Small electronic money institution (small EMI)

First published: 22/09/2017 Last updated: 23/08/2019

PSD2 introduces a number of changes to requirements that small EMIs must follow. The Treasury has implemented these through the PSRs 2017 and the FCA has published its Policy Statement and Approach Document.

Please also familiarise yourself with the relevant parts of the FCA Handbook which are changing, including SUP 15,* SUP 16* and DISP*. The Handbook is amended by the Payment Services Instrument 2017 and you can see the revised Handbook on our Handbook website by setting the date to 13 January 2018.

If you have any questions, you can contact us.

Answer the following questions to understand more about what you need to do to meet new PSD2 requirements:

Do you intend to issue e-money after 12 July 2018?
Please select:

1. Small EMIs wishing to issue e-money after 12 July 2018 must be re-registered under PSD2. To do this they must provide us with new information.                                                              

2. Small EMIs can apply to be re-registered from 13 October 2017 and must have submitted their applications before 13 April 2018. Small EMIs must be successfully re-registered by 13 July 2018. There will be a fee of £250 for re-registration.

3. FCA encourages applications to be correctly completed and submitted as early as possible. Small EMIs that have not successfully been re-registered by 13 July 2018 will have to stop issuing e-money and providing payment services (and they will no longer be able to provide payment services through agents); the FCA will update the Financial Services Register to reflect that these businesses will no longer be registered. You can find further information on our Registration pages.

4. All small EMIs which are account servicing payment service providers (ASPSPs) also need to comply with requirements relating to AIS and PIS providers seeking access to their customers’ online payment accounts (Chapter 17 in our Approach Document).

1. You do not need to apply to re-register. If you do not apply for re-registration before 13 April 2017 this will automatically mean that you are unable to continue to provide payment services after 12 July 2018. Alternatively, you could submit the cancellation form.

2. Please note you still need to comply with the new PSD2 requirements from 13 January 2018 until you are no longer registered.

Do you intend to offer account information services (AIS) or payment initiation services (PIS)?
Please select:

1. Small EMIs are not permitted to provide AIS or PIS. This means that you can no longer operate as small EMIs (unless you are affected by the transitional provisions for certain businesses operating prior to 12 January 2016). You will need to apply to be authorised as an authorised electronic money institution (authorised EMI) if you wish to offer these services.​​​​​​​​​​​​​​ You can find further information on our Authorisation pages.

2. Small EMIs that provided AIS or PIS in the UK before 12 January 2016 and continue to provide these services immediately before 13 January 2018 will be able to continue providing these services in the UK from 13 January 2018 without authorisation, but they will not benefit from the rights of access provided under PSD2. The ability for these businesses to continue providing AIS and PIS will continue until the date which is 18 months after the European Banking Authority (EBA) Regulatory Technical Standards on strong customer authentication and secure communication under PSD2 enter into force. After this date, small EMI provider of AIS or PIS must be fully authorised as authorised electronic money institution (authorised EMI).

If you are unsure you can find guidance on whether you may be carrying out AIS or PIS in PERG*. PERG 3 and PERG 15 are amended by the Payment Services Instrument 2017 and you can see the revised PERG on our Handbook website by setting the date to 13 January 2018.