How an EMI agent is registered
The licensed institution, called the principal, applies to its own regulator. The agent does not apply. In the EU the file names the agent, describes its anti-money laundering controls, identifies its directors and managers with evidence that they are fit and proper, and lists the payment services the agent is mandated for (PSD2, Article 19).
The authority has two months to say whether the agent is on the register, and the agent may start only once it is. In the UK an EMI may provide payment services through an agent only if the agent is on the FCA's register, and the FCA decides within two months of a completed application (Electronic Money Regulations 2011, regulation 34).
What an EMI agent may and may not do
- May provide the principal's payment services on its behalf, once registered.
- May distribute and redeem e-money for an electronic money institution.
- May not issue e-money: EU and UK law both bar issuing through agents.
- Is presented to customers as an agent: the principal ensures they are told.
- Does not carry the liability: the principal answers for what the agent does.
- Counts towards a small institution's limits, which include its agents' transactions.
In the UK the principal is responsible for anything an agent does or omits, to the same extent as if it had expressly permitted it (regulation 36). An agent in another EU Member State is notified through the cross-border procedure (PSD2, Articles 19 and 28).
When the agent route matters
The agent route lets a company launch payment services before it holds a licence of its own. The principal's licence covers the service, and the agent brings the product and the customers.
Because the principal is liable, its contract usually sets the agent's onboarding, monitoring and complaints handling. A company that only sells, loads or redeems e-money, and provides no payment service, can be a distributor instead.
What is changing: PSD3
The EU has agreed a third Payment Services Directive (PSD3) but has not adopted it: on 13 October 2026 it was awaiting the Council's first-reading position. The agreed text narrows the definition of an agent, asks for more information in the registration file and shortens the authority's time to answer.
The ban on issuing e-money through agents and the principal's full liability both stay.
Agent, distributor or technical provider?
- Distributor
- Distributes or redeems e-money for an EMI but provides no payment services on its behalf (UK Electronic Money Regulations 2011, regulation 2). The EMI answers for a distributor as it does for an agent.
- Technical provider
- Supplies software or processing to the institution without providing the payment service to customers. The institution informs its authority when it outsources operational functions (PSD2, Article 19).
- Banking-as-a-service customer
- A commercial label, not a legal status. The legal role underneath is agent, distributor or outsourced provider.
- Electronic money institution
- Holds the authorisation, issues the e-money, safeguards the funds and is liable. The agent acts under it.
Where an EMI agent shows up in a platform
Modules that do the work
- Accounts & IBANsCustomer accounts with their own IBANs, on the partner bank and the rails you choose.
- KYC / AMLIdentity checks, screening and ongoing monitoring, with the verification provider you choose.
- Compliance reportingTransaction monitoring, the Travel Rule and regulatory reports, ready for your regulator.
Platforms that need it
Guides that go deeper
- EMI or payment institution licence in the EU, and the agent routeWhat an e-money institution and a payment institution may do in the EU, the capital each needs, safeguarding, passporting, and launching as an agent first.
- EMI or payment institution licence in the UK, or launch under a partnerE-money or payments, authorised or small: what the FCA asks for in capital, safeguarding and people, how long it takes, and when an agent or banking partner is the faster route.
- How to launch a neobank without a banking licenceYour own e-money licence, an EMI's agent, a partner bank or a bank licence: how each route works, who holds the money, and what safeguarding and deposit protection cover.
Where it is written
The laws and standards this page's facts come from.
- Directive (EU) 2015/2366, PSD2, consolidated (EUR-Lex)
- Directive 2009/110/EC, the E-Money Directive, consolidated (EUR-Lex)
- Electronic Money Regulations 2011 (legislation.gov.uk)
- PSD3, text agreed in negotiations, 5 May 2026 (European Parliament)
- PSD3, procedure 2023/0209(COD) (European Parliament, Legislative Observatory)
General information, not legal advice: what applies to you depends on your services and your market.