UK EMI Authorisation in 2026: FCA Application, Safeguarding and Capital Requirements

A firm planning to issue e-money in the UK has to choose the right authorisation before setting up its structure. The two main options are an AEMI license UK and an API licence UK.

The distinction is straightforward: an AEMI may issue e-money, while an API cannot. An AEMI may also carry out qualifying payment activities under its AEMI licence UK.

This choice affects the funds the firm needs, the information submitted to the FCA, the treatment of customer money and the procedures required before operations begin. For companies entering the UK market in 2026, the changes introduced on 7 May 2026 are another important consideration.

Quick Answer: UK AEMI vs API

AEMI allows a UK-regulated firm to issue e-money and provide payment offerings. API can provide authorised payment services but cannot issue electronic money. Both are FCA-regulated and subject to safeguarding demands, while the capital, permissions and business-model requirements differ.

The comparison often appears under searches such as AEMI vs payment institution UK, UK EMI vs PI and UK EMI vs payment institution. In practice, the main question is whether the proposed structure needs e-money issuance or only qualifying payment activities.

What Is a UK AEMI?

It is the UK status used by firms that want to issue e-money. It can suit businesses developing prepaid products, stored-value accounts and similar arrangements.

An AEMI can also carry out qualifying payment activities. The UK EMI requirements 2026 cover areas such as:

• proposed activities and structure;
• available funds;
• ownership information;
• senior personnel;
• risk procedures;
• AML arrangements;
• customer-fund protection;
• information security;
• continuity arrangements;
• wind-down planning.

The FCA assesses whether these elements fit together with the proposed model rather than looking only at the financial threshold.

What Is a UK API?

An API is intended for a firm that wants to carry out authorised payment activities without issuing e-money.

The exact activities matter because they determine the relevant fiscal threshold. The API requirements UK applicants need to consider include:

• activities to be offered;
• projected volumes;
• sources of funds;
• ownership structure;
• senior staff;
• AMl arrangements;
• customer-fund protection;
• risk procedures;
• information security;
• continuity planning.

An API is therefore not simply a cheaper version of an AEMI. The appropriate route depends on the firm’s planned activities.

AEMI Capital Requirements in 2026

The statutory starting point is €350,000.

This concerns initial funds rather than the firm’s entire financial position. Once activity begins, the amount needed can change according to the scale and nature of the operation.

For e-money issuance, one important calculation is linked to average outstanding e-money. Where the relevant rules apply, the own-funds calculation uses 2% of that average amount.

An AEMI carrying out certain additional activities may also have further calculations to consider. The AEMI requirements should therefore be assessed against projected volumes rather than treated as one fixed figure.

API Capital Requirements in 2026

The amount required from an API depends on the activities included in its authorisation:

• €20,000 for money remittance;
• €50,000 for payment initiation;
• €125,000 for certain other payment activities.

Where several categories are proposed, the higher relevant threshold may determine the starting figure.

The criteria should also be separated from ongoing own-funds calculations. Meeting the threshold at the application stage does not automatically determine the amount the firm will need to maintain later.

FCA Application Process for an AEMI or API

The FCA expects an applicant to provide a clear picture of how the proposed firm will function.

The information normally covers:

• proposed activities;
• programme of operations;
• financial forecasts;
• ownership details;
• senior personnel;
• AML arrangements;
• customer-fund protection;
• risk procedures;
• information security;
• continuity arrangements;
• agents or branches, where relevant;
• wind-down arrangements.

The supporting material should match the actual model. For example, financial projections should correspond with the planned activities, while the organisational structure should show who is responsible for key decisions.

AEMI Safeguarding and API Safeguarding

Customer money has to be protected according to the relevant rules. The arrangements should allow the firm to identify the relevant funds, reconcile its records and demonstrate where customer money is held.

For an AEMI, the duties cover money received in connection with issued e-money. Relevant payment activities can bring additional duties.

For an API, the position depends on the activities performed. The main elements include:

• identifying protected customer funds;
• keeping appropriate records;
• carrying out reconciliations;
• maintaining suitable arrangements with relevant institutions;
• addressing discrepancies;
• retaining evidence of the process.

The 2026 changes make these procedures particularly important for new applicants.

What Changed on 7 May 2026?

New safeguarding rules came into force on 7 May 2026.

The changes introduced additional duties concerning customer-fund records, reconciliation and information provided to the FCA. Among the changes are:

• daily checks of the amount that should be protected;
• monthly information submitted to the FCA;
• more detailed record-keeping;
• stronger reconciliation procedures;
• additional oversight of customer-fund arrangements.

For a firm applying in 2026, these procedures should be incorporated into its structure from the outset.

UK Payment Licence Requirements: AEMI vs API UK?

The appropriate route for a UK payment institution license depends on what the firm wants to do.

An AEMI is relevant where the model involves issuing e-money. An API is intended for firms carrying out qualifying payment activities without issuing e-money.

In simple terms:

• E-money issuance needed → UK AEMI licence 2026
• Payment activity without e-money issuance → API license UK
• Both e-money and qualifying payment activities → AEMI can cover both, subject to its permissions

The firm’s activities should be defined before preparing the FCA paperwork. This helps establish the relevant financial threshold, customer-fund arrangements and supporting documents.

For more information, see our guides on AEMI authorisation in the UK and PI Authorisation guide for 2026.

UK AEMI Authorisation in 2026: Key Points

The main points to consider are:

• An AEMI can issue e-money.
• An API cannot issue e-money.
• An AEMI starts with a €350,000 statutory threshold.
• An API may have a €20,000, €50,000 or €125,000 threshold.
• Starting funds and ongoing own-funds calculations are separate matters.
• Relevant customer funds must be protected.
• The safeguarding regime was strengthened on 7 May 2026.
• UK authorisation does not provide an EU passport.

For wider comparisons, see our guides on EMI License vs MSB License and Best EMI License Jurisdictions in 2026.

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