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FAQ · LicensingQ-59559561 min read

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

The question in full

Agent vs non agent EMI Europe UK difference lies in operational control and product scope. Non-agents are operator-led models managing compliance and custody, while agents include EMD and registered agents with varying levels of product distribution and approval from the principal EMI.

Answer

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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Faisal KhanAnswered 06/Aug/2026
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Page Last Updated: 06/Aug/2026 (5955956)