Unknown EMIs and PIs
United Kingdom
The UK Financial Conduct Authority published Freedom of Information data in November 2024 detailing the volume of regulatory actions taken against EMIs and PIs from 2020 through November 2024. For EMIs in 2024, there were 3 voluntary requirements (VREQs) and 6 s166 skilled person reviews, continuing a pattern of supervisory scrutiny. For PIs, 2024 saw 1 enforcement operation, 1 own-initiative requirement (OIREQ), 2 VREQs, and 1 s166 review. VREQs and OIREQs typically restrict activities such as ceasing payment services, onboarding bans, or fund safeguarding without prior FCA consent. The data does not name individual institutions but signals sustained FCA focus on the payments and e-money sector relevant to BaaS and fintech partnerships.
Verified from source: FCA FOI response (FOI11727) disclosed aggregate enforcement data for EMIs, PIs, and SPIs from 2020-2024 YTD, confirming that in 2024 EMIs received 3 VREQs and 6 s166 reviews, while PIs received 1 enforcement operation, 1 OIREQ, 2 VREQs, and 1 s166 review, matching the candidate record's figures exactly.
- Continued FCA supervisory pressure on EMIs and PIs signals heightened regulatory risk for BaaS and fintech models relying on UK-licensed e-money or payment institutions
- The sustained use of s166 skilled person reviews indicates the FCA is actively investigating compliance frameworks at payments firms, which may affect fintech partnerships
- Fintechs partnering with UK EMIs/PIs should expect potential activity restrictions (onboarding bans, safeguarding requirements) as VREQs and OIREQs remain common tools