Payment services and e-money

Payments and e-money is one of the most innovative and fast-growing areas of financial services. The pace of change makes it an exciting world to work in, but the regulatory framework is complex and presents challenges to payment service providers and electronic money institutions alike.

Our clients range from innovative startups entering the regulatory perimeter for the first time, to established international groups looking to extend their existing offering or seeking help navigating the extensive regulatory environment.

Whether you’re applying for registration or authorisation, are wanting to utilise open banking (AIS or PIS) functionalities or are an international payments business looking to enter the UK market, we have the knowledge and experience to help. And our global presence means we can advise and support where you need it.

FCA Authorisation or Registration for e-money and payment services

Taking the right approach from the start can make the regulatory application process far easier, and substantially increase your potential for success. The FCA is keen to see new entrants in the payments and e-money sector and the competition they bring.

But they will not register or authorise firms that are perceived to be a risk to customers or market integrity.

You will need to show that you are ‘ready, willing and organised’ in several areas, such as:

  • The competencies (and attitudes) of the individuals responsible for payment or e-money services
  • Strong financial crime controls
  • Robust prudential risk management, including realistic wind-down plans
  • Appropriate safeguarding measures
  • Clear evidence of appropriate concern for good customer outcomes, in line with Consumer Duty
  • Robust operational resilience; and
  • A business model and compliance control framework that is robust and operationally resilient.

How we can help

We have supported numerous payment service providers (PSPs) and electronic money institutions (EMIs) through all stages of development.

Whether helping clients develop a thorough understanding of the regulatory regime and supervisory framework, supporting regulatory applications, drafting tailored policies and procedures, or providing ad-hoc support, our regulatory specialists are ready to help.

We make sure we understand your objectives and aspirations from the outset, and help you prioritise and plan your approach to regulation in a way that is efficient, cost effective and informed at all stages of your development.

FCA authorisation and registration support

We can help with every element of regulatory applications, from seeking regulatory permissions and appointing PSD or EMD Individuals to requesting Change in Control approvals. We steer you through the intricacies and complexities of the regulations to help your applications have the best chance of success and can provide expert support from the early stages of scoping permissions and identifying regulated activity, through to preparing the application pack and supporting information.

This often includes:

  • Assessing and/or drafting policies and procedure frameworks tailored to your firm,
  • Offering training to your management team, ensuring regulatory obligations are understood; and
  • Guiding you through any regulatory challenges that arise in between.

Once you’re established, we can help you with regular ongoing compliance support tasks such as regulatory reporting, staff training, reviews, and keeping an eye on the regulatory horizon.