Guides · UK · Chapter 01
UK payments — PI / EMI
Authorised payment institutions and e-money institutions under the PSRs and EMRs — instruments first, then the FCA’s Approach Document, then the register string.
In this chapter, read in order
Types on the UK file
Authorisation
Authorised PI
Payment services under the PSRs — scope is schedule-limited. Read the activities list.
Prudential + conduct
Authorisation
EMI
Issues e-money under the EMRs. Capital and safeguarding differ from a PI.
Not the same as PI
Exemption
Small PI
Lower-volume path. Often mislabelled as a full payment licence.
Not full PI
Narrow
AIS / PIS
Open banking account information / payment initiation — not a general PI story.
Limited permission
Cross-seat map: Payment licence types
Legislation
- PSRs 2017 Payment Services Regulations 2017 Authorisation conditions, registration, safeguarding (reg 23), conduct of business.
- EMRs 2011 Electronic Money Regulations 2011 EMI perimeter, authorisation / registration, e-money rules.
- Safeguarding detail PSRs reg 23 — safeguarding requirements
FCA guidance & approach
- Key publications EMI & payment services — key publications Approach Document versions live here — use the latest “Our Approach”.
- Approach PDF Our Approach — March 2026 (PDF) How the FCA expects firms to read the PSRs/EMRs — start here after the statute.
- Safeguarding hub Safeguarding for PIs and EMIs Segregation vs insurance/guarantee; monthly reporting expectations.
- AIS / PIS Account information & payment initiation services
- Handbook FCA Handbook CASS and SUP chapters that bite authorised PIs/EMIs.
- Publications FCA publications Search consultation papers and policy statements for payment / e-money.
Authorisation & registration
- Hub Approvals and registrations
- Apply hub Apply to become an EMI or payment institution
- PI detail Payment institution applicants Conditions and supporting material for API / SPI.
- Portal FCA Connect Where complete files are lodged and tracked.
- Register FCA Financial Services Register Confirm type, activities, and status after authorisation.
Safeguarding — what buyers check
Authorised PIs and EMIs must protect relevant funds (segregation or insurance/guarantee routes under the regulations). Diligence is not a policy PDF — it is bank letters, reconciliations, and whether the method on the file matches what the firm claims.
- FCA Safeguarding requirements page
- Statute PSRs regulation 23
Change of control
Many authorised payment and e-money firms sit under FSMA Part XII controller thresholds (commonly discussed at 10/20/30/50%). Prior approval is a closing condition — not a post-completion tidy-up. If the firm is also on the crypto MLR register, map both CoC tracks.
- FSMA Change in control
- Crypto overlap Cryptoasset firms — change in control
Traps
- “Payment licence” with no type PI, EMI, small PI, or agent?
- Agent sold as principal Permission may not travel with the shares.
- EMI float vs capital Outstanding e-money liabilities must sit against a real safeguarding story.
- Open banking contracts AIS/PIS partner terms often terminate on change of control.
One check
On the FCA Register, write down: PI or EMI, listed activities, and whether the firm is an agent. If the deck disagrees, that is the diligence.
Next: UK crypto dual track · UK library · SKU-01
Not legal advice. Confirm every link on the live FCA / legislation.gov.uk page before you rely on it.