What is an EMI agent?

In short

An EMI agent is a person or company that provides payment services on behalf of a licensed electronic money institution or payment institution, once that institution has had the agent entered on the regulator's public register. The institution holds the licence and remains fully liable for the agent's acts under Directive (EU) 2015/2366 (PSD2), Articles 19 and 20.

Also called
Agent of an e-money institution, Agent of a payment institution, PSD agent
Family
Accounts, licences and compliance
Facts checked

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

Platforms that need it

Guides that go deeper

Where it is written

The laws and standards this page's facts come from.

General information, not legal advice: what applies to you depends on your services and your market.

Every term

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