FCA EMI Authorisation: A Complete Guide

Electronic Money Institutions issue digital value stored on cards, accounts, or devices. If you're building a fintech that holds customer funds as electronic money in the UK, you need authorisation from the FCA under the Electronic Money Regulations 2011.

What is an EMI?

An EMI issues electronic money — monetary value stored electronically representing a claim on the issuer. An authorised EMI can issue e-money without restriction; a small EMI has a €5 million threshold with lighter requirements but no passporting. Most firms with growth ambitions apply for full authorisation.

Requirements

Initial capital of at least €350,000. Safeguarding is the centrepiece — customer funds must be segregated in a designated account or covered by insurance. Directors must meet fit and proper requirements. Sound governance, risk management, robust IT, and adequate AML controls are all required.

Documents

Regulatory business plan with three-year projections, safeguarding policy and procedures, AML and financial crime framework, operational resilience framework, complaints handling, outsourcing policies, wind-down plan, and individual fitness and propriety applications.

Timeline

Statutory three months, realistically six to twelve months. Questions typically focus on safeguarding, projections, AML, and governance.

Common pitfalls

Weak safeguarding arrangements, underestimating capital requirements as e-money issuance grows, and inadequate AML frameworks around transaction monitoring.

How Complizoom helps

Our EMI packages cover the complete documentation set, from business plan and safeguarding policy through to AML framework and wind-down plan, all tailored to your business model.