MEMA Scope · Assessment

Do small payment institutions need FCA authorisation?

A firm providing payment services at modest volumes that wants to register rather than seek full authorisation. Review the initial view below and answer a few questions to refine it.

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  • FCA rule references
  • Follow-up questions available
Initial viewProvisional assessment

Potential regulated activity identified

You may be able to register as a small payment institution

Registration is available where conditions on volume and services are met. Small payment institutions cannot provide payment initiation or account information services.

Route to consider: Registration rather than full authorisation

Payment Services - Execution

Why this was flagged

  • 1Providing payment services by way of business needs authorisation or registration.
  • 2A small payment institution registers rather than being authorised, if it meets the conditions.

Questions still to resolve

Answer to refine the view. The result updates as you go.

  • ?

    Is your average monthly payment volume expected to stay at or below EUR 3m, including transactions by agents?

  • ?

    Do you provide payment initiation services?

  • ?

    Do you also provide account information services alongside payments?Account information alone can be registered separately as a RAISP.

  • ?

    Do you issue cards or acquire card payments?

Regulatory basis to examine

Your next steps

  1. 1Calculate your projected average monthly payment volume and test the threshold
  2. 2Confirm that you provide only the services a small payment institution can offer
  3. 3Prepare your registration and complete AML registration with HMRC or the FCA as applicable
  4. 4Plan for growth: what happens if volumes exceed the threshold

Where applications for this model most often fall short

  • A defensible volume forecast
  • Clear AML policies and a named MLRO
  • A growth plan if you outgrow the threshold
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This is an initial indication from published FCA material, not an FCA determination or legal advice.

Continue with a more detailed readiness assessment

If authorisation is required, check the firm’s governance, policies, resources and application preparedness.

Will the FCA Authorise Us?

MEMA Scope gives an initial view from published FCA material. It is not legal advice or an FCA determination. Automatic matching and typed questions use AI only to choose a profile and to answer from vetted guidance; the assessment itself is never written by AI.

About this business model

A firm providing payment services at modest volumes that wants to register rather than seek full authorisation.

Registration is available where conditions on volume and services are met. Small payment institutions cannot provide payment initiation or account information services.

This page gives an initial view from published FCA and legislation sources. It is not an FCA determination or legal advice. Not your business model? Describe your business in MEMA Scope.

Small payment institution: frequently asked questions

Can I register as a small payment institution?

Registration is available if your payment services meet the volume and service conditions in the PSRs, broadly an average of no more than EUR 3m per month and no payment initiation or account information services.

Do small payment institutions have to safeguard customer funds?

Authorised payment institutions must safeguard relevant funds; for small payment institutions safeguarding may be voluntary, but you should check the current rules for your situation.

What could change the answer for small payment institutions?

Registration is available where conditions on volume and services are met. Small payment institutions cannot provide payment initiation or account information services. It can change depending on the answers to questions such as: Is your average monthly payment volume expected to stay at or below EUR 3m, including transactions by agents? Do you provide payment initiation services? Do you also provide account information services alongside payments? Do you issue cards or acquire card payments?

Which FCA rules should small payment institutions look at first?

Start with: Conditions for registration as a small payment institution; Payment services; FCA: payment institution applicants; Perimeter guidance on the PSRs. This is an initial view from published FCA material, not an FCA determination.

What are the first steps for small payment institutions?

Calculate your projected average monthly payment volume and test the threshold. Confirm that you provide only the services a small payment institution can offer. Prepare your registration and complete AML registration with HMRC or the FCA as applicable. Plan for growth: what happens if volumes exceed the threshold.

Businesses we check

MEMA Scope covers 32 common business models. Each page explains whether that kind of business may need FCA authorisation, the rules to look at and the routes to consider.

Want a consultant to look at your facts?

Book a free scoping call and we will map the permissions, evidence and timeline for your firm.