FCA EMI Authorisation: Post-Brexit Reality
The UK's exit from the European Union on 31 December 2020 ended automatic passporting rights for UK-authorised payment institutions. UK EMI licences are now governed exclusively by UK domestic law — the Electronic Money Regulations 2011 (EMRs) and Payment Services Regulations 2017 (PSRs) — rather than the EU Electronic Money Directive 2 (EMD2). The practical effect is that UK EMIs serve the UK market only, and companies wanting to serve EU customers must separately obtain an EU EMI licence.
Despite the loss of EU passporting, the FCA EMI authorisation remains highly valuable. The UK is home to Europe's largest fintech ecosystem, with over 3,000 fintech companies and a mature consumer market of 67 million people. The UK's open banking framework (mandated under the CMA's Open Banking remedies) provides unparalleled access to bank account data and payment initiation capabilities. Faster Payments, CHAPS, and Bacs give UK EMIs access to real-time and same-day sterling payment infrastructure.
The FCA is widely regarded as one of the most credible financial regulators globally. FCA authorisation carries significant reputational weight with institutional clients, investors, and global banking partners. Many global fintech companies maintain FCA-authorised entities specifically for the brand value and institutional credibility it provides, even when the UK is not their primary market.
For crypto businesses, the FCA also administers the cryptoasset AML/CTF registration under the Money Laundering Regulations 2017 (MLRs). Companies planning to combine EMI services with crypto activities will need both FCA EMI authorisation and MLR crypto registration — making FCA the single regulatory relationship for all UK-facing financial activities.
FCA EMI Application Requirements
UK Open Banking Ecosystem Advantage
The UK's Open Banking framework, mandated by the Competition and Markets Authority (CMA) and implemented since 2018, gives FCA-authorised payment institutions unparalleled access to banking data and payment initiation capabilities. The nine largest UK banks are required to provide open APIs for account information and payment initiation, creating an infrastructure layer that EU countries are still developing through PSD2 implementation.
UK EMIs authorised as Payment Initiation Service Providers (PISPs) can initiate direct bank payments on behalf of customers — enabling account-to-account payment products that compete with card payments. UK EMIs authorised as Account Information Service Providers (AISPs) can aggregate bank account data across all UK banks, enabling lending underwriting, financial management apps, and identity verification use cases.
The open banking ecosystem creates significant opportunities for crypto companies. Account-to-account payment initiation enables direct GBP deposits to crypto exchanges without card processing fees. AIS capabilities enable automated identity verification and source-of-funds checks. The FCA's Innovation Hub (formerly Project Innovate) provides direct support for fintech companies building novel products on open banking rails.
UK FCA EMI Licence Cost Breakdown
| Item | Details | Cost |
|---|---|---|
| Regulatory Capital | Minimum paid-up capital (EMR 2011, Reg. 19) | £350,000 |
| FCA Application Fee | EMI authorisation application fee | ~£5,000 |
| UK Company Incorporation | Companies House registration, articles, etc. | £1,000–£3,000 |
| Legal & Compliance Preparation | Application pack, AML policy, business plan | £35,000–£80,000 |
| Senior Manager & Director Appointments | SMF applications, fit-and-proper preparation | £5,000–£15,000 |
| AML/Compliance Officer (Year 1) | UK-based MLRO and compliance setup | £25,000–£60,000 |
| FCA Annual Fee | FCA periodic fee based on regulated revenue | £3,000–£20,000/yr |
| Office & Operational Setup | UK office, banking, technology | £10,000–£30,000 |
| Total Year 1 (excl. capital) | Professional fees and setup | £79,000–£208,000 |
| Total Year 1 (incl. capital) | Full investment including regulatory capital | £429,000–£558,000 |