Payment Services Agent
A 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.
Also called: agent of a payment institution · PSR agent · registered agent
How the registration works
A payment services agent is not authorized in its own right. The principal — an authorized or small payment institution, an electronic money institution, or a registered account information service provider — applies to the regulator to have the agent and the payment services it will carry out entered on the register, and the regulator decides. It can refuse, on grounds including the fitness of the agent’s directors and managers, or concerns about money laundering. The agent may not act until it is on the register, and remove the principal and it has no permission to act at all.
Why the distinction matters
Agency is a common route to market for a firm that does not want to hold its own license, and it is genuinely narrower than a license. The agent may do only what the principal is permitted to do and what the principal has had it registered to do. The principal owes the regulator the customer outcomes, the safeguarding of customer funds — which never passes to the agent — and the anti-money-laundering controls covering the agent’s business, and it is responsible for what the agent does or fails to do as though it had expressly permitted it. That is why principals audit their agents rather than simply signing them up.
An EMI agent is the same arrangement where the principal is an e-money institution rather than a payment institution. The European Union has its own agent regime under PSD2, but it is implemented separately in each member state and the agent goes on the home state’s register, so it is not one European status and not the same paperwork as the UK one.
In practice
An agent of a payment institution or EMI is registered by the FCA on its principal’s application — the principal proposes, the regulator decides — and it works under the principal’s permissions rather than any of its own. That is a different legal status from an appointed representative under the Financial Services and Markets Act, which cannot be used for payment services at all, and different again from a US authorized delegate appointed under state money transmission law. The three are not interchangeable.
Example
A UK payments firm wants to sell an existing EMI’s wallet product under its own brand. Rather than apply for its own license, it is put forward by the EMI and entered on the FCA register as its agent. Its permissions are a subset of the EMI’s, its customers are the EMI’s customers for regulatory purposes, and if it mis-sells, the EMI answers for it.
Commonly confused with
| Term | How it differs |
|---|---|
| Appointed Representative | An appointed representative is appointed under the Financial Services and Markets Act for regulated investment and insurance business; a payment services agent is registered under the payment services regime. |
| Authorized Delegate | An authorized delegate is the US role, appointed by a state-licensed money transmitter under state law, not registered by a UK or EU principal. |
| E-money Distributor | A distributor may only distribute or redeem e-money that has already been issued; an agent may execute payment services on the principal’s behalf. |
See also
- EMI AgentA 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.
- 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.
- 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.
- Payment InstitutionA payment institution is a firm authorized in the United Kingdom or a European Union member state to provide payment services — transfers, acquiring, remittance, payment initiation — but not to issue electronic money. It may hold customer funds in payment accounts used only for payment transactions; those funds are neither deposits nor e-money.
- Authorized DelegateA company authorized to conduct money transmission on behalf of a licensed principal, operating under that principal’s money transmitter license rather than holding one of its own. Most US states call this an authorized delegate; some call it an agent.
Go deeper
Regulatory information checked: 22/Sep/2026