Small payment institution (small PI)

First published: 22/09/2017 Last updated: 14/09/2018

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

Small PIs should have made necessary changes to ensure compliance with PSD2 requirements, the majority of which were effective from 13 January 2018. The key changes for small PIs include those relating to Conduct of business (Chapter 8 in our Approach Document), Complaints handling (Chapter 11 in our Approach Document) and Reporting and notifications (Chapter 13 in our Approach Document).

Please also familiarise yourself with the relevant parts of the FCA Handbook which have changed, including SUP 15,* SUP 16* and DISP*. The Handbook is amended by the Payment Services Instrument 2017.

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 provide payment services from 12 January 2019?
Please select:

1. To continue providing payment services after 12 January 2019, small PIs must be re-registered. They will need to provide us with additional information. Small PIs can apply to be re-registered from 13 October 2017 and must submit their application before 23:59 on the 12 October 2018. They must be successfully re-registered by 12 January 2019. There will be a fee of £250 for re-registration.

2. The FCA encourages applications to be made as early as possible. Small PIs that have not successfully been re-registered before the end of the transitional timeframes will have to cease providing payment services, as will their agents; we 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.

3. All small PIs 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 October 2018 this will automatically mean that you are unable to continue to provide payment services after 12 January 2019. 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) from 13 January 2018?
Please select:

1. Small PIs are not permitted to provide AIS or PIS. This means you can no longer operate as a small PI (unless you are affected by the transitional provisions for certain businesses operating prior to 12 January 2016). You will need to apply to become an authorised payment institution (authorised PI) if you want to offer these services. You can find further information on our Authorisation pages.

2. Small PIs 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 PI provider of AIS or PIS must be fully authorised as authorised payment institution (authorised PI).

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.