long term in case of market adjustments.

If you dream about disrupting or at least taking small steps forward in the UK e-money industry, start your journey with exploring the regulatory framework of this country, assessing benefits, and learning ways of how to get a UK e-money license. Such a license will be a facilitator for you to reach the lucrative market, and be constantly innovative while assuring the security and protection of consumer funds. Obtaining a license isn’t easy; you definitely can count on us in the opening procedure of an e-money institution in the UK. Such different lawyers with more than six years of experience in licensing FinTech here at Regulated United Europe will be ready to provide the relevant expertise in the applicability of regulations.

What is an E-Money Institution License?

An e-money license, or Electronic Money Institution License, is a regulatory dispensation provided to those institutions by any national financial regulator for the primary issuance of electronic money—that is, digital representation of fiat currency—and the facilitation of financial services associated with it. Within the UK context, the license is mandated by law and forms the lifeline for many businesses dealing in electronic transactions and digital finance. While leading the charge to utilise such licences are the fintech companies, the concept applies to several industries.

An EMI license can provide opportunities to innovate for such businesses as:

• E-commerce platforms willing to offer secured and seamless electronic payment methods to customers with minimal dependency on third-party payment processors.
• Retailers who would be allowed to use the facility of an EMI license in order to include electronic money service in their business model for the issue of prepaid cards and loyalty programs.
• Uses also apply to gaming and entertainment since they allow businesses to start implementing digital payment systems for in-game purchases, subscription services, and ticket sales for events. These include the fact that EMI licenses could be issued for SMEs from different industries since an integration of electronic money services into their activities may allow them to provide customers with flexible payment solutions and smooth financial transaction processing.

A UK EMI license holder may engage in, amongst others, the following activities:

• Issuing of e-money in different forms
• Protection of customer funds by safeguarding them for security and protection
• Execution of payment transactions in the forms of transfers, direct debits, and standing orders
• Issuing and administering of payment instruments, which include prepaid cards or electronic wallets
• Cash placements and withdrawals from a payment account
• Currency exchange operations connected with the issue of e-money
• Operate the payment accounts of customers, enabling them to receive, store, and transfer funds
• Provide payment initiation service (PIS)
• Provide account information service (AIS)

Types of EMI Licenses in the UK

Whether an e-money startup or an already established financial institution, a licensing solution can be found in the UK that will suit the business needs of every company. With two UK EMI licenses available, access to the UK’s competitive and promising market will be provided, depending on the business model, resources, and other key variables.

You can apply for one of the following EMI licenses:

• A small electronic money institution (SEMI) that allows license holders to issue e-money and provide payment services but does not cover the provision of AIS and PIS
• An authorized electronic money institution- AEMI, which is a standard license

Your company will be classified as an SEMI if:

• It does not project to issue an average outstanding e-money of more than 5 mill. EUR
• The company’s monthly average payment transactions in a 12-month period don’t exceed 3 mill. EUR
• The maximum limit for the amount stored in the customer’s payment instrument, where electronic money is held, doesn’t exceed 250,000 EUR

If your company projects an average outstanding e-money issue of more than 5 mill. EUR, you will have to apply for an AEMI license with stricter eligibility criteria and a more cumbersome application process.

Advantages of Having a United Kingdom EMI License

In the aftermath of Brexit, new elements in place have come into play, but the UK still has its unique set of reasons to be up-front. Advantages of UK e-money licensing span from its strong, transparent regulatory framework to globally recognized financial prominence to maintaining a resilient financial ecosystem. In other words, being an EMI in the UK means competitiveness, business opportunities, and huge governmental support to assure further success in progressive business activities related to electronic money service provision.

Key advantages of holding an e-money license in the UK:

• A license might provide an entrance ticket to a well-interconnected UK financial market, boosted by strong partnerships and an extensive customer base, hence creating many expansion and growth possibilities.
• The UK has established a clear regulatory framework for the provision of financial services with the perfect balance between rigor and adaptability. This will definitely allow EMI licenses to remain compliant yet innovative against emerging consumer preferences.
• London, the capital of the United Kingdom, is one of the best-reputed financial centers globally and boasts well-developed infrastructure, while having an exceptionally good reputation in terms of financial services, including e-money, which adds a veneer of legitimacy and reliability to the operations of your EMI.
• You will find that the workforce in the UK is extremely diverse and proficient in finance, technology, compliance, and other required areas, offering the breadth of specialist knowledge for your EMI.
• Outwardly, with its centuries-old ties and relationships with most regions, the UK provides easy access to international markets, making it much easier to pursue global expansion strategies.
• The UK has over 130 double taxation agreements around the world that will enable you to minimize your level of tax liability by avoiding paying in two countries once your EMI starts cross-border business.
• Innovation: The UK values innovation significantly. Thus, if your EMI is involved in some innovative activities or the development of technology, it can claim research and development tax credits, which will allow it to deduct the R&D costs and thereby substantially reduce the overall expenses related to such activities.

EMI Regulations in the UK

Since Brexit, the UK has implemented its regulatory framework policed by the Financial Conduct Authority (FCA). Before delving into the UK’s national laws, one crucial amendment needs to be made with regard to access to the European Economic Area (EEA). UK EMI license holders no longer have automatic access to passporting privileges within the EEA, and you would need to find other ways to offer your services to consumers in the EU/EEA.

To provide services in the EU/EEA post-Brexit, UK-based EMIs now must either:

• Establish a presence by setting up a company or branch within an EU/EEA member state and apply for an EMI license from the relevant regulatory authority in that country
• Rely on specific agreements or equivalency regimes negotiated between the UK and the EU/EEA countries which allow limited access to EU markets in certain financial areas if the EU deems the UK’s regulatory standards comparable to its own
• Some UK-based EMIs might opt to relocate their headquarters or a significant part of their operations to an EU/EEA member state to have access to the EU/EEA market

Bear in mind that we have an experienced team of lawyers, business developers, and financial accountants who can advise you on the best approach in this situation. If availing yourself of the EU’s passporting rights is of paramount importance to you, we can help you obtain a license from any EU jurisdiction of your choice. However, by no means be discouraged from further exploring the UK’s regulatory environment and the opportunities an FCA EMI license can offer. It remains a prestigious jurisdiction, attracting international investment, hosting a wide array of financial services, and continuously evolving to meet the needs of innovative businesses.

All EMI licensees based in the UK are governed by a number of laws and regulations pertaining to UK financial licensing, including:

• Electronic Money Regulations 2011 (EMRs) – prescribe how electronic money is issued, customer funds are protected, business is conducted, and standards for compliance are maintained.
• Payment Services Regulations 2017 – apply to UK EMIs offering payment services and include matters on payment processing, security requirements, and customer protection, among others.
• The Payment Card Interchange Fee Regulations 2015 – regulate interchange fees charged between banks in card-based payment transactions with different caps on interchange fees and differentiation of caps.
• The Financial Services and Markets Act 2023 (FSMA): Probably the most significant piece of legislation introduced to the UK’s financial services sector in recent times, sets the framework for the revocation of retained EU laws, adding new objectives for regulators relating to financial services.
• The Electronic Money, Payment Card Interchange Fee and Payment Services (Amendment) Regulations 2023 – These Regulations amend the EMRs, the PCIFR and the PSRs.
• The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, along with The Money Laundering and Terrorist Financing (Amendment) Regulations 2019, present a regime designed to attempt to deter money laundering and terrorist financing. It includes provisions on the risk-based approach, customer due diligence procedures, record-keeping, and internal controls.
• POCA provides the legislative mechanism for recovering the assets of crime through criminal confiscation and gives the investigative powers such as search and seizure.
• The Data Protection Act 2018 is a UK law that brought the provisions of the General Data Protection Regulation, controls how organisations, businesses or the government uses customers’ personal information.

How to Get a UK EMI License?

There are two ways to obtain an EMI license in the UK: obtaining a new EMI license and buying a ready company already having such a license. We can offer both solutions. Anyhow, you should, at first, consider such aspects as your financial resources, business goals, capabilities of operation, risk tolerance, and timelines. Below, we share with you those critical aspects from all the alternatives that are germane to your making an educated decision. If you want to consider those aspects – and others of a similar vein that are important – against your unique business model, you are invited to schedule an in-depth consultation call with our experts. They will be happy to go in deep with your unique situation and provide actionable insights.

Key aspects of getting a new EMI License:

• The ability to mold business strategies and compliance measures from the very beginning.
• Full control, right from the very beginning, over the structure of the company, policies, and setup of operations
• Applicants must invest time, efforts, and resources in the license application process, which may take several months or a year to be finally completed.
• Tremendous expertise is needed to see through the complex regulatory application requirements to their successful completion.
• It is also necessary to go through the risks of uncertainties from possible revisions, etc., by the regulatory authorities during the application process

The key considerations buying a ready-made company with an EMI license:

• A buyer should be able to afford probably higher initial costs of buying an already established company with an EMI license as compared to the costs of a new application. The following is considered key in such acquisitions:
• Buyer has to perform comprehensive due diligence related to the authenticity, compliance status, history, and financial stability of the acquired company.
• A buyer would have to put up with the acquired company’s inherited structures, policies, and operational methods from the purchase, which might not fit the buyer’s vision perfectly.

READY-MADE COMPANIES WITH EMI LICENSE FOR SALE

Eligibility Requirements for the Applicants of UK EMI License

Many applicants for an EMI license in the UK are obliged to satisfy certain eligibility criteria that relate to their EMI’s capability, credibility, and commitment to operate a compliant as well as a trustworthy electronic money business in the UK. These conditions shall be proven through the provision of elaborative documentation and evidence of your compliance mechanism, risk management policy, organizational structure arrangement, and other related information deemed necessary in the assessment of your eligibility for an EMI license in the UK.

Eligibility Conditions for EMI License Applicants in the UK

• Registration of a company in the UK under the Companies Act
• Adequate Initial Capital
• Application Processing Fees
• Own appropriate capital to ensure operational risks and safeguard clients’ funds. Ensure the continued adherence to the set regulatory requirements. This would include setting up proper governance, internal control arrangements, and risk management. The suitability of significant owners should be ensured as well. This will also involve the appointment of reputable directors as well as responsible personnel with appropriate relevant competence for issuing e-money as well as providing payment services.
• Design and implement appropriate arrangements to protect funds belonging to e-money holders and, where relevant, payment service users, including arrangements relating to segregated client funds accounts.
• Design effective compliance procedures, policies, and systems in conformity with AML/CFT requirements.
• Have an appropriate infrastructure, technology systems, and operational capability to safely and effectively carry out electronic money services.
• Make provisions for sufficient insurance covering relevant risks and potential liabilities from business operation.
• Not hinder the effective supervision of your business by the FCA, particularly in cases of close links with other persons (if these links are abroad, ensure foreign laws do not hinder the supervisions carried out by the FCA).

Initial capital for EMI authorisation in the UK:

• €50,000 – In respect of SEMI whose average outstanding e-money is less than 1 mill. EUR
• €100,000 – In respect of SEMI whose average outstanding e-money is between 1 mill. EUR-2 mill. EUR
• €350,000 EUR for AEMIs

EMI own funds requirements in the UK:

• SEMI – 2% of the average outstanding electronic money of the institution
• AEMIs must calculate their own funds in accordance with specific methods instructed by the FCA

EMI license application fees in the UK:

• SEMI – 5,000 GBP (approx. 5,750 EUR)
• AEMI – 15,000 GBP (approx. 17,200 EUR)

Regulatory documentation required for a UK EMI license application:

• Checks: Business plan-products or services offered by the EMI, forecasted income and expenses
• Certificate of incorporation from Companies House
• Memorandum of association
• Articles of association
• Ownership structure-major shareholders, directors, and key personnel
• Background information-qualifications and responsibilities of the directors and officers of the EMI participating in the business: a CV, certificates, etc.
• Due diligence reports on key persons, shareholders, and beneficial owners
• Evidence of possessing the required capital by way of initial capital calculation
• Ongoing capital requirement computation
• Proof of application fee payment
• Forecasted financial statements: P&L statements, balance sheets, cash flow projections, and capital adequacy calculations
• Detailed description of the design of controls necessary to comply with AML/CFT
• Documentary evidence of compliance with other regulatory requirements, including consumer protection, data privacy, and regulatory reporting
• Documents with the EMI’s risk management policy, procedures, and systems for identifying, assessing, and mitigating risks
• Proof of professional indemnity insurance or similar guarantee, provided you are offering AIS and/or PIS
• Business continuity plan and disaster recovery plan
• Security policy and security-related customer complaint policy
• Outsourcing arrangements (if any)

Please note that this is not an exhaustive list of the required documentation, but it should give a good enough idea of the level of preparation in order to obtain an EMI license in the UK. You can rely on us when it comes to compiling, organizing, and drafting the required documentation. We have explicit knowledge of the specific documentation and compliance standards put forth by the FCA in respect to financial licensing and are ready to help you perfect your application package.

How to Set Up a Company for EMI Activities in the UK?

The UK company registration is more or less a straightforward process, which can be done online within 24 hours, provided all the documents are duly prepared in advance. For your EMI you may choose Private Limited Company (LTD), Public Limited Company (PLC), and Limited Liability Partnership (LLP) as legal business structures. Such factors as flexibility in structuring management and operations, suitability to the regulatory framework, among others, make the former the most common legal structure for EMIs in the UK.

The minimum requirements to register a Private Limited Company (LTD):

• At least one shareholder
• At least one director (at least 16 years old)
• A registered office address in the UK where official communications can be sent
• The name selected for the company should not be identical or too similar to an already existing company name in the list of Companies House.
• For incorporation, the company should issue a minimum of one share.

The key steps toward the creation of a UK Private Limited Company (LTD) for EMI licensing are as follows:

• Preparation of the documents with Companies House
• Opening of the UK business bank account
• Key personnel to be appointed
• Pay the incorporation fee, which is only 12 GBP, approx. 14 EUR
• Filing of documents, either online through the website of Companies House or posting paper documents
• Preparation of records concerning the company and accounts
• Register at HM Revenue and Customs for tax purposes
• Apply for an EMI license

The standard timeframe the FCA takes to process an EMI license application is approximately six months from the date of receipt of the application pack. This can, however, be considerably longer or even shorter, depending on the nature of the application and the state of preparedness of the applicant. You are well advised to ensure that each legal requirement has been properly and professionally addressed before submitting your application to avoid delays or even rejection.

Major steps to be performed for the UK e-money license application will include the following:

• You’ll have to fill in and submit the EMI license application form together with the relevant documents via the FCA online portal.
• Upon receipt of the application, the FCA will review it from various angles of compliance, financial, and operational sides.
• While reviewing, the FCA may request additional information or clarification.
• Depending on the nature of the case, the FCA may interview those associated with your EMI.

Purchaser Requirements for a UK Licensed EMI Ready-Made Company

If one is going to purchase a ready company with an e-money license in the UK, he also needs to be aware of some main requirements towards the buyer’s side. Firstly, buyers should prove their financial stability to be capable of operating EMI. Similarly to the license application, directors, officers, and shareholders need to pass the fit and proper criteria set by the FCA.

In this respect, in order for EMI to continue to meet its due legal requirements before the FCA, you should make sure that your desired ready-made EMI company works within the relevant regulatory regime by checking for adequacy and efficiency, existing anti-money laundering and counter-terrorist financing processes, customer protection, data privacy, and other measures legally necessary for the smooth operation of an EMI company. Simultaneously with operational process and document verification, a transition plan has to be drawn up in order to effectively introduce your newly purchased company into your operational framework.

Obtaining an EMI license from the FCA can be your strategic move that determines your business’s success. It is not an easy goal to accomplish, and you should seek guidance from our legal team here at Regulated United Europe who will be delighted to support you in incorporating a company and applying for an EMI license in the UK. The experienced practitioners will also be able to advise on how to obtain a ready company with an already existing UK e-money license. Supported by knowledgeable lawyers, business development professionals, and financial accountants, you will find that setting up your EMI business in the UK is smooth, efficient, and transparent. Immediately contact us for your personal EMI license consultation and set the grounds for long-term success.