FCA Authorisation for Payment Institutions and EMIs

What the FCA assesses for a payments or e-money firm

Payment institutions and e-money institutions are authorised under the Payment Services Regulations and Electronic Money Regulations. Safeguarding of customer funds, capital, and financial crime controls are central to the FCA's assessment.

The 11 questions in this check

1. Business Model & Scope

   Do you have a clear business plan and target market for the permissions you want?

   The FCA expects firms to clearly define their target market and show how the business model supports good customer outcomes and regulatory compliance.

2. Business Model & Scope

   Are the regulatory permissions you are applying for correctly scoped for what you will actually do?

   Applications are commonly delayed when the permissions requested are broader than the business model, or miss activities the firm will carry on.

3. People & Accountability

   Do you have people with the right experience for the senior roles your regime requires?

   The regulator assesses whether the individuals running the activity are competent, capable and fit and proper, with responsibilities clearly allocated (under the SM&CR, the PSD/e-money individual regime or the money laundering rules, depending on your activity).

4. Financial Resources & Safeguarding

   Do you have the capital, safeguarding approach, and financial resources documented for the activity you want to carry on?

   The FCA expects appropriate capital planning, safeguarding arrangements (where relevant) and evidence of sufficient financial resources to support the proposed activity.

5. Compliance Oversight

   Do you have ongoing compliance oversight, monitoring, and complaints handling in place?

   The FCA expects clear responsibility for compliance, active monitoring of risk and controls, and effective arrangements for handling customer complaints.

6. Systems & Controls

   Do you have the systems, records and financial crime controls the activity requires?

   Firms must evidence adequate systems and controls, record keeping, and (where in scope) financial crime and AML arrangements proportionate to the business.

7. Governance & Accountability

   Is there clear board or senior management oversight and accountability for the regulated business?

   The regulator expects governance arrangements that give senior management effective oversight, with clear individual accountability.

8. Ownership & Establishment

   Have you mapped your controllers and beneficial owners, and is the firm's mind and management in the UK?

   The FCA assesses controllers, beneficial owners and group structure, and expects the firm to be capable of effective supervision with its head office and key functions in the UK (a Threshold Condition, or the equivalent condition under the PSRs/EMRs/MLRs).

9. Application Readiness

   Are your application pack and supporting documents drafted and ready to submit?

   A complete, consistent application pack with the required supporting documents materially reduces the risk of delay or a request for more information.

10. Safeguarding

    Have you designed your safeguarding arrangements and can you meet the current safeguarding rules?

    Safeguarding of customer funds (by segregation or insurance/guarantee) is central to the FCA's assessment, and the enhanced rules add reconciliation, reporting and audit requirements.

11. Capital & Own Funds

    Have you identified your initial capital and ongoing own-funds requirement for the services you will provide?

    Initial capital varies by permission and service (some routes, such as account information services, rely on professional indemnity insurance instead), and firms must maintain an ongoing own-funds calculation where it applies.

Common pitfalls

• Safeguarding arrangements not properly designed or evidenced
• Insufficient initial or ongoing capital
• Financial crime and AML framework not proportionate to the model

Read more on our FCA authorisation service, see how we support payments / emi firms, or work through the full authorisation readiness checklist.