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Compliance & Risk

EMI / PI Licence Support

From dossier to go-live

Presentation

Overview

Applying for an Electronic Money Institution or Payment Institution licence is fundamentally a regulatory and legal process, but regulators increasingly expect that process to be backed by credible technical evidence: system architecture that actually enforces the safeguarding, security and operational resilience policies described in the application. Pay Engineers provides the technical and operational packaging that turns your compliance narrative into evidence a regulator can trust.

We work alongside your legal counsel and compliance advisors rather than replacing them. Our role is to ensure that when the application describes how customer funds are safeguarded, how security incidents are detected, or how the platform will scale operationally, there is a real system design behind those claims that would survive a regulator technical review or a later audit.

This engagement is equally valuable when you already hold a licence application in progress and have received technical queries or gap findings from a regulator that need a credible engineering response.

Who This Is For

  • Fintechs preparing an EMI or PI licence application in the UK, EU or comparable regimes
  • Businesses that have submitted an application and received technical gap findings requiring a structured response
  • Companies choosing between applying directly for a licence versus operating under an existing licence holder as an agent or distributor
  • Payment businesses needing sandbox and integration readiness ahead of onboarding with partner aggregators or banking-as-a-service providers

What You Get

  • A gap analysis comparing your current or planned architecture against what regulators typically expect to see evidenced
  • Technical dossier inputs: architecture diagrams, data flow documentation and control descriptions written for regulatory review
  • A shortlist of partner aggregators, BIN sponsors or banking-as-a-service providers matched to your business model and target markets
  • Sandbox readiness support, ensuring your systems are actually prepared to integrate once licensing or partner approval progresses

Technical Approach

We begin with compliance mapping: translating the specific regulatory requirements applicable to your licence type and jurisdiction into concrete technical and operational controls, rather than working from a generic checklist that ignores your actual business model. Architecture documentation is produced to the standard regulators and their technical reviewers expect, covering safeguarding fund flows, security architecture, incident response and operational resilience.

Where your application depends on partner integrations, whether a safeguarding account provider, a BIN sponsor, or a processing partner, we review and document the technical integration plan so that dependencies are clear and credible rather than aspirational. Where gaps exist between your current systems and what the application describes, we produce a realistic remediation plan with technical detail sufficient for your compliance team and legal counsel to use directly in the application narrative.

Delivery Process

  • Discovery of your licence type, jurisdiction, business model and current architecture maturity
  • Gap analysis against typical regulatory technical expectations for your licence category
  • Production of technical dossier inputs in close coordination with your legal and compliance advisors
  • Partner shortlisting and technical due diligence on the aggregators or BIN sponsors most relevant to you
  • Sandbox readiness work, run in parallel with your continuing legal application process

Outcomes and Benefits

  • A technical dossier that strengthens your licence application with credible, reviewable evidence rather than narrative alone
  • Faster resolution of regulator technical queries, since gaps are identified and addressed proactively
  • A well-matched partner shortlist that avoids months of wasted due diligence on unsuitable providers
  • Systems that are genuinely ready to integrate the moment licensing or partner approval is granted, avoiding a second delay after the legal milestone is cleared

Technologies

Compliance mapping Architecture docs Partner APIs

FAQ

An Electronic Money Institution licence permits the issuance of e-money and operation of user-held balances such as wallets, while a Payment Institution licence permits payment services such as payment initiation, acquiring or money remittance without issuing e-money balances. We help you determine which licence, or combination, fits your actual business model during an initial scoping exercise, since choosing the wrong licence type early can mean re-applying later at significant cost and delay. Some business models are better served by becoming an agent or distributor of an already-licensed institution rather than obtaining a licence directly, and we present that option honestly where it fits. This assessment happens before any dossier work begins, so the whole application is built around the right target from day one.
We support the preparation of the technical and operational sections of the licence dossier, including systems architecture descriptions, safeguarding and ledger design documentation, security policy alignment and business continuity planning, working alongside your legal counsel who handles the legal and corporate governance sections. Once submitted, we support responses to regulator information requests, particularly technical follow-up questions, which are common during the review process. After approval, we support the technical work needed to actually go live, such as safeguarding account integration and reporting system readiness, since a licence approval and a genuinely operational business are not the same milestone. We are not a law firm and do not provide legal advice, so legal counsel remains part of the engagement throughout.
Timeline varies significantly by jurisdiction and regulator workload, but a realistic range for a well-prepared application is 6 to 12 months from initial submission to approval, with additional time needed beforehand for dossier preparation, which we typically scope at 3 to 5 months depending on how much documentation already exists. Regulators frequently issue multiple rounds of follow-up questions, and how quickly and thoroughly these are answered has a material effect on overall timeline. We build a realistic project plan with your legal counsel at the outset rather than quoting an optimistic figure that creates false expectations with your board or investors. Businesses that need to operate before full licensing is complete often use an agency arrangement with an existing licence holder as an interim step.
Licensed institutions typically have ongoing obligations around safeguarding reconciliation, regulatory reporting, incident notification and periodic audits, several of which have direct technical implications for how your systems record and report data. We can support the technical implementation of these ongoing obligations as part of a licensing engagement or as a separate managed compliance retainer once you are operational. Getting the underlying ledger and reporting architecture right during the dossier phase significantly reduces the ongoing operational burden of these obligations later. We flag this connection explicitly during the initial technical design so it is not treated as a separate problem to solve after go-live.
We work alongside your legal counsel rather than replacing them; our role is specifically the technical and operational architecture components of the dossier, while legal counsel handles corporate governance, fit-and-proper assessments and the formal legal submission. If you do not yet have specialist regulatory legal counsel, we can recommend firms we have worked with previously in relevant jurisdictions, though the final choice and relationship remains yours. This division of responsibility reflects our actual expertise honestly, since a licensing application that is technically excellent but legally weak, or vice versa, is unlikely to succeed. We coordinate closely with counsel throughout the engagement so the technical and legal narratives remain fully consistent.

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