Electronic money institution

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Glossary · Regulatory change

Electronic money institution

EMIAlso called e-money institution, e-money issuer

Definition

An electronic money institution is a firm authorised to issue electronic money, a stored monetary value that customers pay in and can spend or transfer. EMIs can also provide payment services. They are not banks: they cannot lend customer funds or offer deposit protection, so they must safeguard the money customers hand over.

SEGREGATED ACCOUNTSECURE ASSETSINSURANCE OR GUARANTEE
Fig. 1 · Electronic money institution
Electronic Money Regulations 2011 · Second E-Money Directive · FCA PS25/12
Key rulesElectronic Money Regulations 2011 · Second E-Money Directive · FCA PS25/12 · PSD3 and PSR
Applies toAuthorised and small electronic money institutions in the UK
RegionsUK · EU
01

How it works

A customer pays funds to the EMI and receives an equal amount of e-money, held in an account, card or wallet. The EMI must issue e-money at par and redeem it at par on request. Many fintech accounts, prepaid cards and payment apps run on EMI licences. In the UK, firms apply to the FCA for authorisation, and small EMIs with limited outstanding e-money can register under a lighter regime.

Because e-money is not a deposit, the customer is protected through safeguarding. The EMI either holds the funds in a segregated account at a bank or invests them in approved secure assets, or covers them with insurance or a guarantee. In the UK, rules in force since 7 May 2026 require daily reconciliations, a resolution pack and annual safeguarding audits. EMIs also follow money laundering rules, including customer due diligence.

Step 1AuthorisationThe firm applies to its regulator for an e-money licence.
Step 2Issue at parCustomer funds are exchanged for the same value of e-money.
Step 3SafeguardFunds are segregated or covered by insurance or a guarantee.
Step 4ReconcileSafeguarded amounts are checked against e-money owed every day.
Step 5RedeemCustomers can withdraw their e-money at par value on request.
02

The rules

UK · 30 April 2011Electronic Money Regulations 2011Electronic Money Regulations 2011 (SI 2011/99)

Sets authorisation, capital, issuance and redemption at par and safeguarding requirements for e-money issuers, supervised by the FCA.

Authorised and small electronic money institutions in the UK
EU · 16 September 2009, transposition by 30 April 2011Second E-Money DirectiveDirective 2009/110/EC on the taking up, pursuit and prudential supervision of the business of electronic money institutions

Sets the EU licensing, capital and safeguarding regime for EMIs and allows a licensed EMI to passport its services across member states.

Electronic money institutions in the EU
UK · 7 May 2026FCA PS25/12FCA Policy Statement PS25/12, Changes to the safeguarding regime for payments and e-money firms (CASS 15)

Adds daily safeguarding reconciliations, a resolution pack, safeguarding audits and monthly returns to the existing safeguarding rules.

Authorised and small EMIs, authorised payment institutions and credit unions issuing e-money
EU · 28 June 2023PSD3 and PSRProposals for a Directive on payment services and electronic money services and a Payment Services Regulation

Commission proposals to fold the E-Money Directive into the payment services framework, making EMIs a type of payment institution; not yet published in the Official Journal.

Payment service providers, e-money institutions and banks in the EU
03

Common questions

Is an EMI the same as a bank?

No. An EMI can hold and move customer money but cannot lend it or pay interest on it, and balances are not covered by deposit guarantee schemes such as the FSCS. Customer funds are protected by safeguarding instead.

What is the difference between an EMI and a payment institution?

A payment institution can execute payments but cannot issue stored value. An EMI can issue e-money that customers hold over time, and it can also provide payment services.

What happens to customer money if an EMI fails?

Safeguarded funds are kept apart from the firm's own assets and returned to customers through an insolvency process, after the costs of distributing them. This is why regulators focus on safeguarding reconciliations and resolution packs.