Authorised vs Registered: What Payment Firm Status Really Means

TL;DR: Verification takes priority

Authorised e-money institutions (EMIs) hold a formal licence from a national competent authority (NCA) and must meet strict capital, governance, and operational rules under the Electronic Money Directive 2009/110/EC (EMD2). Registered small EMIs operate under a lighter regime but remain supervised. Account-information service providers (AISPs) and agents occupy different legal boxes entirely. Checking a firm's status on the European Banking Authority (EBA) EUCLID register or your national regulator's public list is the only reliable way to confirm what a payment firm actually is.

Step 1: Understand the four main categories

European payment firms fall into distinct regulatory boxes, each with different obligations and consumer protections. The category a firm belongs to determines its capital requirements, governance standards, and the scope of services it can offer. Confusing these categories is a common source of consumer risk.

Authorised EMIs hold a full licence from an NCA and can issue e-money, provide payment services, and hold customer funds. Registered small EMIs operate under a simplified regime but still require registration and ongoing supervision. AISPs provide account-information aggregation only - they never touch money. Agents are third parties acting on behalf of a licensed firm, not independent operators.

Step 2: Check the EBA EUCLID register

1. Visit the European Banking Authority (EBA) EUCLID register at www.eba.europa.eu/euclid.
2. Search by firm name, country, or licence number.
3. Confirm the firm's status field shows "Authorised" or "Registered" (not "Agent" or blank).
4. Note the NCA name and the authorisation or registration date.
5. Cross-check against the NCA's own public list (e.g., FCA Financial Services Register for United Kingdom firms, or the Bank of Lithuania register for Lithuanian EMIs).

The EUCLID register is the single source of truth for EMI and AISP status across the European Economic Area (EEA). If a firm does not appear, it is not licensed or registered.

Step 3: Distinguish authorised EMIs from small-EMI registrants

| Criterion | Authorised EMI | Registered Small EMI | |-----------|----------------|----------------------| | Minimum capital | EUR 1 million | EUR 350,000 | | Governance requirements | Full management body, compliance officer | Simplified structure permitted | | E-money issuance | Yes, unlimited | Yes, up to EUR 5 million outstanding | | Supervisory reporting | Quarterly/annual | Annual or biennial | | Scope of services | Full payment services | Restricted to own e-money scheme | | Authorisation timeline | 3-6 months typical | 1-2 months typical |

Small EMIs registered under Article 9a of EMD2 serve niche markets - typically closed-loop schemes like transport cards or corporate gift cards. They remain supervised but face lower compliance costs. The EUR 5 million cap on outstanding e-money is a hard regulatory limit; breaching it can trigger withdrawal of registration.

Step 4: Recognise AISPs and agents - they are not EMIs

Account-information service providers (AISPs) aggregate data from customer bank accounts but never move money or hold funds. Under the Payment Services Directive 2 (PSD2), AISPs must be registered with an NCA, but they operate under a different legal framework than EMIs. An AISP cannot issue e-money and has no capital requirements.

Agents are not independent entities. A licensed EMI appoints agents to distribute its services on its behalf. Agents appear in the EUCLID register with a status of "Agent" and a link to their principal firm. When an agent fails, the licensed EMI remains liable to customers.

Step 5: Verify the NCA's enforcement history

Check whether an NCA has issued public warnings about a firm or imposed sanctions. The Financial Conduct Authority (FCA) publishes a warning list; the Bank of Lithuania (LB) publishes enforcement notices on its website. As of Q1 2025, the EBA EUCLID register tracks approximately 1,087 active EMI and AISP entities across the EEA, but not all NCAs publish enforcement data uniformly.

A firm may be licensed but subject to conditions, restrictions, or ongoing investigations. Public enforcement data is sparse - most supervisory action occurs confidentially - but published warnings are red flags.

Red flags: What to watch for

• Firm claims authorisation but does not appear in EUCLID or the NCA's public list. This is the most common fraud signal. Verify directly with the NCA by phone or official contact form.
• Firm offers services outside its licence scope. A registered small EMI cannot offer payment initiation services; an AISP cannot hold funds. Check the EUCLID register for the "Services" field.
• Firm is listed as an "Agent" but markets itself as independent. Agents must clearly disclose their principal. Failure to do so violates PSD2 transparency rules.
• No published Terms of Service or Data Protection Notice. Licensed firms must publish these under PSD2 Article 52 and GDPR. Absence suggests unlicensed operation.
• Firm references a licence number that does not match EUCLID records. Scammers often invent plausible-sounding licence numbers. Cross-check every digit.
• NCA has issued a public warning naming the firm. The FCA and Bank of Lithuania maintain active warning lists. Check before sending money.

What this article does not cover

This post focuses on regulatory status under EMD2 and PSD2. It does not address: crypto-asset activities regulated under the Markets in Crypto-Assets Regulation (MiCAR); anti-money laundering (AML) or counter-terrorist-financing (CFT) obligations under the 5th Anti-Money Laundering Directive (AMLD5); deposit-guarantee scheme coverage (which applies to credit institutions, not EMIs); or prudential rules under the Capital Requirements Regulation (CRR) or Capital Requirements Directive (CRD). Authorisation as an EMI does not guarantee protection under a deposit-guarantee scheme. Consumers should verify whether funds held with an EMI are covered by an investor compensation scheme or are held in segregated trust accounts.

Frequently asked questions

Q: Can an AISP become an EMI?

Yes. An AISP can apply to its NCA for EMI authorisation, but it must meet the full capital, governance, and operational requirements of EMD2. The two licences are separate and require distinct applications.

Q: If an agent fails, who is liable to customers?

The licensed EMI that appointed the agent remains liable. Customers have recourse against the principal, not the agent. This is why verifying the principal's EUCLID status is essential.

Q: How often is the EUCLID register updated?

The European Banking Authority (EBA) updates EUCLID daily. New authorisations and registrations typically appear within 1-3 business days of NCA notification. Withdrawals may take longer to reflect.

Q: What is the difference between "Authorised" and "Registered" status in EUCLID?

"Authorised" means full EMI licence under EMD2 Article 5. "Registered" means small-EMI registration under Article 9a. Both are supervised, but registered small EMIs face lighter compliance burdens and a EUR 5 million e-money cap.

Q: Can I verify a payment firm's status without accessing EUCLID?

Yes. Contact the firm's NCA directly and provide the firm name and country. The NCA will confirm status by phone or email. This manual verification is slower but works if EUCLID is unavailable or if the firm operates outside the EEA.