The company should prepare an accepted replacement account in its own name while answering the information request and assessing the notice. Keeping the UK company as the receiving entity preserves its existing payment structure. Redirecting receipts to the Brazilian parent requires a separate assessment of who sells, collects and owes refunds.
- The UK account closure rules can require 90 days' notice, specific reasons and complaint information. The contract date, duration, customer classification, agreed exclusions and statutory exceptions determine the result. (Payment Services Regulations 2017, regs. 40(7), 51A–51D and 55.)
- The Brazilian parent matters to the assessment of group size and to the evidence explaining related-party payments. Parent funding must retain its true purpose when the company changes banking arrangements. (FCA, Payment Services and Electronic Money Approach, May 2026, Glossary, “micro-enterprise”; Lei 14.286/2021, arts. 3–4.)
- Finance should identify lawful available funds and the last usable date for every payment function. A complaint should proceed alongside the transition; it does not itself extend the closure timetable.
Establish what the notice actually does
Confirm the account holder, contracting bank, product and governing law. Identify the UK establishment providing the payment services. A sort code or familiar app name cannot establish those facts. (Payment Services Regulations 2017, reg. 40(1).)
Ask the bank to confirm the closure date and which functions remain available: incoming transfers, outgoing payments, direct debits, cards and statement exports. A future termination, a blocked payment instrument and a refused payment order require different analysis. The Regulations separately address instrument restrictions and payment refusals. (Payment Services Regulations 2017, regs. 71 and 82.)
A court freezing order requires its own response. Obtain the order and any permitted exclusions. The court can permit specified payments for carrying on a business; management cannot create that permission by moving the money elsewhere. (Proceeds of Crime Act 2002, ss. 303Z1(3) and 303Z5.)
The account here supports the company's operations. If the business instead holds balances for customers, the responsibilities change. The separate analysis of banking as a service partner exit and EU customer funds addresses that provider-and-customer relationship.
Apply the notice rules to the actual contract
The critical date is when the framework contract governing the account's payment services was entered into. An account opened after April 2026 points towards regulation 51B, but the signed agreement and acceptance records must establish that date. A new account under an older agreement, or a variation of existing terms, needs examination.
For an indefinite framework contract entered into on or after 28 April 2026, regulation 51B ordinarily requires notice at least 90 days before termination. It also requires sufficiently detailed and specific reasons, instructions for complaining to the provider and information about any Ombudsman right. The notice must satisfy the paper or durable-medium and language requirements. Check separately whether the bank has exercised a valid contractual termination power. (Payment Services Regulations 2017, regs. 51B and 55(1); S.I. 2025/688, regs. 1(2) and 3(4).)
For an indefinite contract entered into before that date, regulation 51A ordinarily permits provider termination on at least two months' notice where the contract provides for it. Fixed-term expiry requires separate analysis. A contractual promise of longer notice also needs to be assessed.
Check the company's status and any exclusion
A business outside the consumer, micro-enterprise and qualifying-charity categories may agree to disapply some or all of Part 6. Incorporation alone does not remove notice protection. Read the exclusion clause and identify which provisions it covers. (Payment Services Regulations 2017, regs. 2 and 40(7).)
The micro-enterprise assessment concerns status when the payment-service contract was concluded. The size test combines fewer than ten staff with annual turnover or a balance-sheet total not exceeding EUR 2 million. Apply the relevant partner and linked-enterprise treatment, including the Brazilian parent. The UK subsidiary's figures alone may therefore be insufficient. (Payment Services Regulations 2017, reg. 2; Recommendation 2003/361/EC, Annex, arts. 1–6; FCA Approach, May 2026, Glossary, “micro-enterprise”.)
Identify the precise exception
An outstanding information request does not establish an exception by itself. Regulation 51C removes the regulation 51B notice requirement in specified circumstances, including inability to complete required customer due diligence, defined crime concerns and certain official requirements. A separate conflicting legal duty prevails to the extent of that conflict. (Payment Services Regulations 2017, regs. 51B(4) and 51C.)
Regulation 51D has a different effect. Specified abusive or threatening conduct, or qualifying incorrect onboarding information, can remove the 90-day minimum while preserving a prompt notice obligation. For incorrect information, the bank must satisfy the condition that it would not have contracted had the correct information been supplied. The required reasons and complaint information remain subject to conflicting legal duties. (Payment Services Regulations 2017, reg. 51D.)
Assemble the account and transaction evidence
The director responsible for the response should preserve:
- The original agreement, acceptance record, product schedule and every relevant variation, including termination, restriction, information and set-off clauses.
- The closure notice, its delivery evidence, earlier warnings, outstanding requests and a dated record of disabled functions.
- The ownership chain, signatory authorities and financial and staffing records needed to assess the UK company and relevant group entities.
- Recent statements, processor settlements, scheduled payments, pending refunds and a reconciliation of the displayed balance.
The bank must apply the relevant customer and beneficial-owner checks, understand the relationship and monitor transactions, including their source where necessary. Companies House records alone do not discharge all its ownership checks. If required due diligence cannot be completed, the bank may have to stop transactions and terminate the relationship. (Money Laundering Regulations 2017, S.I. 2017/692, regs. 28(2)–(5), (9)–(11) and 31(1).)
For questioned subscription receipts, match the customer contract and invoice to the bank entry and any processor settlement. Explain fees, refunds, currency conversion and timing differences. Identify the entity supplying the software and the countries actually involved. Support unusual volumes or related-party payments with their records, and correct genuine discrepancies explicitly.
Provide an indexed response by the bank's deadline and request clarification of specific missing items. Ask for reasons that can lawfully be disclosed. Tipping-off restrictions can limit explanations when their statutory conditions are met; an unanswered question does not establish wrongdoing. (Proceeds of Crime Act 2002, s. 333A.)
Keep parent funding separate from subscription income
Emergency funding from Brazil should have a documented legal basis. If the Brazilian-resident parent subscribes capital or lends to the UK company, the approvals, funding agreement, payment description and accounts should describe that same transaction. A shareholder loan should not appear as customer revenue or as a transfer between accounts belonging to one legal person.
Where the funding uses Brazil's foreign-exchange market, conduct it through an institution authorised for the relevant operation. The customer is responsible for the transaction's purpose classification, with the institution's required guidance. Brazilian capital abroad must have an economic basis and supporting documentation. (Lei 14.286/2021, arts. 3–4; Resolução BCB 279/2022, arts. 2–3 and 6.)
Moving the UK company's own money between accepted accounts does not, by itself, create a Brazilian resident's direct bank deposit abroad. The parent's investment or loan claim needs its own reporting assessment. Brazilian capital-abroad reporting depends on the resident holder, aggregate reportable assets and applicable reporting dates. A UK bank change alone is not the filing test. (Resolução BCB 279/2022, arts. 1–3 and 7–8.)
If a fallback makes the parent collect UK subscription receipts, resolve the agency or changed seller arrangement before using it. Obtain the providers' acceptance and review the associated Brazilian payment, tax and accounting consequences. The recommended same-company replacement avoids introducing that additional structure during the closure.
Control the payment transition
Appoint a finance lead to maintain a payment calendar. For each obligation, record the amount, due date, payment rail, available funding, submission cut-off, approver and execution status. The bank's closure date may fall after an earlier processing cut-off.
Use the calendar to implement these steps:
- Fund payroll through a lawful, accepted route before the payroll provider's cut-off. Confirm execution before resubmitting a batch through another account.
- Check supplier payments, standing orders and direct debits individually. Obtain confirmation of changed instructions or replacement mandates and prevent duplicate collection.
- For processor-settled subscriptions, agree how the provider will settle receipts into the replacement account. Test the change before relying on it for the next settlement cycle.
- Preserve the original transaction references for refunds and chargebacks. Confirm how refunds will be funded and processed after the operating account closes.
- Update customer payment instructions only after verifying the receiving account. Track payments sent to the old account, including rejected or returned transfers.
- Export statements, payment confirmations, mandates and correspondence while access remains available. Preserve a company-controlled reconciliation record and agree later access arrangements. Accounting-record duties continue after closure. (Companies Act 2006, ss. 386 and 388.)
Request a written balance breakdown and the process for returning available funds. Separate pending transactions, charges, disputed deductions, contractual set-off and legal restrictions. Acquiring reserves may sit under a different agreement. A displayed balance does not establish that the entire sum can be transferred immediately.
Where due diligence cannot be completed, regulation 31(2) preserves a qualified route to repay money to its depositor. Ask the bank and advisers whether the proposed repayment requires consent or is subject to another legal restriction. (Money Laundering Regulations 2017, reg. 31(2).)
Obtain acceptance from the replacement provider
Apply in the UK company's name with one consistent account of its ownership, business and transaction pattern. Explain the bank-initiated closure accurately when asked. If reasons were not provided, say so. Do not describe the move as voluntary or claim that an investigation cleared the company without supporting evidence.
Confirm that the replacement supports the required currencies, payroll payments, direct debits, subscription settlements and refunds. Identify who owes the balance and whether it is a bank deposit or funds held through a payment institution or e-money issuer. Check the corresponding protection and repayment terms. Obtain acceptance before changing live instructions.
A new settlement account may be sufficient where the existing acquiring relationship remains available. Changing the processor as well adds separate contract and migration work. Payment processor selection for IT businesses addresses that additional decision.
Use the available complaint and legal routes
Check Financial Ombudsman eligibility before building the response around it. For payment-services complaints, micro-enterprise status is tested when the contract was concluded or when the complaint was referred to the bank. The separate small-business category is tested when the complaint was referred to the bank. It excludes micro-enterprises and requires annual turnover below GBP 6.5 million and either fewer than 50 staff or a balance-sheet total below GBP 5 million. Relevant partner and linked enterprises must be considered, alongside the other eligibility and jurisdiction conditions. A company can qualify for this complaint route while being large enough to agree a Part 6 exclusion. (FCA Handbook, DISP 2.7.3R–2.7.6R; Glossary, “micro-enterprise” and “small business”.)
Send the complaint to the bank first. A payment-services complaint within the relevant rules ordinarily requires a final response by the end of 15 business days after the day of receipt. In exceptional circumstances beyond the bank's control, it must send a holding response within that period, explaining the delay and giving a final-response deadline within 35 business days. Other complaints ordinarily follow the eight-week process. A closure dispute may contain issues falling under different rules. The usual Ombudsman referral deadline is six months from the date the bank sends a qualifying final response, alongside the other applicable time limits. (FCA Handbook, DISP 1.6.2R, 1.6.2AR–1.6.2CR and 2.8.2R.)
Ask for an extension or correction where the evidence supports it, and record any agreement. Continue the transition unless the timetable is actually changed. Preserve evidence of loss and steps taken to avoid it.
If the company cannot use the Ombudsman, regulation 101 can still require a provider complaint procedure for disputes about Parts 6 and 7. Obtain advice on contractual remedies and any urgent court application. Regulation 148's statutory damages route excludes a body corporate's losses incurred in carrying on business. It should not be presented as an automatic compensation claim for this SaaS company. (Payment Services Regulations 2017, regs. 101 and 148(1)–(3).)
Regulated claims advice or representation requires an applicable authorisation or exclusion. Litigation and rights of audience require the relevant entitlement in the chosen UK jurisdiction. In England and Wales, those are reserved legal activities. (Financial Services and Markets Act 2000, ss. 19 and 419A; Regulated Activities Order 2001, arts. 89F–89I and 89N; Legal Services Act 2007, ss. 12–14.)
Put the response into operation
On receipt, preserve the notice and records, confirm usable services and identify the next payment cut-offs. The director should commission the contract and eligibility assessment. Finance should answer the transaction questions and prepare the payment calendar. Brazilian advisers should check any parent-funding or changed collection route.
Before redirecting receipts, obtain the replacement provider's acceptance and test the essential payment functions. After the switch, reconcile late receipts, refunds, outstanding balances and charges until each item has an identified outcome.
Plan the banking transition
Licentium's banking continuity and account closure review describes the contract and planning scope. Request a review of the account closure and payment continuity options.