Operating as an agent of an authorised electronic money institution provides a route to offering payment and e-money distribution services without the cost and complexity of obtaining your own FCA authorisation. However, the FCA's increased scrutiny of agent networks means that the bar for agent appointment has risen significantly. This article provides an updated guide to becoming an EMI agent in 2026, covering the requirements, process and ongoing obligations.
What Is an EMI Agent?
An EMI agent is a firm or individual that carries out specified payment services or e-money distribution activities on behalf of an authorised electronic money institution (AEMI). The agent operates under the principal EMI's authorisation and is registered with the FCA through the Financial Services Register. Common agent activities include distributing e-money products, processing payment transactions, facilitating customer onboarding and providing customer support.
The agent does not hold its own FCA authorisation — it operates within the scope of the principal's permissions and is subject to the principal's oversight and compliance framework.
Updated FCA Requirements
The FCA's enhanced requirements for agent oversight, introduced through PS22/11, have raised the bar for agent appointment. Principal EMIs now apply more demanding standards, and prospective agents must demonstrate:
Robust AML controls. A comprehensive AML framework including customer due diligence procedures, transaction monitoring, suspicious activity reporting and staff training. The AML framework must be tailored to the specific services the agent will provide and the risk profile of its customer base.
Operational capability. Adequate technology, staffing and operational processes to deliver services reliably and in compliance with regulatory requirements. The principal will assess the agent's operational infrastructure before appointment.
Financial standing. Sufficient financial resources to sustain operations and meet any liabilities arising from the agent's activities. While there are no minimum capital requirements for agents, the principal will assess financial viability.
Fitness and propriety. Key individuals must be fit and proper — free from criminal convictions, regulatory sanctions and other disqualifying factors. The principal will conduct background checks on directors and beneficial owners.
The Registration Process
- Identify and approach a principal EMI. Research authorised EMIs whose business model aligns with your proposed activities. Principal EMIs vary in their appetite for agent appointments, their oversight approach and their commercial terms.
- Principal due diligence. The principal EMI will conduct comprehensive due diligence on your business, including AML framework review, financial assessment, operational review and fitness and propriety checks on key individuals.
- Agent agreement. Negotiate and execute an agent agreement with the principal, covering the scope of permitted activities, compliance obligations, reporting requirements, termination provisions and commercial terms.
- FCA registration. The principal EMI submits the agent registration application to the FCA. This is the principal's responsibility — agents cannot submit their own registration. Registration typically takes 2–3 months.
- Commencement. Once the FCA confirms registration on the Financial Services Register, the agent may commence the permitted activities.
Ongoing Compliance Obligations
Agent registration is not a one-time event. Agents must maintain compliance on an ongoing basis:
- Maintain and update the AML framework as customer base and risk profile evolve
- Conduct ongoing transaction monitoring and submit SARs where required
- Handle customer complaints in accordance with the principal's procedures
- Provide regular compliance reporting to the principal
- Cooperate with the principal's monitoring activities including compliance testing and audits
- Notify the principal immediately of any material compliance issues, regulatory communications or adverse events
Selecting the Right Principal
Not all principal EMIs offer the same level of support, commercial terms or regulatory standing. When selecting a principal, consider:
- The principal's regulatory track record and FCA supervisory history
- The scope of permitted activities under the agent agreement
- The quality of compliance support and training provided
- Commercial terms including revenue share, fees and minimum volumes
- The principal's technology platform and integration capabilities
- The principal's approach to agent oversight — firms with robust oversight programmes are safer partners
Regulatory Counsel advises prospective EMI agents on principal selection, compliance framework development and the registration process. Contact us for a free initial consultation.
Frequently Asked Questions
No. EMI agents operate under the principal EMI's authorisation. You must be registered with the FCA, but the registration is submitted by the principal.
Typically 2–3 months from the date the principal EMI submits the registration application to the FCA.
Maintaining AML controls, conducting transaction monitoring, handling customer complaints, reporting to the principal and cooperating with the principal's monitoring activities.
Technically possible but uncommon. Each principal-agent relationship requires separate registration, and the compliance obligations multiply. Most agents work with a single principal.