Payment services & E-money
Safeguarding Compliance Reviews/Gap Analysis
Entering the UK’s dynamic payment services market offers immense opportunity, but it requires robust systems and controls to remain within the perimeter once authorised. As of 7 May 2026, the FCA has significantly raised the bar for safeguarding compliance through policy statement PS25/12 under the CASS 15 Supplementary Regime. AEMI and SEMI firms (as well as SPI’s who have opted in to safeguard) must now move beyond informal processes to meet prescriptive standard ahead of upcoming mandatory Annual Safeguarding Audits, by ensuring safeguarding arrangements are able to stand up to the the scrutiny and standards set by the FCA.
At Apex Compliance Advisory, we provide independent Compliance Reviews of safeguarding arrangements through conducting a gap analysis of current processes that are in place against the CASS 15 standards. Identifying and remediating control failures long before they become reportable breaches during a mandatory Annual Safeguarding Audit. This expert, support to navigate the regulatory landscape, ensures your firm is compliant with FCA regulation and protects your reputation so that you can continue to serve your customers and grow your business.
Scalable Payment Solutions from API to AEMI
If you are a business seeking to enter the UK Payment Services sector, it is important to prepare in advance as navigating the UK’s payment landscape requires a regulatory strategy that scales alongside your commercial ambitions. Entering the regulatory perimeter with a Money Remittance API licence perfect for cross-border transfers is the first step towards initial market entry, eventually transitioning into an Authorised Electronic Money Institution (AEMI). This transition enables you to shed transaction volume restrictions and gain the Authorised status that commands significantly higher credibility with banking partners, investors, and global clients. It is a strategic move that unlocks the power to issue e-money, manage digital wallets, and integrate Open Banking (AIS/PIS), transforming your business from a simple remittance provider into a comprehensive, high-scale financial platform.
From helping start-up money transfer business secure their API licence to guiding already authorised APIs to secure the AEMI Authorised status, at Apex Compliance Advisory we cater for all. Our strategic advice is based on a feasibility study of your business journey as an AEMI requires a significant €350,000 capital injection whereas a Money Remittance API can be launched with as little as €20,000 in initial capital. This makes the API route a highly efficient way for startups to enter the UK market before scaling up to full AEMI status as their business evolves.
The SPI or SEMI option
For many fintech startups, the barrier to entry isn’t just technology, it’s the capital and regulatory burden. This is where the Small Payment Institution (SPI) and Small Electronic Money Institution (SEMI) routes offer a strategic, cost-effective entry point into the UK market. The SPI model is the ideal launchpad for businesses focused on small scale money remittance with less than €3 million monthly transaction volume on average. It features a significantly less stringent registration process than a full API and you bypass initial capital requirements during the critical early growth phase.
As your product evolves into a digital wallet or stored value platform, the Small E-Money Institution (SEMI) provides a unique, alternative to a full AEMI. The standout commercial benefit of a SEMI is the absence of initial capital requirements, with ongoing capital obligations only kicking in once your issued e-money exceeds €500,000. While a SEMI is subject to a €5 million cap on average outstanding e-money and cannot perform Open Banking activities (AIS/PIS), it offers a low-overhead environment to issue electronic value and refine your safeguarding frameworks. At Apex Compliance Advisory we cater for a wide range of clients with different circumstances, providing a personalised service to each and every client we work with as we understand firms have different timelines and milestones.
Your Partner in Payment Services Compliance
Whether the API or SPI route is right for you, Apex Compliance Advisory is here to provide clarity and expert guidance. We manage the entire compliance process, from strategic planning to final delivery, ensuring your firm is fully FCA compliant.