AEMI authorisation costs at a glance
The AEMI authorisation cost involves much more than the application fee paid to the Financial Conduct Authority (FCA). Firms also need to consider capital requirements, compliance resources, safeguarding arrangements, systems and controls, professional support and the ongoing costs of operating as a regulated e-money institution.
There is no single figure for the total cost of becoming an AEMI. The investment required will depend on the size and complexity of the business, its operating model and, importantly, how much of the necessary infrastructure is already in place.
Key costs and financial requirements include:
- FCA application fee: £5,640
Check the latest FCA authorisation and registration application fees
- Initial capital requirement: €350,000
https://www.fca.org.uk/publication/finalised-guidance/payment-services-electronic-money-approach.pdf (pg 159)
- UK office and operational infrastructure
- Technology and financial crime systems
- Safeguarding arrangements
- Professional, accountancy and audit costs
- Ongoing FCA fees
https://www.fca.org.uk/firms/fees
- Ongoing capital and compliance requirements
The £5,640 application fee is therefore only a relatively small part of the overall financial commitment involved in establishing and operating an AEMI.
Fees and regulatory requirements are correct at the time of publication and may change. Firms should check the latest FCA requirements before applying.
How much does it cost to become an AEMI in the UK?
Overview of costs
Becoming an Authorised Electronic Money Institution (AEMI) involves considerably more than paying an application fee to the Financial Conduct Authority (FCA).
Applicants need to account for capital requirements, compliance resources, safeguarding arrangements, systems and controls, professional support and the ongoing cost of operating as a regulated e-money institution.
What is the FCA application fee for an AEMI?
An application to become an Authorised Electronic Money Institution falls within the FCA’s Category 5 application fee.
The current fee is £5,640. This is a one-off application fee and is separate from the periodic FCA fees payable once a firm is authorised.
Check the latest FCA authorisation and registration application fees
How much capital does an AEMI need?
An AEMI issuing electronic money must have initial capital of at least €350,000.
This is not an FCA fee. It is a financial resource requirement, but it is an important part of the overall funding needed when planning an AEMI application.
Once authorised, AEMIs must also continue to meet the applicable own-funds requirements.
https://www.fca.org.uk/publication/finalised-guidance/payment-services-electronic-money-approach.pdf (pg 159)
What other costs should an AEMI budget for?
The wider cost of establishing an AEMI will depend heavily on what the business already has in place. For a new operation, some of the most significant areas of expenditure are likely to include people, premises, technology, compliance and professional support.
https://www.fca.org.uk/firms/apply-emoney-payment-institution/emi
Firms need to have the systems and processes in place to comply with relevant legislation and guidance including:
- The Electronic Money Regulations (EMRs)
https://www.legislation.gov.uk/uksi/2011/99/contents
- The Payment Services Regulations (PSRs)
https://www.legislation.gov.uk/uksi/2017/752/contents
- The Money Laundering Regulations (MLRs)
https://www.legislation.gov.uk/uksi/2017/692/contents
- The FCA Handbook
https://handbook.fca.org.uk/handbook
- The FCA Approach Document for e-money and payment services
https://www.fca.org.uk/publication/finalised-guidance/payment-services-electronic-money-approach.pdf
Senior management and compliance
AEMIs need appropriate governance and suitably experienced individuals to manage the business and its regulatory obligations.
This may involve recruiting directors and senior managers, compliance personnel, an appropriately experienced MLRO, and finance, risk and operational staff.
As a broad indication, salaries for MLROs and senior employees can be approximately £50,000–£150,000, while recruitment fees may add around 15%–30% of a candidate’s first-year annual salary.
Actual costs will depend on factors such as experience, responsibilities and location.
UK office and operational infrastructure
Applicants also need to establish an appropriate UK presence and the operational infrastructure needed to run the business effectively.
As an indication, serviced office costs can range from approximately £500–£1,200 per desk per month in London and £200–£700 per desk per month in other UK cities.
These are market estimates rather than costs prescribed by the FCA.
Systems and technology
Technology costs can vary considerably depending on the nature and scale of the business. AEMIs may require systems covering:
- Customer onboarding and KYC/KYB
- Transaction monitoring
- Sanctions screening
- Fraud detection
- Safeguarding and reconciliations
- Regulatory reporting
- Information security and incident management
Whether these systems are built internally or provided by third parties will have a significant impact on both initial and ongoing costs.
What safeguarding costs should an AEMI consider?
Safeguarding is a core regulatory requirement for AEMIs and needs to form part of the financial and operational planning for authorisation.
The FCA’s strengthened safeguarding regime came into force on 7 May 2026.
Safeguarding-related expenditure may include:
- Safeguarding accounts and arrangements
- Reconciliation processes and systems
- Record keeping
- Resolution packs
- Regulatory reporting
- Independent safeguarding audits
Safeguarding therefore needs to be considered during the planning and authorisation process, rather than treated solely as a requirement to address after authorisation.
Read the FCA’s safeguarding requirements for payment and e-money institutions
What are the ongoing costs of operating an AEMI?
Receiving authorisation is only the beginning of the regulatory lifecycle. An AEMI will continue to incur costs associated with maintaining its regulatory framework and meeting its obligations.
These can include:
- FCA periodic fees
- Compliance monitoring
- Financial crime reviews
- Safeguarding and regulatory reporting
- Financial, safeguarding, financial crime and IT/security audits
- Staff training
- Technology and security
- Policy and procedure reviews
- Ongoing capital requirements
As an indication, accountancy costs may be approximately £6,000–£25,000, while IT security audits can range from around £6,000–£30,000, depending on complexity. Combined annual audit costs could potentially be in the region of £30,000–£70,000.
These figures are intended as broad market estimates rather than FCA-prescribed fees. The actual cost will depend on the size, complexity and activities of the firm.
What Does an AEMI Application Need to Cover?
The resources needed to prepare the application itself are another important consideration.
Applicants need to demonstrate that they have appropriate governance, financial resources, risk management, financial crime controls, safeguarding arrangements, systems and operational infrastructure.
This requires detailed supporting documentation, including a programme of operations, business plan and financial information, alongside policies and frameworks covering the relevant regulatory requirements.
The FCA places considerable importance on receiving a complete application. Firms therefore need to factor in the work required to become authorisation-ready, rather than looking at the application in isolation.
Read the FCA requirements for electronic money institution applicants
How Neopay can help
Neopay has extensive experience supporting payment and e-money firms through the FCA authorisation process.
We can support prospective AEMIs with:
- Readiness and gap analysis
- Regulatory business plans and programmes of operations
- Governance and risk management frameworks
- Financial crime and AML frameworks
- Safeguarding arrangements
- Policies and procedures
- Application preparation and FCA liaison
- Training and ongoing compliance support
Addressing these areas early gives firms a clearer picture of the resources and investment required and can help identify potential gaps before an application is submitted.
If you’re considering AEMI authorisation and would like to discuss your application or the support you may need, contact Neopay to speak with one of our regulatory consultants.
Frequently Asked Questions
How much is the FCA application fee for an AEMI?
The current FCA application fee for an Authorised Electronic Money Institution is £5,640. Applicants should check the FCA’s latest fee schedule before applying.
How much capital does an AEMI need?
An AEMI issuing electronic money must have initial capital of at least €350,000. It must also continue to meet applicable own-funds requirements once authorised.
Is the FCA application fee the total cost of becoming an AEMI?
No. The application fee is only one element of the overall cost. Firms also need to budget for capital, personnel, premises, compliance systems, safeguarding, professional support, technology, audits and ongoing regulatory requirements.
How long does AEMI authorisation take?
The FCA states that it will usually assess a complete application within three months. An incomplete application can take up to 12 months to assess.
The overall process can be longer once the preparation period before submission is taken into account. Firms need sufficient time to develop their business plan, governance, financial crime framework, safeguarding arrangements and supporting documentation.
Does an AEMI have to safeguard customer funds?
Yes. AEMIs are subject to safeguarding requirements designed to protect relevant customer funds. The FCA’s strengthened safeguarding regime came into force on 7 May 2026.
Does an AEMI have to pay annual FCA fees?
Yes. The application fee is a one-off fee. Once authorised, an AEMI will also be liable for ongoing FCA periodic fees.
Is an AEMI the same as a bank?
No. An AEMI is authorised to issue electronic money and provide relevant payment services. This is different from being authorised as a bank and accepting deposits for the purpose of lending.
Useful FCA resources
FCA – Authorisation and registration application fees
FCA – Electronic money institution applicants
FCA – Safeguarding requirements for payment and e-money institutions
Fees and regulatory requirements are correct at the time of publication and may change. Firms should check the latest FCA requirements before applying.
