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October 12, 2021
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What is the difference between an agent and non-agent of an EMI in Europe/UK?

Understand EMI Agent and Non-Agent models in Europe/UK. Learn how EMIs operate through operator-led (non-agent) structures vs agent-led models like EMD and Registered Agent, and their roles in compliance, custody, and product distribution.

Faisal Khan

Consultant, Cross-Border Payments & Fintech Licensing

What is the difference between an agent and non-agent of an EMI in Europe/UK?

What is the difference between an agent and non-agent of an EMI in Europe/UK?

There are a couple of differences between an agent and a non-agent in the European EMI licensing regime.

A non-agent for starters is commonly referred to as an operator-led model. Where the operator of the license is handling all the facets of custody of funds, compliance, reporting, etc. The non-agent is essentially responsible for marketing & sales, including the first level of customer support.

For an Agent led model, there are essentially two: 

  1. EMD - Electronic Money Distributor, and
  2. RA - Registered Agent

You can see a detailed comparison I did on this earlier on at: https://faisalkhan.com/delegate-status-comparison-table/

The main difference between the two is that an EMD can only resell the services that the principal EMI is offering, whilst an RA can create new products/services that the RA can sell, with the approval of the principal EMI.

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