N/A — Industry Guidance
United Kingdom
The FCA released an updated version of its approach document for payment services and electronic money regulation in November 2024, with tracked changes from the original 2017 publication. This guidance document outlines the FCA's supervisory expectations for payment institutions and electronic money institutions, including requirements around safeguarding, governance, capital adequacy, and conduct. The November 2024 update likely incorporates lessons from recent supervisory activity, including the elevated use of VREQs, OIREQs, and s166 reviews across the EMI and PI sectors. For the BaaS industry, this guidance shapes the regulatory framework within which UK-licensed payment and e-money firms operate as banking infrastructure providers to fintechs.
Verified from source: The URL confirms this is the FCA's tracked-changes version of its approach to payment services and electronic money (originally 2017), updated November 2024. The PDF content is encoded/encrypted but the URL path matches the candidate record exactly: fca-approach-payment-services-electronic-money-2017-november-2024-tracked-changes.pdf.
- Updated FCA guidance may introduce new or clarified expectations for EMIs and PIs acting as BaaS infrastructure providers
- Fintechs and their EMI/PI partners should review the updated guidance for changes to safeguarding, governance, or conduct requirements
- The timing alongside elevated enforcement activity suggests the FCA is aligning guidance with its supervisory findings