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:
- EMD – Electronic Money Distributor, and
- 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.
-  Working with an EMI license and becoming an EMD Agent
-  Difference between EMD (Registered Agent) and Sponsorship
-  EMI Agents & Restriction on Correspondent Agreements
This page was last updated on February 14, 2023.