The preceding EMI article covers common application preparation and filing stages. The additional PI requirements depend on the service categories, capital calculation and application route. (Payment Services Regulations 2017, Schedule 1, Part 1; FCA, Payment institution applicants, “Supporting material for API applicants”.)
Summary
- Initial capital depends on the payment services: €20,000 for money remittance only, €50,000 for payment initiation, or €125,000 for the broader account, execution, issuing or acquiring categories. An account-information-only registration has separate treatment. (Payment Services Regulations 2017, Schedule 3, paragraph 2; Central Bank of Ireland, Guidance Note for the Payment Institution Supplementary Return XBRL, PIS 01.00, row 020; FCA, Account information services (AIS) and payment initiation services (PIS), “Our role in regulating AIS and PIS providers”.)
- A new authorised PI must be a UK-constituted body corporate with its head office and any registered office in the UK. An overseas company's UK branch does not satisfy that condition. (Payment Services Regulations 2017, regulation 6(4)–(5).)
- UK small-PI registration requires average monthly payment transactions of no more than €3 million and excludes payment initiation and account information services. Ireland has no equivalent small-PI regime. (Payment Services Regulations 2017, regulation 14(3)–(4), (12); Central Bank of Ireland, Payment Authorisation, “Small Payment Institutions”.)
- UK. A new full-authorisation application costs £2,820 or £5,640, depending on its service scope. Small-PI and account-information-only registrations each cost £1,130. (FEES 3 Annex 8R, entries (1)–(3); FEES 3 Annex 1AR, Categories 3–5.)
- Payment initiation and account information services require professional indemnity insurance or a comparable guarantee. The insurance assessment is separate from the initial-capital calculation. (FCA, Account information services (AIS) and payment initiation services (PIS), “Our role in regulating AIS and PIS providers”; Payment Services Regulations 2017, regulation 6(7)(e)–(f); Central Bank of Ireland, Regulatory Requirements and Guidance for Payment Institutions, “EBA Guidelines on Professional Indemnity Insurance under PSD2”.)
Payment services in the application
The proposed services must match the statutory categories. In the UK, paragraphs 1(a)–(e) of Schedule 1 cover cash-account services, payment execution, issuing payment instruments and acquiring payment transactions. Money remittance, payment initiation and account information occupy paragraphs 1(f), (g) and (h). The application must identify every relevant category. (Payment Services Regulations 2017, Schedule 1, Part 1; FCA, Payment institution applicants, “Supporting material for API applicants”.)
The distinction between remittance and acquiring affects the capital requirement. Money remittance does not involve creating payment accounts in the payer's or payee's name. Acquiring involves contracting with a payee to accept and process transactions that result in funds reaching the payee. The FCA considers that payment facilitators contracting to provide acquiring services can fall within this category. Technical processing alone does not establish acquiring. The applicant must examine its contractual role before selecting the lower remittance capital tier. (PERG 15.3, Q21–Q22; Payment Services Regulations 2017, Schedule 3, paragraph 2.)
The UK applicant company
A new UK authorised PI must be a body corporate constituted under UK law. Its head office, and registered office where it has one, must be in the UK. It must carry on at least part of its payment-services business there. A foreign company cannot meet these conditions solely by establishing a UK branch. This differs from the overseas-head-office EMI route addressed in the first part. (Payment Services Regulations 2017, regulation 6(4)–(5); FCA, Payment institution applicants, “Conditions you must meet”.)
Initial capital for the requested services
The UK starting requirement is €20,000 for money remittance, €50,000 for payment initiation, or €125,000 for any service within paragraphs 1(a)–(e). Where several categories apply, the highest initial-capital amount governs. Adding remittance to an acquiring application therefore leaves the statutory initial floor at €125,000. Account-information-only registration is addressed separately below. (Payment Services Regulations 2017, Schedule 3, paragraph 2.)
The Central Bank of Ireland publishes the same three capital tiers for Irish PIs. Its capital-reporting instructions identify money-remittance-only businesses, payment initiation providers and firms providing any of services 1–5. An Irish applicant must therefore calculate the starting amount from the requested services. (Central Bank of Ireland, Guidance Note for the Payment Institution Supplementary Return XBRL, PIS 01.00, row 020, pp. 8–9.)
UK requirements remain denominated in euros. A firm holding capital in sterling must account for exchange-rate movements when checking adequacy. The applicant must hold the required initial capital immediately before authorisation. A plan to raise it after permission is granted does not satisfy that timing condition. (FCA, Payment Services and Electronic Money – Our Approach, May 2026, paragraph 9.5; Payment Services Regulations 2017, regulation 6(3).)
Continuing own funds
An ordinary full PI must maintain own funds at least equal to the higher of its initial-capital floor and its applicable ongoing requirement. The relevant regulator directs the calculation method. Method A uses fixed overheads; Method B uses payment volumes; Method C uses a prescribed income indicator. The applicant cannot assume that the cheapest method will be accepted. UK PIs satisfying regulation 22(2)(b) are exempt from Methods A–C, but retain the initial-capital floor. (Payment Services Regulations 2017, regulation 22(1)–(2) and Schedule 3, paragraphs 3 and 8–10; Central Bank of Ireland, Guidance Note for the Payment Institution Supplementary Return XBRL, PIS 01.00, rows 010 and 030.)
A worked UK calculation demonstrates the difference between the initial floor and continuing capital. Assume a new remittance-only PI projects average monthly payment volume of €5 million. Assume the FCA directs Method B without a supervisory adjustment. The derived requirement is €5,000,000 × 4% × 0.5 = €100,000. That amount exceeds the €20,000 initial floor. The startup calculation uses the business-plan projection, subject to any adjustment required by the FCA. (Payment Services Regulations 2017, regulation 22(1) and Schedule 3, paragraphs 7 and 9(2)(a), (3)–(4).)
Payment-initiation-only providers receive different treatment. Under the UK rules, a firm providing only payment initiation, or payment initiation with account information, does not apply Methods A–C. It must still maintain the €50,000 floor. The Central Bank's Irish reporting instructions also exclude PIS-only providers from the A–C calculation. Adding another payment service requires a fresh assessment of the applicable capital duties. (Payment Services Regulations 2017, regulation 22(1)–(2); Central Bank of Ireland, Guidance Note for the Payment Institution Supplementary Return XBRL, PIS 01.00, rows 020–030.)
Small-PI registration in the UK
A qualifying UK business can apply for small-PI registration. The monthly average of payment transactions over the preceding 12 months must not exceed €3 million. Transactions executed through UK agents count towards that amount. A new business, or one operating for less than 12 months, can use its projected 12-month total to establish the average. The proposed services must exclude payment initiation and account information. (Payment Services Regulations 2017, regulation 14(3)–(4), (12).)
Small PIs do not have the full-PI initial-capital and ongoing own-funds requirements. Registration still depends on the statutory conditions concerning management, qualifying holders, close links (for corporate applicants), UK location and applicable anti-money-laundering registration. Satisfying the transaction threshold alone is insufficient. (FCA, Our Approach, paragraph 9.1; Payment Services Regulations 2017, regulation 14(5)–(11).)
Ireland has no small-PI regime. An Irish remittance business requiring its own PI permission cannot use the UK transaction threshold to obtain lighter registration. The separate account-information route remains available for a business confined to that service. (Central Bank of Ireland, Payment Authorisation, “Small Payment Institutions”; Forms for Payment Institutions, “Application for Registration as an Account Information Service Provider”.)
Account information, payment initiation and insurance
A UK business providing only account information services can apply as a registered account information service provider (RAISP). It has no capital requirement under that route. A proposed payment-initiation service requires authorisation instead. The distinction depends on the service performed: initiating an order is a separate activity from providing consolidated account information. (FCA, Account information services (AIS) and payment initiation services (PIS), “Account information services”, “Payment initiation services” and “Our role in regulating AIS and PIS providers”.)
A UK payment initiation provider must not hold the payer's funds in connection with that service. Absence of customer-fund possession therefore does not establish an exemption from authorisation. The provider must obtain the permission required for payment initiation despite that restriction. (Payment Services Regulations 2017, regulation 69(3)(a); FCA, Account information services (AIS) and payment initiation services (PIS), “Our role in regulating AIS and PIS providers”.)
Professional indemnity insurance, or a comparable guarantee, applies to payment initiation and account information providers. The required protection addresses specified liabilities arising from those services. In Ireland, the Central Bank advises applicants to submit the completed EBA insurance calculator with their own inputs and resulting calculation. That evidence should accompany the application rather than be replaced by an unexplained insurance figure. (FCA, Account information services (AIS) and payment initiation services (PIS), “Our role in regulating AIS and PIS providers”; Central Bank of Ireland, Regulatory Requirements and Guidance for Payment Institutions, “EBA Guidelines on Professional Indemnity Insurance under PSD2”; Expectations for PIEMI Authorisation and AISP Registration, p. 25.)
Safeguarding differences for UK PIs
A UK authorised PI receiving or holding relevant funds must apply the safeguarding requirements. A small PI can elect to safeguard voluntarily under regulation 23(16). Once it elects, CASS 15 applies as though it were an authorised PI. This election determines whether the statutory safeguarding regime applies to that small institution. (CASS 15.1.2R and 15.1.7R.)
A small PI that does not elect remains subject to Principle 10's requirement to arrange adequate protection for clients' assets. The FCA expressly distinguishes that duty from mandatory statutory safeguarding. Small registration therefore requires an assessment of customer-asset protection even when the institution does not opt into CASS 15. (FCA, Our Approach, paragraph 10.4.)
Payment institution application fees
The UK fee for a new full-authorisation application limited to money remittance, payment initiation or account information is £2,820. An application including any service within paragraphs 1(a)–(e) costs £5,640. Where more than one tariff applies, the highest governs. A small-PI application costs £1,130; the separate RAISP registration costs the same amount. (FEES 3 Annex 8R, entries (1)–(3) and opening tariff rule; FEES 3 Annex 1AR, Categories 3–5.)
A UK acquiring applicant therefore starts with a £5,640 application fee and a €125,000 initial-capital floor. Its continuing own-funds calculation remains necessary. For the Irish submission fee and annual levy, the first part's Irish application process provides the shared position. (FEES 3 Annex 8R, entry (3); FEES 3 Annex 1AR, Category 5; Payment Services Regulations 2017, regulation 22(1) and Schedule 3, paragraph 2; Central Bank of Ireland, Payment Authorisation, “Frequently Asked Questions”.)
The Irish PI application package
The Central Bank's current forms page marks the PI authorisation application form as under development. A prospective applicant should obtain the current submission requirements from the Payments Authorisation Team. An older downloaded form should not be assumed to be the required package. (Central Bank of Ireland, Forms for Payment Institutions, “Application Form for Authorisation as a Payment Institution”; Payment Authorisation, “Stage 1: Exploratory Stage”.)
The Central Bank expects the proposed initial capital to be injected after its “Minded to Authorise” letter and before the authorisation decision. The applicant must demonstrate timely funding for that injection and continuing capital requirements. The amount follows the PI's services rather than the EMI capital threshold discussed in the first part. (Central Bank of Ireland, Expectations for PIEMI Authorisation and AISP Registration, pp. 17–18; Guidance Note for the Payment Institution Supplementary Return XBRL, PIS 01.00, row 020.)
Agents and later service changes
A UK PI should identify planned agent use in its application and register its agents after authorisation or registration. It must not provide payment services in the UK through an agent until the agent is included on the FCA register. Undeclared agent use requires a SUP 15 notification and FCA confirmation of no material concerns before the agent application. Where the permission restricts agent onboarding, the firm must instead obtain removal of that restriction before submitting the agent notification. The principal remains responsible for its agents' acts and omissions. (Payment Services Regulations 2017, regulations 34(1) and 36(2); FCA, Payment institution applicants, “Registering agents”.)
In Ireland, the Central Bank requires prior approval to extend a PI's authorised services. It also requires prior approval for material business-model changes that leave the service permissions unchanged. A remittance firm proposing merchant acquiring must therefore obtain the broader permission and meet the corresponding capital requirement before providing that service. (Central Bank of Ireland, Amendments Processing for Payment Institutions, “Application for Extension of Authorisation” and “Application for Material Change of a Business Model”; Guidance Note for the Payment Institution Supplementary Return XBRL, PIS 01.00, row 020.)
