Licence route · SEMI
Small Electronic Money Institution
A registration route for e-money issuers whose average outstanding e-money stays below the small-EMI threshold. Genesis constructs the safeguarding and float-reconciliation design the FCA expects.
AvailableApplication depth: Moderate
Who this route is generally for
Lower-volume e-money issuers below the small-EMI threshold.
Typical activity
Issuing electronic money and providing related payment services at limited scale.
Key indicators
Regulatory status
Registered (small EMI)Source: EMRs 2011, reg. 12 · Position at 2026-07-30
Initial capital
No initial capital requirementSource: EMRs 2011 · Position at 2026-07-30
Ongoing own funds
No ongoing own funds requirementSource: EMRs 2011 · Position at 2026-07-30
Safeguarding
Required for e-money float and relevant fundsSource: EMRs 2011, reg. 20 · Position at 2026-07-30
Route indicators are informational and require confirmation against the full business model and applicable law.
How Genesis supports the route
Building a SEMI the regulator expects.
- Determines route eligibility from actual activities and funds flow
- Builds the regulatory business plan and programme of operations
- Constructs the route-specific financial model
- Designs safeguarding where applicable and reconciles it
- Assembles the evidence schedule and challenges the application before submission
Common weaknesses
What delays applications.
- Financial model that contradicts the business narrative
- Safeguarding design that does not reconcile with funds flow
- Governance that exists on paper but not in operating reality
- Evidence gaps against stated regulatory claims
- Permissions that do not match the actual activities
Current Genesis route status: Available
This route has a certified reference application pack.