FCA Authorisation: EMI, Payment Institution & VASP

FCA authorisation for an EMI typically takes 6–12 months from submission of a complete application. The FCA has a statutory determination period of 12 months from receipt of a complete application (or 6 months if it receives all required information). Key stages include: pre-application meetings (2–3 months preparation), formal application review (3–6 months), and FCA queries phase. A compliant applicant should budget 12–18 months total including preparation.

UK Virtual Asset Service Providers (VASPs) — businesses offering cryptoasset exchange, custody, or transfer services — must register with the FCA under the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (MLRs). This is a registration (for AML compliance purposes only), not a full authorisation. The FCA's VASP register is separate from the Electronic Money Institution register. Registration typically takes 3–6 months and does not confer any financial promotion permissions.

An Authorised EMI must maintain initial capital of €350,000. Ongoing own funds requirements are calculated using a percentage of outstanding electronic money (Method A, B, or C under the Electronic Money Regulations 2011). Safeguarding requirements mandate that EMIs segregate client funds in a designated account at a credit institution, or hold qualifying liquid assets, covering 100% of outstanding electronic money at all times.

Yes. A Payment Institution under the Payment Services Regulations 2017 (PSRs) can provide services such as payment account operation, payment transaction execution, money remittance, and card issuing. Small Payment Institutions (SPI) have lighter requirements for volumes under €3m/month. Authorised Payment Institutions (API) require initial capital of €125,000 (for money remittance) to €125,000 or €730,000 depending on service scope. Timeline is typically 6–12 months.

The FCA's Innovation Pathways programme offers direct support to innovative financial businesses that do not fit clearly into existing regulatory categories. Firms can request a dedicated FCA supervisor to discuss regulatory requirements before applying for authorisation. This is separate from the Regulatory Sandbox (now part of the Digital Sandbox), which provides a live testing environment. Both are open to startups; there is no minimum revenue or AUM requirement.