What the regulator is really asking
Payment and e-money firms hold other people's money — often for no more than a day, often across borders, and usually through partners they do not control. The questions that decide an application follow from that: where the money sits and how it is protected, what happens to it if the firm fails, and whether the people and systems between the customer and the bank can be trusted with it.
Safeguarding
Segregation or insurance, the safeguarding account and the bank behind it, the reconciliations and the governance around them. In the UK the FCA's supplementary safeguarding regime has applied since 7 May 2026, and an application now has to show how the firm will meet it from its first day of trading, not afterwards.
Wind-down
A credible plan for closing the firm in an orderly way and returning customers' money — costed, with triggers, and consistent with the financial projections. Regulators read this document more closely than most applicants expect.
Capital and own funds
Initial capital set by the services the firm provides, and an own-funds calculation that follows its volumes. The projections, the capital and the safeguarding model have to tell the same story.
Agents, distributors and outsourcing
Every agent has to be registered and every distributor notified, and each has to be overseen. Every critical outsourced function — card processing, banking services, identity checks — needs a contract and an exit plan the regulator can follow.
Financial crime
Payment flows are where money laundering moves fastest. Transaction monitoring, sanctions screening and a customer risk model that fits the firm's actual corridors and customers carry more weight here than almost anywhere else.
Small institutions, and the step up
Small payment institutions and small e-money institutions carry a lighter application and lighter capital requirements, in exchange for a ceiling on volumes. A firm that grows through the ceiling has to become authorised, and the step up is a full application in its own right. It is far better planned before the ceiling than after it.
Across the EU
In Cyprus, payment and e-money institutions are licensed by the Central Bank of Cyprus; in Malta, by the MFSA. An EU licence carries the passport, and with it the expectation of real substance in the home state. Where a firm needs both a UK authorisation and an EU one, we plan them together, so that the business model, the safeguarding arrangements and the people line up across both.