Unknown EMIs (3 institutions)
United Kingdom
FCA data through November 2024 shows three VREQs were imposed on EMIs during 2024, continuing a declining trend from a peak of 10 VREQs in 2022 and 5 in 2023. VREQs are voluntary commitments by firms to restrict their activities, often used when the FCA identifies compliance concerns. Common restrictions include halting onboarding of new customers, ceasing specific payment services, or requiring FCA approval before safeguarding client funds. While the specific institutions are unnamed, EMIs are key infrastructure providers in the UK BaaS ecosystem, and these restrictions can directly impact fintech partners relying on EMI licenses for payment services and e-money issuance.
Verified from source: FCA FOI response confirms that 3 Electronic Money Institutions were subject to Voluntary Requirements (VREQs) in 2024 year-to-date (through November 2024). The FCA described typical VREQs as including requirements to cease payment services, cease onboarding new customers, ensure safeguarding of funds, and notify customers.
- VREQs on EMIs can disrupt fintech services relying on those EMI licenses, potentially forcing partner migrations
- The declining but persistent use of VREQs indicates the FCA maintains ongoing concerns about EMI compliance standards
- Fintechs should conduct due diligence on whether their EMI partner is subject to any activity restrictions