What a UK EMI actually costs in 2026, from the official schedules

Search for UK EMI costs and the results quote application fees of GBP 15,000 or even GBP 25,000, and a GBP 20,000 initial-capital requirement for a small EMI. None of those figures appears in any official schedule. The FCA's fee page and FEES 3 Annex 10R put an authorised EMI application at GBP 5,580 and a small EMI registration at GBP 1,120 - a fraction of the quoted figures, paid by card at submission. The GBP 20,000 small-EMI "capital requirement" is invented twice over: wrong currency and wrong amount, because Schedule 2 sets no initial capital for a small EMI below EUR 500,000 of average outstanding e-money.

We name no names; the pattern is what matters. A costs page that does not cite FEES 3 Annex 10R and Schedule 2 is quoting decoration, not regulation.

Schedule 2 to the Electronic Money Regulations 2011 requires an authorised EMI to hold initial capital of at least EUR 350,000. The oddity is real: a post-Brexit UK statute continues to denominate its thresholds in euro, because the current revised text on legislation.gov.uk has never been converted to sterling. The small-EMI thresholds are euro figures too - no initial capital below EUR 500,000 of average outstanding e-money, then at least 2% of it - as are the registration ceilings in regulation 13 (EUR 5,000,000 of average outstanding e-money; EUR 3,000,000 a month of unrelated payment transactions). "Average outstanding electronic money" is a defined term in regulation 2(1): total e-money liabilities at the end of each calendar day, averaged over the preceding six calendar months.

Initial capital gets you through the door; own funds keep you there. For the e-money business the requirement is Method D under Schedule 2: an amount equal to 2% of average outstanding electronic money. A hybrid EMI that also provides payment services unrelated to e-money issuance adds a separate calculation under Method A, B or C - broadly, 10% of fixed overheads (A), a tiered percentage of payment volume sliding from 4% down to 0.25% (B), or a multiplier applied to an income-based indicator (C). The FCA may also adjust the resulting requirement up or down by as much as 20% on its assessment of the firm's risk. The budgeting consequence: a growing float mechanically drags the own-funds floor up with it, at EUR 2 for every EUR 100 of e-money outstanding.

Once authorised, an EMI pays periodic fees - and here we will tell you exactly how the bill is built while deliberately quoting no rates. Authorised EMIs sit in FCA fee-block G.10 and small EMIs in G.11. The tariff base for G.10 is average outstanding electronic money, measured for fee purposes over the preceding twelve calendar months, valued at 31 December and reported in sterling. On top of the FCA's own fee comes the Financial Ombudsman Service levy, charged against the same tariff base.

The rates themselves live in FEES 4 Annex 11R of the Handbook and are re-set every year in the FCA's April fee cycle by policy statement - which is why any page quoting a fixed figure as "the annual fee" dates within months. Budget from the current Annex 11R table applied to your own projected float.

Application fees are a rounding error next to what it costs to run an EMI compliantly - and on 7 May 2026 that recurring cost stepped up for the whole sector. The FCA's new safeguarding regime (CASS 15, CASS 10A and SUP 3A of the Handbook) is in force, not proposed, and it reaches small EMIs as well as authorised ones. These are the line items it adds to every operating budget.

For a small book sitting just above the GBP 100,000 audit-exemption line, the audit alone can outweigh the FCA's entire fee schedule. And the direction of travel is more assurance cost, not less: the FCA's stated reason for the reform was that insolvent payment firms between Q1 2018 and Q2 2023 left average shortfalls of 65% of their customers' funds. Price the compliance headcount, the audit and the reconciliation tooling before the application fee - they are the real cost of the licence.

Two numbers you will not find published, because they do not exist. First, there is no official end-to-end timeline for authorisation. What exists is statutory: regulation 9 of the EMRs requires the FCA to determine a completed application within three months, and allows it up to 12 months for an incomplete one. Longer end-to-end ranges circulate in the advisory market, but they are third-party estimates, not schedule entries - and every month a file stays open is a month of premises, payroll and advisers before revenue.

Second, there is no published fee for a section 178 change-of-control notice - the filing a buyer makes to acquire an existing authorised EMI. No published fee is not the same as free: the buyer still carries the preparation and advisory cost of a controller file. But the acquisition route has something the application route lacks - a statutory assessment window of 60 working days from a complete notice, interruptible once (FSMA ss. 189-190). Which tier and which route fit your model is a separate question - we compare the tiers in small EMI vs authorised EMI - and the acquisition path is the one behind SKY7's live UK FCA-authorised EMI for sale. None of this changes the constant: no adviser can guarantee an authorisation or an approval, whatever they charge.