We help fintechs and payment businesses prepare for UK authorisation as an electronic money institution or payment institution.
The process starts with choosing the correct regulatory route for the business model and continues through preparation of the full application pack, submission, and support during FCA follow-up.
In the UK, the correct route depends on the services you plan to provide, the structure of the business, and projected transaction volumes.
E-money firms typically fall under the AEMI or SEMI route, while payment firms fall under API or SPI. Small-firm routes have threshold and scope limits, and the FCA expects the application to reflect the real operating model from the start.
We help clients determine the right licensing path, structure the application correctly, and prepare a submission that is complete, tailored and aligned with FCA expectations.
The first step is to determine whether the business should apply as an EMI or a PI, and then whether it falls into the authorised or small-institution route. The FCA also expects firms to clearly define the services in scope and explain whether the model uses agents, branches, outsourcing or other third parties.
Applicants need real UK substance, clear management responsibility, fit and proper controllers and managers, and governance arrangements proportionate to the business. The FCA expects clear reporting lines, internal controls, and appropriate oversight.
Applications must address capital and prudential requirements, safeguarding arrangements where relevant, AML/CTF controls, operational risk, incident handling, business continuity and wind-down planning. For firms within the scope of safeguarding, the framework also needs to address reconciliations, records, and governance around client funds.
The FCA can reject an application without assessment if minimum information is missing. That is why the submission has to be complete, internally consistent, and built around the actual business model rather than generic templates.
Advapay supports UK EMI and PI applications from start to finish. We advise on the right licensing route, help structure the business model, prepare the application documents, provide legal and compliance support, manage the project, and assist with FCA queries after submission.
Depending on the project, the licensing pack may include application forms, programme of operations, regulatory business plan, financial model and forecasts, governance and ownership materials, prudential analysis, safeguarding documentation, AML/CTF framework, operational and security documentation, outsourcing materials and wind-down planning.
For both PI and EMI applications, the FCA usually assesses complete applications in around 3 months. Incomplete applications can take up to 12 months. Current case-officer allocation time is up to 20 working days.
We help you build the right structure, prepare the documents, and manage the submission process from start to finish.
