UK EMI License in 2026

UK EMI license 

• Tetra Consultants can assist you in obtaining a UK Electronic Money Institution (EMI) license from the Financial Conduct Authority (FCA). Our team of lawyers, legal experts and regulatory consultants helps you through the entire Electronic Money Institution authorization process, ensuring that your application is well-structured.  

• We also ensure that your business plan is well-written, and your application meets the Electronic Money Institution license requirements set by the Financial Conduct Authority, including those on capital, corporate governance, anti-money laundering/combating the funding of terrorism, and information technology, among others. 

• Gaining access to an Electronic Money Institution license allows your business to successfully operate in the issuance of electronic money, the execution of payment transactions, and the delivery of innovative payment services in the UK, as well as in the entire European Economic Area in the case of an Authorised Electronic Money Institution license.  

What is an electronic money institution?

• An electronic money institution, abbreviated as EMI, is a financial entity that is authorised to conduct the business of issuing electronic money as well as provide payment services to customers. EMIs store money in electronic form, like e-wallets or virtual accounts, and facilitate payments, transfers, as well as card transactions without the ability of the EMI to act as a bank, lending money to customers. 

Regulatory authority for UK EMI license in 2026

• The key financial authority for a UK EMI license in 2026 will be the Financial Conduct Authority (FCA), who will oversee and regulate electronic money institutions under the UK’s financial services legislation. 

• The financial legislation and instruments for a UK EMI license will include the Electronic Money Regulations 2011 (EMR), the Payment Services Regulations 2017 (PSR 2017), implementing the revised Payment Services Directive (PSD2), the UK’s AML/CTF legislation under the Money Laundering Regulations (the UK has not adopted 6AMLD), and the level of regulation from the FCA in respect of prudential capital (minimum of €350,000), safeguarding audit (annual audit of safeguarding processes), transaction monitoring/sanctions screening, and strong customer authentication (SCA).  

• Additionally, forthcoming regulations will place emphasis on digital operational resilience, including robust API/SDK integration and IT security controls for EMI-level payment infrastructure.  

• For firms who are serving EU clients or operating group entities within the European Union, the EU Digital Operational Resilience Act (DORA) will also be relevant. While DORA is not directly applicable under UK law, UK-based EMIs with EU exposure should ensure compliance with DORA requirements when serving EU markets or interacting with EU-regulated entities 

What are the regulatory requirements for obtaining an EMI license in the UK in 2026?

• The applicant has to be a company incorporated in the UK under the Companies Act, with its registered office in the United Kingdom. 

• The business has to have at least an initial capital of €350,000 (or the equivalent in other currencies) if the EMI is an Authorised EMI; Small EMIs, on the other hand, have lower capital requirements, but they are restricted to operating within the UK. 

• The EMI has to ensure the safe storage of client money in client bank accounts that are segregated from the EMI’s own money, or through an insurance model, as per the Electronic Money Regulations (EMR). 

• The EMI has to have sufficient own resources as well as an effective capital adequacy model, taking into account ongoing business risks. 

• A business plan has to be developed by the company, including the business plan, product plan, target markets, revenue, cost, as well as capital adequacy projections, at least for the first 3-5 years. 

• The EMI shall have sound governance, internal controls, and risk management systems, including operational, IT, and credit/liquidity risks, that are acceptable to the FCA. 

• The operator shall have an effective AML/CFT system that covers aspects of KYC, CDD, TM, SS, and SAR. 

• The EMI shall have sound IT infrastructure, including data protection that meets the UK GDPR and FCA security requirements. 

• The firm shall have professional indemnity insurance in place if it is seeking to provide Account Information Services (AIS) or Payment Initiation Services (PIS). 

• The applicant shall provide detailed documentation, including constitutional documents, ownership structure, forecasted financial statements, risk management policies, AML/CFT manuals, etc. 

Key person requirements

• The EMI must have at least one director or executive with day-to-day responsibility for the e-money business, and there must be no restriction on their place of residence. 

• The EMI must have a compliance officer with experience and expertise in financial services regulation and AML/CFT. 

• The EMI must have a Money Laundering Reporting Officer (MLRO) with experience and expertise in AML/CFT. 

• Directors and individuals with significant influence (PSCs/PEPs) must be of good reputation, have no criminal record or adverse media reports, and must pass fit and proper tests at FCA levels. 

• The EMI must ensure that no disqualified person is involved in the management or ownership of the EMI. 

Who is exempted from getting a UK EMI license?

• Payment services provided by banks and credit institutions already authorised under the FSMA are exempt from the need to obtain a UK EMI license. 

• Small EMI (SEMI) business below specified thresholds may be eligible for the lighter regime of registration only instead of full EMI authorisation. 

• Some exempt persons defined by the Financial Services and Markets Act 2000 (Exemption) Order (as amended by the 2026 amending regulations) are exempt from the general prohibition on carrying out E-money business. 

• Intra-group or ancillary e-money business, such as closed loop schemes used within a single corporate group, may be outside the scope of the need to obtain a retail-focused EMI license. 

• Some forms of non-commercial or low-risk payment handling business (for example, agent-only or back end only infrastructures) may be considered as exempt or TFE by FCA-level guidance in the 2026 regime. 

What are the types of EMI?

There are two main types of e-Money institutions in the UK:  

Authorised EMI (AEMI) 

• An AEMI is a fully licensed EMI, authorised by the FCA, permitted to issue e-money and offer various payment services without any restriction on volumes, as long as it has a minimum initial capital of €350,000, as well as full safeguarding and anti-money laundering requirements. 

Small EMI (SEMI) 

• A small EMI has a lighter regime with lower thresholds for average outstanding volumes of e-money and related payment volumes, permitted to operate only in the UK and is appropriate for startups or small-volume operators, which can then become AEMIs if they exceed these thresholds. 

Why do you need a UK EMI license?

• A UK EMI license is a fantastic choice in 2026 as it will provide a fintech or a payment business with a legal license to provide electronic money services and issue e-money in the United Kingdom, with a clear regulatory framework under the FCA. It is a license that will promote innovation in digital wallets, borderless payments, and embedded finance, with credibility with partners, banks, and customers in a high-trust location. 

What are the benefits of having a UK EMI license?

As an authorised EMI you will have the following benefits:  

• You will acquire an English SWIFT code for transactions 

• You will be able to issue English IBAN accounts for your clients 

• You will be able to register accounts remotely for individuals and companies 

• You will be able to issue credit and debit card payments linked to your customer accounts 

• Your company will be able to perform bank payments in more than 45 currencies worldwide 

• You can accept payments from all international accounts that use the SWIFT system 

• Create correspondent accounts in different countries 

• Establish an AML function 

• Your financial services are VAT-exempt in the UK 

• No restrictions regarding the turnover of the company 

What is the procedure for obtaining a UK EMI license?

The procedure to set up an electronic money institution may vary depending on the amendments taking place in the local laws and regulations. Tetra Consultants has summarized the most prevalent steps that take place during the normal engagement of attaining the EMI license.