Guides · Payment
Payment licence types
“Payment licence” is not one thing. Name the type on the register before you price the deal or file the application.
Covers payment services, e-money, remittance, and open banking participants — not general banking. Pair with the glossary and registration ≠ licence.
The types you’ll hear
UK · EU
Payment institution (PI)
Authorised payment services — execution, remittance, acquiring, and related schedule items.
Authorisation
UK · EU
E-money institution (EMI)
Issues electronic money. Different capital and safeguarding from a PI.
Authorisation
UK
Small PI
Lower-volume exemption. Often sold as a full “payment licence.” It is not.
Not full PI
UK · EU
Agent of a PI
Operates under someone else’s authorisation. May not travel on a share sale.
No standalone PI
US
MSB
FinCEN money services business. Federal AML paperwork — not a state licence.
Registration
US
MTL
State money transmitter licence. Often the real gate beside FinCEN.
Licence · state-by-state
Singapore
MC / SPI / MPI
Payment Services Act classes. Thresholds and activity lists decide the class.
Licence
UAE
PSP / stored value
CBUAE payment categories — not VARA crypto, not free-zone by default.
Licensing / approval
UK · EU
AIS / PIS
Open banking account information or payment initiation. Narrow scope.
Narrow permission
What each seat usually means
United Kingdom
Look for PI vs EMI vs small PI vs agent on the FCA Register. Schedule-limited services — the list matters.
European Union
PI / EMI under PSD2 / EMD2. Passport claims need host-country notifications — not a silent pan-EEA stamp. Bank licences that do payments use a different CoC track.
United Arab Emirates
Name the seat: CBUAE (payments / stored value), VARA (crypto), or ADGM / DIFC. “UAE payment licence” without that name is incomplete.
Singapore
Class on MAS FID (MC / SPI / MPI) plus activity list. SPI running MPI volumes is a red flag. DPT can sit in the same PS Act family — still check the class.
United States
FinCEN MSB is registration. State MTLs are licences. Underwrite the grid, not the federal stamp alone.
South Africa
Payment-rail oversight (SARB / NPS) is not FAIS crypto product licensing. “Licensed for crypto payments” needs both nouns parsed.
Traps
- No type on the slide Ask which: PI, EMI, agent, SPI/MPI, MSB-only, or MTL grid?
- Agent sold as principal The permission may not move with the shares.
- Safeguarding as a PDF Want bank letters and reconciliations, not a policy brochure.
- MSB without MTLs Federal registration does not clear the states that matter.
One check this week
Pull the live register entry. Write down the permission type in the exact words on the file. If the deck says something softer, that gap is the diligence.
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Not legal advice. Not a jurisdiction-shopping guide. Verify the live register; instruct local counsel.