FCA Payment Institution Authorisation Solutions | Pre-licensing Support | FCA PI Authorisation Application Management | Post-licensing Risk and Compliance Solutions

We offer a comprehensive set of solutions to help you obtain and maintain a UK Payment Institution (PI) Authorisation issued by the UK Financial Conduct Authority (FCA) under the Payment Services Regulations 2017 (PSRs), tailored to:

• Your business goals and objectives
• Your client demographics
• Your countries of operation
• The size of your business
• The available human and technology resources
• Your risk appetite
• Your governance structure
• The products that you offer
• FCA regulated payment institutions’ obligations covering risk and compliance management under financial laws and regulations, the applicable financial licensing requirements, AML/CFT laws, privacy laws, consumer protection laws, and more

We have designed our regulatory licensing solutions to help you navigate the complexities of the UK payment institution authorisation regime in a commercially oriented and goal-focused manner, providing effective support for all stages of the FCA payment institution authorisation process, including but not limited to the following aspects:

• FCA Payment Institution Authorisation Guidance: Advising on a wide range of aspects associated with FCA payment institution authorisation as it relates to your specific situation
• Pre-licensing assessment: Covering compliance gap analysis as well as risk and compliance assessment
• Pre-licensing support:
• Drafting the necessary policies and procedures to help you comply with the FCA payment institution authorisation conditions and financial markets' regulations
• Developing internal controls to help you meet your obligations under the UK payment institution authorisation regime
• Payment Institution FCA Application Support: Covering the entire licensing process
• Post-licensing Support: Covering
• Ongoing compliance advice
• Comprehensive second-line risk and compliance support, including leading the implementation of your risk management framework (RMF), compliance management framework (CMF), compliance monitoring program (CMP), compliance calendar and checklist, ongoing risk assessments, internal and external reporting, outsourced providers' management, and more
• AML/CFT advice
• AML/CFT compliance management
• Compliance assurance solutions, including compliance assurance program (CAP) development, implementation, and internal control testing

 

 

Service Coverage

This page is about the UK Payment Institution Authorisation. In the United Kingdom, firms that provide regulated payment services - such as money remittance, merchant acquiring, payment account services, and payment initiation services - must be authorised or registered with the FCA under the Payment Services Regulations 2017 (PSRs).

There are two tiers of authorisation:

• Small Payment Institution (SPI) – for firms with lower transaction volumes, subject to thresholds and lighter prudential requirements.
• Authorised Payment Institution (API) – for firms exceeding thresholds or seeking passporting rights (pre-Brexit), subject to higher prudential, governance, and safeguarding obligations.

PI firms are subject to prudential, governance, conduct, and reporting requirements, including: safeguarding of customer funds, AML/CTF compliance, governance and internal controls, and FCA reporting. We offer comprehensive support for a wide range of payment institution FCA applications tailored to meet the specific needs of the following businesses:

• Peer-to-Peer Payment Services
• Domestic Money Remitters
• Consumer Money Remitters
• Commercial Money Remitters
• Mobile Payment Providers
• Prepaid Card Issuers
• Remittance Service Providers
• Foreign Exchange Dealers
• International Money Remitters

You can find more information about our FCA payment institution authorisation solutions below:

 

FCA Payment Institution Authorisation Preparation

Pre-licensing Compliance Assurance

Our FCA payment institution authorisation solutions cover the following focus areas:

• Compliance Goals Analysis: We review your business-specific goals and resources against the suitability criteria for an FCA payment institution authorisation
• Initial Consultation: We provide guidance on potential risk and compliance issues that may arise during the UK payment institution authorisation process
• Choosing the Right Jurisdiction: We assist in evaluating regulatory, risk, and compliance environments to determine the most suitable jurisdictions for your FCA payment institution authorisation, tailored to suit your:

• business objectives,
• operational capacity,
• client base,
• markets of operations,
• and other relevant factors

• Gap Analysis: We identify gaps between your existing operations and regulatory requirements and help you align them in a commercially oriented manner
• Payment Institution FCA Application Plan: We help you establish a roadmap to effectively meet the FCA payment institution authorisation requirements

 

 

FCA Payment Institution Authorisation Guidance

Selecting the right compliance model is crucial not only for navigating the licensing process but also for maintaining ongoing compliance and avoiding potential breaches. Our FCA payment institution authorisation solution covers:

• Compliance Model Selection: To help you best comply with the UK payment institution authorisation regime and related risk and compliance obligations.
• Corporate Governance Model Selection: We offer practical guidance on establishing effective corporate governance practices that support your risk and compliance oversight.
• Operations Model Advisory: We advise you on optimising your operational and governance models to help you efficiently comply with the UK payment institution authorisation regime and other applicable FCA regulated payment institutions’ obligations, keeping in mind your specific circumstances, available resources and business goals.

 

FCA Payment Institution Authorisation And Entering The Regulated Environment

We help businesses transition from an unregulated environment to operating under the UK payment institution authorisation regime, helping them meet their obligations as an FCA payment institution authorisation holder.

We also assist already regulated businesses in aligning their existing risk and compliance management structures with the UK payment institution authorisation regime requirements.

Our focus areas for this service include:

• New businesses
• Existing payment institutions operating in unregulated markets
• Regulated UK payment institutions  expanding into foreign jurisdictions
• Financial institutions and/or service providers with established risk and compliance frameworks seeking to offer regulated money transfer services as a new product.

 

Multi-Jurisdictional Compliance

With years of experience managing risk and compliance obligations for businesses operating under multiple financial licences across various jurisdictions, we help businesses remain compliant with the regulated payment institutions’ obligations globally.

 

FCA Payment Institution Authorisation and Wholesale Markets

Obtaining a UK payment institution authorisation may not always be necessary or suitable for all businesses, particularly where activities are limited to intragroup transfers, commercial payment flows, or wholesale-only arrangements that fall outside the scope of the Payment Services Regulations 2017. Wholesale or corporate-only models are not generally regulated as retail payment services.

We offer risk and compliance management solutions to assist wholesale or exempt businesses that:

• Operate exclusively in wholesale or intragroup payment flows
• Qualify for exemptions under the PSRs (e.g., limited network or technical service provider exemptions)
• Provide services incidentally to another regulated activity

We help these businesses manage obligations that may still apply, including:

• FCA perimeter guidance (PERG) compliance checks
• AML/CTF compliance under the UK Money Laundering Regulations 2017
• Data protection and PSD2-derived security requirements
• Restrictions on offering services to retail clients without FCA registration
• Governance, risk management, and oversight of outsourced service providers

 

 Payment Institution FCA Application

We assist with your licence application through ongoing engagement in the FCA payment institution authorisation process:

• Document Compilation and Review: We compile and review all required supporting documents to support your payment institution FCA application.
• Application Form Completion: We help you complete the forms so that all material information is accurate and complete.
• Pre-Submission Review: We can arrange a pre-submission review session with key stakeholders to ensure all parts of your application are understood and agreed upon. This session aligns application details with the actual situation, removing ambiguity.
• Regulatory Liaison: We manage the end-to-end submission process, maintaining clear and effective communication channels throughout the regulated UK payment institutions' authorisation process.
• Timeline Management: We closely monitor and adhere to all necessary deadlines, providing timely updates and adjustments to keep the application process on track.

 

Resolving FCA Payment Institution Authorisation Issues

Having competent compliance advisors is crucial when licensing issues arise. Therefore, our FCA payment institution authorisation solutions include a range of services to address and resolve these issues effectively:

• Remediation Solutions for FCA Payment Institution Authorisation Applicants: We address and remediate risk and compliance issues identified by regulators, helping your operations align with the UK payment institution authorisation regime requirements.
• Specific Licence Conditions Compliance: We can help you manage additional conditions imposed on your FCA payment institution authorisation, developing a tailored action plan to maintain compliance and facilitate the eventual removal of these conditions with minimal disruption to your business operations.
• Licensing Issues Handling: We address common licensing issues encountered during the FCA payment institution authorisation process, providing you with solutions to navigate and resolve these challenges efficiently.
• Further Information: You can visit our Compliance Remediation Solutions page for more information.

 

Post-Licensing Support

We offer a full range of ongoing risk and compliance solutions for regulated UK payment institutions. Our services include, but are not limited to:

Ongoing Risk and Regulatory Compliance

• FCA Regulated Payment Institutions’ Obligations Guidance: We can advise your risk, compliance, management and other teams on meeting the requirements of the UK payment institution authorisation regime and other regulatory compliance obligations. You can visit our Compliance Advisory page for more information.
• Regulatory Risk and Compliance Management: We provide dedicated compliance managers to manage your overall compliance. For more information, visit our global Compliance Management Solutions page for Money Remmitance Providers
• Compliance Assurance Solutions: As part of our compliance assurance solutions, we offer:
• Compliance Assurance Program (CAP) development and testing options
• Internal Controls Design option
• Internal Controls Testing option
• Internal AML/CFT Review option
• Statutory AML/CFT Audit option
• Compliance Training Solutions: We offer training programs to different teams on complying with:

• FCA regulated payment institutions’ obligations for risk and regulatory compliance management. You can visit our Compliance Training page for more information.
• FCA regulated payment institutions’ AML/CFT obligations and operational best practices for fraud prevention. You can visit our AML/CFT Training page for more information.

• Crisis Management Planning: We can develop proactive strategies to manage potential compliance crises effectively.
• Anti-Money Laundering (AML) and Counter Terrorist Financing Solutions: We provide a full range of AML/CFT solutions for UK payment institutions. For more information, visit our Specialised AML/CFT Solutions page for Money Remitters.
• Advanced Compliance Technologies: We can assist you with selecting and integrating advanced technology solutions, such as compliance automation tools and regulatory technology (RegTech), to streamline compliance processes without disrupting operations.
• Risk and Compliance Framework Adjustments: Including adjustments to risk management frameworks (RMFs), compliance monitoring programs (CMPs), compliance management frameworks (CMFs), and other core procedures and policies to align them with:
• new business goals
• regulatory changes
• changes in your operations
• evolving market conditions
• changes in stakeholders’ risk appetites (your banking partners, insurance companies, liquidity providers, etc.).

 

 

Risk and Compliance Obligations for FCA Payment Institution Authorisation Holders

FCA payment institution authorisation holders are subject to various obligations set out in applicable laws and regulations. They are also expected to uphold standards for their conduct and internal operations, as outlined in regulatory guidance or accepted industry practices.

We can help you address these obligations and expectations through comprehensive support across various areas. The list below is not exhaustive:

UK Payment Institution Authorisation and Regulatory Compliance Obligations

• Compliance Management Systems: We can help you establish effective compliance programs, compliance monitoring plans, controls testing methodologies, compliance calendars and more (as required under the SYSC 6.1 and PSRs 2017, Reg 17).
• Risk Management Frameworks: We can help you develop comprehensive risk management frameworks to fulfil FCA regulated payment institutions’ obligations for identifying, assessing, and mitigating operational, regulatory, strategic, financial and other types of risks (as required under the SYSC 7.1 and  PSRs 2017, Reg 17).
• Policy and Procedure Development: We can help you draft and implement policies and procedures aligned with the UK payment institution authorisation requirements (as required under the PSRs 2017, Reg 18).
• Compliance Monitoring Plans: We can oversee the execution of your CMPs, covering ongoing monitoring of your compliance obligations under the UK payment institution authorisation regime (as required under the PSRs 2017, Reg 18).
• Internal Control Testing and Compliance Assurance: We can conduct internal reviews and audits of your controls to test their effectiveness and compliance with the applicable regulatory standards.
• Digital Payment Token Services: If your business supports digital assets or stablecoin-based transfers, we can help you develop controls to meet AML/CFT requirements and applicable licensing conditions for digital payment token services, including transaction monitoring, wallet screening, and Travel Rule compliance.
• Safeguarding of Client Funds: We can help you implement and document safeguarding arrangements for customer funds under the UK PI authorisation regime.

 

UK Payment Institution Authorisation and Operational Oversight Obligations

• Oversight of Outsourcing: We can establish a set of effective controls to comply with FCA regulated payment institutions’ obligations for overseeing outsourced services, also covering related obligations under AML/CFT compliance, ISO requirements, and more, as required under the PSRs 2017.
• Structures for Governance: We can help you establish effective governance structures to comply with FCA regulated payment institutions’ obligations and develop an effective approach to overseeing your risk exposure and compliance status across different functions of your business.
• Senior Management Accountability: We can help you comply with the FCA regulated payment institutions’ obligations for senior management and key staff conduct and competence (as required under the FCA SM&CR framework).
• Maintaining Operational Resilience: We assist in developing continuity plans to meet FCA regulated payment institutions’ obligations for operational resilience and transaction flow continuity, helping critical business services withstand disruptions.
• Managing Technology Risks: We provide guidance on technology risk management obligations under the UK payment institution authorisation regime.
• Business Continuity Frameworks: We can help you document and implement business continuity plans to comply with the FCA's expectations for operational continuity under the payment institution authorisation regime.

 

UK Payment Institution Authorisation and Market Integrity/Transparency Requirements

• Principles for Fair Treatment: We can help you implement controls to comply with expectations that cover adherence to principles of fair treatment and transparent communications with clients (as required under FCA Principles for Businesses).
• Standards for Conduct and Disclosure: We can help you comply with UK payment institution authorisation standards for conduct and disclosure.
• Protection of Client Assets: We can help you comply with UK payment institution authorisation obligations to protect and segregate client assets.
• Resolution of Disputes: We can help you establish effective mechanisms for dispute resolution and complaints management, particularly for retail clients.

 

UK Payment Institution Authorisation and Resource Management Obligations

We can help you comply with the following requirements of the UK payment institution authorisation regime:

• Adequacy of Resources: Covering financial, technological, human and other resources.
• Competence of Professionals: Covering key personnel, their necessary skills, knowledge, and professional competence.
• Our focus areas include:

• Assessment and Gap Analysis: We can help you evaluate the adequacy of your financial, technological, and human resources against the requirements of the PI authorisation regime.
• Resource Allocation Plans: We can help you develop strategies to optimise resource allocation, covering sufficient capacity for compliance, trading, operations, banking, customer support and other functions and departments.
• Technological Solutions: We can recommend and implement RegTech tools to streamline compliance processes, such as transaction monitoring, reporting, and audit trails.
• Key Personnel Assessment: We can help you assess the skills, qualifications, and experience of key personnel to identify areas for improvement.
• Training and Development Programs: We can design and deliver targeted compliance training programs to upskill personnel in compliance, risk management, and money transfer regulations.
• Representative Vetting: We can help establish a framework for assessing the competence and suitability of advisors and representatives before appointment.
• Compliance Monitoring: We can help develop controls to monitor representatives' adherence to conduct and disclosure obligations.
• Ongoing Training: We can help you create a framework to support continuous education for advisors and representatives on licensing obligations, market integrity, and client interaction standards.
• Regulator Liaison: We can act as an intermediary with regulators to address queries and help you demonstrate compliance with resourcing obligations.

 

UK Payment Institution Authorisation and Reporting

• Regulatory Reporting: We can help you prepare and submit periodic and ad-hoc reports covering:
  • FCA regulated payment institutions’ licensing obligations
  • FCA regulated payment institutions’ AML/CFT obligations (SMRs, STRs, SARs, cross-border transaction reports, cash transaction reports, and other reporting obligations)
• Incident Reporting: We can assist you in meeting your FCA notification requirements for fraud events, IT outages, and safeguarding breaches under the PI authorisation regime (as required under SUP 15.3).
• Compliance Documentation: We can help you develop and maintain the necessary documentation to meet record-keeping obligations under various laws and regulations.
• Audit Readiness: We can prepare you for audits and reviews to demonstrate compliance with regulatory requirements, provisions of the UK payment institution authorisation regime, applicable operational standards, and more.

 

Related Services

We assist in obtaining FCA payment institution authorisation equivalents in the following jurisdictions:

• Australia: For more information on the Australian equivalent of an FCA payment institution authorisation, the AUSTRAC money remitter registration, you can visit our AUSTRAC Money Remitter Registration page.
• New Zealand: For more information on the New Zealand equivalent of an FCA payment institution authorisation, the DIA money remitter registration, you can visit our DIA Money Remitter Registration page.
• United States: For more information on the United States equivalent of an FCA payment institution authorisation, the money transmitter license, you can visit our US Money Transmitter Licence page.
• Singapore: For more information on the Singaporean equivalent of an FCA payment institution authorisation, the SPI licence, you can visit our Singaporean SPI Licence page.
• Prominent Financial Centres and Offshore Tax Havens: We also offer licensing solutions for money remittance businesses in the prominent financial centres and offshore tax havens, including:

• Seychelles
• Cayman Islands
• British Virgin Islands (BVI)
• Belize
• Mauritius
• Gibraltar