Multiple EMI/PI Firms (14 sampled)
United Kingdom
The UK Financial Conduct Authority (FCA) published findings from multi-firm reviews examining risk management and wind-down planning at e-money institutions and payment firms. The reviews, conducted across 2024 and into 2025, found that many firms had underdeveloped wind-down frameworks. While no specific enforcement actions or fines were announced as part of this review, the findings signal supervisory expectations and potential future enforcement for firms that fail to remediate. This is relevant to BaaS providers operating under UK EMI licenses, as inadequate wind-down planning could affect partner banks and their fintech clients.
Verified from source: The FCA conducted a multi-firm review during 2024/2025 of 14 e-money and payments firms, finding that risk management frameworks and wind-down plans remain underdeveloped across the sector, with none of the reviewed firms fully meeting FCA expectations.
- UK EMI/PI firms face heightened supervisory scrutiny on operational resilience and wind-down readiness
- BaaS providers with UK EMI licenses may need to strengthen wind-down plans to meet FCA expectations
- Potential for future enforcement actions against firms failing to address identified deficiencies