SEMI and AEMI licenses in the United Kingdom

Получение лицензии на электронные деньги в Великобритании

In the United Kingdom, it is legally permissible to register an English company and obtain a financial license from the Financial Conduct Authority (FCA) within up to 12 months.
The primary distinguishing feature of such a financial institution compared to a traditional credit institution (bank) is the absence of the right to issue loans or accept interest-bearing deposits. However, it is also not subject to banking regulation and supervision.
The required authorized capital amounts to up to €350,000, which must be paid at the time of receiving a license—when the FCA issues an official letter of approval. This capital must remain constantly available in the company’s accounts and is considered non-reducible.

The English term for this type of license is AEMI (Authorized Electronic Money Institution). This is a relatively new type of financial service that enables participation in financial activities under a more flexible regulatory regime, facilitating rapid development and deployment of financial products.

SEMI and AEMI Distinctions

SEMI and AEMI are different categories of licenses within the financial services and payment systems sector, each with distinct characteristics:

SEMI (Small Electronic Money Institution):
Limited issuance volume (not exceeding €5,000,000 annually)
Simplified requirements
No deposit-taking allowed
AEMI (Authorized Electronic Money Institution):
No issuance volume restrictions
Authorized to accept deposits
Requires a higher minimum capital than SEMI

Who needs these licenses?

Fintech companies in the payment processing and e-money sectors
Payment service providers, mobile operators, and transaction processing entities
E-commerce platforms
Startups in online acquiring

Advantages of EMI licensing in the UK

This structure helps resolve key challenges in banking and cross-border transfers, especially in major currencies like USD, EUR, and GBP. Features include:

Access to SWIFT accounts
Issuance of IBAN accounts to clients
Remote account opening for individuals and legal entities
Issuance of MasterCard payment cards
Global bank payments in multiple currencies
Acceptance of payments from any SWIFT account
Opening of correspondent accounts worldwide

EMI Licensing Requirements in the UK

For SEMI:

Operation limited to the UK
License issuance time: 4 months
One UK-resident director required

For AEMI:

Minimum capital: €350,000
License issuance time: 6 months
Two UK-resident directors required

Documents required for E-Money licensing in the UK

Company charter
Business plan with a 3-year budget forecast
Evidence of capital adequacy
Funds safeguarding measures
Internal control and risk management systems
Structural organization and use of agents/branches
AML/CFT compliance mechanisms
Information on shareholders with qualifying holdings
Background checks on directors and management
Auditor credentials
Registered office address

Note: All documents must be submitted in English.

Licensing procedure in the UK

Submitted documents will be reviewed by the Bank of England within 4–6 months. In case of deficiencies, additional documentation may be requested, restarting the 2–3 month review cycle from the new submission date.
The licensing process includes three main stages, each involving specific actions.

Why choose Law&Trust International?

Law&Trust International provides comprehensive legal support for obtaining EMI/AEMI licenses in the UK, including:

Expert legal consulting
Submission of core and supplementary documentation to HM Treasury, the Bank of England, and the FCA
Document preparation and filing
Legal representation and third-party contract support
Company, trademark, and IP registration
Bank account and VAT registration
Legal opinions for payment systems and banking partnerships
Once the license is obtained, it will be delivered to you in person or via courier.

If you are ready to apply for an EMI/AEMI license in the UK, contact our legal team for a free consultation.