UK Payment Business Readiness Checklist
A structured checklist for overseas founders, investors, and payment businesses preparing to establish a UK payment institution or electronic money institution. Covers regulatory perimeter, governance, FCA application readiness, safeguarding, and evidence preparation.
Business Model Clarity
Clearly defined payment services or e-money activities the firm intends to perform
Target customer segments and geographic markets identified
Revenue model articulated with coherent volume and pricing assumptions
Distinction between regulated and unregulated activities documented
Product and service descriptions mapped to FCA regulatory permissions
UK Regulatory Perimeter
Identification of which UK regulatory regime applies (PSRs 2017, EMRs 2011, or both)
Determination of authorisation vs registration route
Assessment of whether passporting, temporary permissions, or new application is required
Understanding of which FCA-regulated activities will be performed
Legal opinion or regulatory perimeter analysis where activities are complex or novel
Payment Institution vs EMI Route
Decision documented on whether to apply as a payment institution, small payment institution, authorised EMI, or small EMI
Understanding of the operational and capital implications of each route
Assessment of whether e-money issuance is a core activity or ancillary
Safeguarding obligation differences understood between PI and EMI regimes
FCA Application Readiness
Programme of operations drafted covering business model, systems, controls, and governance
Financial projections prepared for at least three years including stress scenarios
Regulatory business plan coherent with proposed activities and permissions
All application forms identified and responsibility for completion assigned
Legal structure and ownership chain documented
Governance Structure
Board composition and terms of reference defined
Committee structure designed (risk, audit, compliance where applicable)
Decision-making authority routes and escalation paths documented
Conflicts of interest policy in place
Board meeting schedule and reporting cadence established
Senior Management Responsibilities
Senior management functions (SMFs) identified and allocated
Statements of responsibilities drafted for each SMF holder
Management responsibilities map (if applicable) prepared
Fitness and propriety assessments completed for proposed SMF holders
Handover and succession arrangements considered
Safeguarding Operating Model
Safeguarding method selected (segregation or insurance/guarantee)
Safeguarding bank account arrangements identified
Daily reconciliation process designed
Third-party due diligence for safeguarding account providers documented
Wind-down and resolution planning for relevant funds considered
Financial Projections and Capital Planning
Initial capital requirements calculated for the relevant licence type
Ongoing own funds requirements modelled
Wind-down cost analysis prepared
Revenue, cost, and break-even assumptions internally coherent
Stress and scenario testing applied to financial projections
Compliance Policies
AML/CFT policies, procedures, and controls drafted
Customer due diligence and ongoing monitoring frameworks designed
Sanctions screening approach documented
Complaints handling procedures in place
Data protection and privacy policies aligned to UK GDPR
Financial promotions policy prepared where relevant
Operational Resilience
Important business services identified and documented
Impact tolerances set for each important business service
Scenario testing planned for disruption events
Incident management and escalation procedures designed
Business continuity and disaster recovery arrangements in place
Outsourcing and Third-Party Risk
Critical and important outsourcing arrangements identified
Due diligence process for outsourced providers documented
Outsourcing register or inventory established
Contractual provisions aligned to FCA outsourcing expectations
Ongoing monitoring and exit strategy for each critical provider
Evidence Pack Preparation
All policies linked to named owners, approval records, and review schedules
Governance decisions traceable to board minutes and committee records
Financial model internally consistent and supported by documented assumptions
Safeguarding arrangements evidenced with account details and reconciliation processes
Control framework mapped to regulatory obligations with evidence links
RegNexus Platform Readiness
RegNexus deployment scope assessed for governance, evidence, and reporting needs
Regulatory workflows and evidence lifecycle management requirements identified
Board reporting and supervisory readiness infrastructure planned
Integration requirements with existing systems documented
Ongoing operational support and compliance monitoring scope defined
This checklist is provided as general guidance for UK market-entry planning. It does not constitute legal, regulatory, or financial advice, and does not guarantee FCA authorisation or registration. Every application is assessed individually by the FCA. Firms should obtain independent legal and regulatory advice appropriate to their specific circumstances.
Book a Free UK Market-Entry Advisory Call
Discuss your readiness with our team. We will review your position against this checklist and recommend the right support and infrastructure for your UK market-entry plan.