Licence route · SPI
Small Payment Institution
A registration route for firms whose monthly payment volumes remain under the regulatory threshold. Lighter than full authorisation, but the institution must still evidence safeguarding, governance and financial-crime controls.
AvailableApplication depth: Foundational
Who this route is generally for
Early-stage or lower-volume payment firms below the registration thresholds.
Typical activity
Payment services under a registration rather than full authorisation.
Key indicators
Regulatory status
Registered (not authorised)Source: PSRs 2017, reg. 14 · Position at 2026-07-30
Initial capital
No initial capital requirementSource: PSRs 2017 · Position at 2026-07-30
Ongoing own funds
No ongoing own funds requirementSource: PSRs 2017 · Position at 2026-07-30
Safeguarding
Required where relevant funds are heldSource: PSRs 2017, reg. 23 · 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 an SPI 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.