This article is intended as a practical guide only. EMI authorisation and registration requirements depend on the details of your business model, permissions, governance, safeguarding arrangements, and customer funds flow. Firms should take specialist legal or regulatory advice before applying.

If you’re researching how to get an Electronic Money Institution (EMI) licence in the UK, there’s a good chance you fall into one of these categories:

• You already have customers, revenue, and scale, but your current setup is starting to limit what you can build. 
• You’re operating as an agent or distributor under another EMI’s licence and think it might be time for more control over what you offer. 
• You plan to expand into the UK and need to understand what the FCA (Financial Conduct Authority) expects before you apply.

No matter your situation, getting authorised is far from guaranteed. In fact, in 2025, there were 155 EMI licence applications and 35 approvals, an approval rate of just under 23%.  

To give yourself the best chance, remember that an EMI licence is a major business undertaking. It can be expensive and demanding. For a small, well-prepared fintech, total costs may be below £1 million. For a more ambitious business building a robust platform, hiring experienced staff and funding itself through a lengthy FCA process, it can often cost several million pounds when you factor in all the requirements needed to show the FCA you’re ready to operate. 

In this article, we talk about how to get an EMI licence, and when other routes may be a better fit for your business goals.

We’ll cover:

• What is an EMI licence?
• Why do firms apply for an EMI licence?
• How much does an EMI licence cost?
• How long does it take to get an EMI licence?
• Does it make sense for you to get an EMI licence?
• Alternatives to applying for an EMI licence
• How to get an EMI licence step by step
• Why work with ClearBank to make your EMI licence journey smoother 
• Case study: How ZEN.COM secured its UK EMI licence in partnership with ClearBank

ClearBank is a UK- and EU-authorised B2B bank that provides banking infrastructure for regulated financial institutions, including firms preparing to operate as EMIs. If you’re considering applying for an EMI licence, get in touch with our team.

An Electronic Money Institution licence allows firms to issue electronic money, or e-money. Depending on the permissions a firm receives, it can support products such as digital wallets, payment accounts, stored-value balances, and other payment services.

There are different routes to becoming an EMI depending on your size and activity. You may apply for full EMI authorisation, or you might be eligible for small EMI registration if you plan to issue e-money at a smaller scale. In some cases, a payment institution licence, or another model entirely, may be a better fit for the services you want to provide. 

One thing to note is that an EMI licence is not the same as a banking licence. EMIs can issue e-money and provide payment services, but they cannot take deposits or pay interest on those deposits as a bank can.

You might have already gone to market under another authorised EMI’s licence, which worked quite well early on. The reasons to apply for your own licence usually become clearer as your business scales.

We find that firms typically choose this path because of three factors:

1. Risk. If your firm is working under another’s EMI licence, you’re always answerable to that licenced firm. If the EMI runs into regulatory issues, restricts activity, or slows down approval, you could feel the impact.

   For example, if the EMI you’re working under decides it no longer wants to support a certain geography, you may have to pause onboarding or change to a different product. 
    

2. Cost. Operating through another EMI adds another link to the already complex chain of managing payments. Each link can add fees and complexity. 

   For example, a fintech operating through another EMI may be paying the licenced EMI, as well as the underlying banking infrastructure provider. Applying for its own licence can remove one link from the chain, potentially reducing long-term costs.
    

3. Control. With your own licence, you become “the master of your own destiny,” with more room to shape your product and operating model. While your model needs to be approved by the FCA, you’re no longer limited by another EMI’s rules.

   Say a payments business wants to launch a new electronic wallet feature. If it’s operating under another EMI, those changes may depend on the EMI’s permissions and product rules. With its own licence, the firm has the freedom to build a variety of products, as long as they’re compliant with the FCA. 

The FCA application fee for an authorised EMI licence is £5,580 (Category 5). The application fee for a Small EMI licence is £1,120 (Category 3). 

But the full cost of becoming an EMI is much broader. For one, you need the infrastructure and capital to operate after authorisation.

What’s more, hiring is often one of the highest costs. Senior roles like a UK MLRO, Head of Financial Crime, or CFO take time and major investments to retain, along with the necessary support staff for related systems and controls. 

Other costs may include:

• Initial capital requirements: You need enough capital to meet the FCA’s threshold and support the business after authorisation.
• Legal and advisory support: Specialist advisers can help you scope your permissions, prepare the application, and avoid costly rework.
• Compliance and financial crime systems: You need controls that show how you’ll manage AML, CTF, sanctions, and other financial crime risks.
• Safeguarding setup: A clear model for segregating, reconciling, and protecting customer funds.
• Banking partner costs: Accounts, payment rails, and infrastructure to operate once authorised.
• Technology and API integration: You may need to build connections between your platform and your banking infrastructure.
• Ongoing compliance and reporting: After authorisation, you’re required to keep meeting FCA oversight and expectations through governance and reporting. 

While these factors vary significantly based on your current infrastructure, it’s common to see the full cost amount to several million pounds. 

Your preparation period can take a long time before the clock even starts. You may spend months defining the model, hiring key staff members, preparing policies, choosing advisers, designing safeguarding flows, and building your operational evidence.

But the formal timeline for authorisation depends on the quality of your application and the complexity of your business model. 

The FCA's statutory assessment period is three months for a complete application and up to twelve months for an incomplete application. In practice, authorisation timelines are often longer when preparation and pre-application work are taken into account.

Note that authorisation is not the same as launch readiness. You can receive your licence, but you still need to complete your setup, including safeguarding arrangements and technical integration, before going live.

One way to shorten the route to launch is by preparing your banking infrastructure and API integration during the licencing process, instead of waiting until after authorisation. 

For example, you can open a safeguarding account with ClearBank before your EMI licence is granted. We restrict account activity until you receive authorisation. And if you get your licence, your account can be ready to start using right away. 

• Weak safeguarding arrangements
• Inexperienced senior management team
• Unrealistic financial forecasts
• Poorly documented AML and financial crime control
• Unclear customer journey and funds flows
• Over-reliance on outsourced providers

At ClearBank, we often see firms request an account in the hope of getting an EMI licence. But many of those accounts go unused once the firms realise the cost and ongoing efforts required for the application process and authorisation. 

Applying for an EMI licence usually makes sense only when your business has reached a reasonable level of maturity. That might include demonstrating a steady customer base, revenue, scale, operations, or EMI licences in other countries. 

If you’re too early to demonstrate this, you might struggle with the application and approval process. The FCA expects to see:

• Enough capital to meet the FCA’s initial and ongoing capital requirements, based on your activities and scale
• A clear, working business plan
• Experienced senior management and board
• Adequate financial crime prevention and management systems 
• A robust safeguarding model 

Not every business needs to become a licenced EMI. Sometimes, you need a setup that better supports your goals. Options include:

• Work with a different partner to expand your use cases. Whether you replace or add another banking or EMI partner, this could be easier than getting a full licence.
• Register as a small EMI (SEMI) if less than €5 million is needed. If you’re only planning to issue e-money on a small scale, the application for an SEMI is less rigorous.
• Become a registered payment institution (PI). If you’re only looking to provide services that move money and not actually issue e-money, then you may only need to become a payment institution.

If you’ve decided to go ahead and become an EMI, we’ve written a quick 7-step guide to keep at hand:

Review the FCA’s requirements for electronic money institution applicants. Define exactly what you want to offer, who your customers are, how money will move through your business, and what regulated activities you need permissions for.

Work with legal or advisory firms that specialise in FCA applications to help prepare your application pack and stress-test your business model. This can be an area where it’s tempting to cut costs, but weak advice can cost more later if your application is poorly scoped or your evidence is incomplete. Good advisers can help you understand what the FCA expects and prepare a stronger application pack. More importantly, they can help you avoid mistakes that create delays or extra costs.

ClearBank can connect you with advisers we’ve successfully worked with in the past. 

The FCA’s pre-application support service (PASS) lets you request a pre-application meeting before submitting your application. This gives you a chance to improve your submission by asking questions and discussing your plans. 

To request a meeting, register through FCA Connect and provide details of your proposed application and key questions you want to cover. 

Build an application pack that clearly shows how your business will operate as a regulated firm. Avoid relying on generic policies and templates; your advisers can help you make your application specific to your business model. 

Refer to the FCA’s guidance on how to apply to become an electronic money or payment institution.

Explain how customer funds will be protected, including segregation and reconciliation processes. This includes defining who your banking partner is and how your payment flows are structured. You’ll answer detailed questions about how funds are handled, such as whether they are safeguarded on receipt or swept into a dedicated safeguarding account.

Note that in 2026, the FCA updated safeguarding requirements that EMIs must follow.

Submit your application through FCA Connect.

After this, expect to respond to additional FCA questions, requests for clarification, and challenges to your operating model.

You can begin preparing your banking setup before approval rather than waiting until authorisation. Partners like ClearBank can support safeguarding and API readiness in parallel with your application. 

ClearBank is a UK- and EU-authorised B2B bank built to provide banking infrastructure for regulated financial institutions. With over £18 billion in client deposits, we support EMIs through our agency and embedded banking solutions.

While we don’t act as a formal licencing adviser, we can support you as you prepare your application by helping you evidence the banking infrastructure behind your EMI model. This can include:

• A banking partner letter: During the FCA application process, you may need to show that you’re in discussions with a banking partner. When working together, ClearBank can provide a signed letter confirming that those discussions are happening. 
• A locked safeguarding account: As your application progresses, you may need to demonstrate that you have opened a safeguarding account, even though you don’t yet have the licence. ClearBank can open a safeguarded account with debit and credit facilities locked until authorisation.
• A safeguarding model backed by central bank accounts: ClearBank holds sterling client funds in accounts at the Bank of England, helping you show the FCA where customer funds will be safeguarded and why the model is robust.
• A sandbox environment to start your build earlier: While the FCA process is ongoing, you can access ClearBank’s sandbox simulation environment and begin building your API integration in the background. That means you’re not waiting until authorisation to start the technical build.
• A faster route from authorisation to launch: Once your EMI licence is granted, ClearBank can unlock your safeguarded account and switch on live payment processing. Because your safeguarding setup and API integration are already in progress, you can move faster from approval to go-live.

ClearBank can also provide introductions to relevant legal or advisory firms if you’re looking for specialists while preparing your application pack. 

Beyond EMI application readiness, here’s how ClearBank supports your operating model once you’re authorised:

Through ClearBank’s agency banking, eligible regulated firms can access accounts and payment scheme connectivity without becoming direct scheme participants themselves. This includes Faster Payments, CHAPS, and Bacs.

ClearBank supports different account types depending on how you need to hold and manage funds. For example, you can use operating accounts for your own business funds, customer segregated accounts to hold customer funds separately, client money accounts regulated under CASS, and multi-currency accounts to hold up to 11 currencies under one IBAN.

You can also choose between real and virtual account structures:

• Real accounts give you and your customers publicly addressable accounts
• Virtual accounts enable you to assign unique account details to customers, with all virtual accounts linked to ClearBank real accounts

This can make reconciliation easier, especially if you need to track funds across a growing number of users or use cases.

As your product matures, you may want to offer more banking capabilities inside your own customer experience.

Embedded banking allows you to offer customers FSCS-protected, interest-bearing accounts. This can help you create new revenue opportunities and deepen customer engagement without needing to become a bank yourself. 

In fact, ClearBank’s commissioned Forrester Total Economic Impact™ study found that our embedded banking proposition delivered £9.7 million in business growth benefits for our clients, from product expansion to cross-selling opportunities. 

ZEN.COM, a leading European fintech company, wanted to strengthen its position in the UK market and support further international expansion. Securing an EMI licence was just the first piece of the puzzle. It also needed a banking partner for the infrastructure behind its UK proposition.

ClearBank partnered with ZEN.COM during its EMI licence journey, providing the infrastructure and regulatory insight needed to navigate the FCA’s requirements. ZEN.COM can now offer financial services in the UK, while strengthening its proposition for consumers and businesses.

“ClearBank’s proven infrastructure and deep regulatory knowledge enabled us to progress quickly towards smooth integration and readiness.” – Michał Bogusławski, CEO Europe at ZEN.COM

Read the full case study: ZEN.COM partners with ClearBank to secure UK EMI licence, expanding financial solutions for UK users

Getting an EMI licence can give you more control and less dependency on another EMI to shape your product.

But the licence is only one part of becoming an EMI. You also need the right people and systems in place to demonstrate that your business is ready to operate as a regulated financial services firm.

ClearBank helps you prepare to operate as an EMI by putting the right banking, safeguarding and technical infrastructure in place before and after authorisation. 

If you’re applying for an EMI licence or deciding whether it’s the right route for your business, ClearBank can show you what it takes to move from application readiness to launch.

Get in touch with our team today.