REGULATORY SERVICES

Become an Agent

Registering as an appointed representative or agent under an authorised payment institution or EMI licence.

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Whether you need licensing support, compliance advice or regulatory strategy, our team is ready to help. Free initial consultation — no obligation.

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HOW WE CAN HELP

What We Do

Many payment institutions and electronic money institutions distribute their services through networks of agents. The agent model allows firms to extend their reach without requiring each distribution point to hold its own regulatory authorisation.

However, appointing agents requires careful regulatory process — agents must be registered with the FCA and other regulators, and the principal firm remains fully responsible for the agent's compliance.

We help both principal firms seeking to build agent networks and businesses seeking to become agents of regulated firms. Our service covers the entire agent registration process and ongoing oversight arrangements.

01

Suitability Assessment

We assess the suitability of the agent arrangement and regulatory requirements.

02

Due Diligence

We conduct regulatory due diligence on prospective agents.

03

Registration & Agreements

We prepare and submit agent registrations and draft agent agreements.

04

Oversight Framework

We establish ongoing agent monitoring and oversight frameworks.

DELIVERABLES

What's Included

Agent Registration Application

Complete application for agent registration with the relevant regulator.

Due Diligence Report

Regulatory due diligence assessment of the prospective agent.

Agent Agreement

Comprehensive agreement covering regulatory obligations and responsibilities.

Oversight Framework

Ongoing monitoring and compliance oversight arrangements for agents.

Training Materials

Regulatory training programme for agents covering compliance obligations.

Passporting Notifications

Cross-border agent registration through EU passporting procedures.

WHO WE WORK WITH

Who This Service Is For

Firm Types

  • Payment institutions building agent networks
  • EMIs seeking distribution partners
  • Businesses wanting to offer payment services as agents
  • Firms with existing agent networks needing compliance support

Situations & Triggers

  • Launching an agent distribution model
  • Expanding agent networks into new markets
  • Responding to regulatory findings on agent oversight
  • Restructuring existing agent arrangements
WHY REGULATORY COUNSEL

Why Work With Us

Financial Services Only

We operate exclusively within regulated financial services. Every member of our team has direct regulatory experience in this sector.

Senior-Led Delivery

Every engagement is led by a senior consultant with hands-on regulatory experience — not delegated to junior staff.

Practical, Not Theoretical

We build frameworks that work in practice, not just on paper. Our advice is grounded in what regulators actually expect.

Global Reach

We advise across 65+ jurisdictions, combining local regulatory knowledge with a consistent, high-quality approach.

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Frequently Asked Questions

An agent is a person or business that provides payment services on behalf of an authorised payment institution or EMI under the principal firm's authorisation.

No. Agents operate under the principal firm's authorisation and do not need their own licence, but they must be registered with the regulator.

The principal firm is fully responsible for the agent's compliance, including ensuring fit and proper standards, implementing adequate AML controls, and maintaining ongoing oversight.

FCA agent registration typically takes 2 to 3 months, depending on the complexity of the arrangement and submission quality.

EU-authorised firms can register agents in other EEA member states through the passporting process, involving notification to both home and host state regulators.

Principal firms must conduct regular oversight including compliance monitoring visits, transaction monitoring, complaint handling review, and annual fitness assessments.

This depends on the regulatory framework and the terms of each agent agreement. Some jurisdictions permit multi-principal arrangements subject to appropriate controls.

The principal firm bears regulatory responsibility for agent breaches. This can result in enforcement action against the principal, reinforcing the importance of robust agent oversight.