EMI Agent
A firm through which an electronic money institution provides payment services in the UK. The EMI applies for the agent’s registration and the FCA registers it; the agent holds no authorization of its own, acts under the institution’s permissions, and the EMI remains responsible for everything the agent does or fails to do.
Also called: agent of an electronic money institution · e-money agent
Agency is how a licensed firm extends its reach without the people doing the work applying for authorization of their own. The EMI carries out due diligence on the prospective agent and applies to the FCA for the agent’s registration; the FCA registers it, and may refuse on money-laundering or fitness grounds. The agent then appears on the public register as an agent of that EMI — identified as belonging to a principal, not as authorized itself.
The distinction decides who bears what. The EMI is answerable for anything the agent does or omits, to the same extent as if it had expressly permitted it, so the EMI writes the compliance requirements, audits against them and can end the arrangement. The agent is running a business that exists at the principal’s discretion, on the principal’s permissions rather than its own.
Agency, distribution and issuing
An EMI may provide payment services in the UK through an agent only if that agent is on the FCA register. The same agent may also distribute or redeem the institution’s electronic money — the regulations expressly allow an EMI to do that through an agent — which is the activity an e-money distributor performs, the difference being that a distributor needs no registration and may not provide payment services. What no agent, distributor or other party acting for the institution may ever do is issue the e-money. That stays with the EMI, and so does the duty to safeguard the funds behind it.
In practice
An EMI agent is registered to provide payment services for the institution and may also distribute or redeem its e-money. What it can never do is issue e-money, which stays with the institution along with the duty to safeguard the funds behind it. The agent trades on the institution’s permissions rather than its own, and the institution is answerable for what the agent does as if it had done it itself.
Example
A software company wants to give its users accounts and payment functionality. Rather than apply for its own authorization, the EMI it works with applies to have it registered as that EMI’s agent. The accounts and the e-money belong to the EMI, the EMI safeguards the funds, and the software company appears on the register beneath it. End the arrangement and take the agent off the register, and the product stops.
Commonly confused with
| Term | How it differs |
|---|---|
| E-money Distributor | A distributor sells and redeems the EMI’s e-money, while an EMI agent provides payment services on the EMI’s behalf, and holding one status does not confer the other. |
| Appointed Representative | An appointed representative acts under FSMA for regulated activities; an EMI agent acts under the e-money and payment services regimes, and the two are recorded on different parts of the register. |
See also
- Payment Services AgentA payment services agent is a person that provides payment services on behalf of a payment institution, an electronic money institution or a registered account information service provider. The principal applies and the FCA decides; the agent is entered on the register, works under the principal’s permissions, and the principal answers for what it does.
- E-money DistributorAn e-money distributor is a person engaged by an electronic money institution, authorized or small, to distribute or redeem that institution’s electronic money on its behalf. It issues nothing itself and cannot provide payment services; the customer’s claim on the funds stays against the institution.
- Electronic Money InstitutionA firm authorized in the United Kingdom or in an EU member state to issue electronic money and to provide payment services. The e-money it issues is a claim its holders have against the institution, redeemable at par and expressly not a deposit, which is why the funds behind it must be safeguarded.
- Appointed RepresentativeA UK firm that carries on regulated activities under FSMA as the representative of an authorized principal firm. The principal accepts regulatory responsibility for what the representative does, and the representative holds no authorization of its own.
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Regulatory information checked: 22/Sep/2026