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Authorized Payment Institution (API) vs Small Payment Institution (SPI) in the UK

The UK remains one of the world’s most mature and opportunity-rich markets for payment service providers. Whether a business wants to launch a remittance platform, digital wallet, FX service, merchant payouts engine, or a neobank layer, it must operate under the regulatory umbrella of the Financial Conduct Authority (FCA). Two licensing options dominate the landscape:

  • Authorized Payment Institution (API)
  • Small Payment Institution (SPI)

What Is an Authorized Payment Institution (API)?

An Authorized Payment Institution (API) is a fully licensed payment provider under the UK Payment Services Regulations 2017 (PSRs). It offers the broadest level of payment service permissions and may also passport services across the EEA (subject to post-Brexit rules). APIs are chosen by companies that require enterprise-grade payment capabilities and full operational flexibility.

  • International remittance providers
  • Multi-currency wallets
  • FX and settlement platforms
  • B2B payments and treasury networks
  • Neobanks
  • Fintech-as-a-service platforms
  • Enterprise payment rails

API authorization delivers maximum capability but comes with strict FCA scrutiny, detailed documentation, proven governance structures, and strong safeguarding and AML/CTF systems.

What Is a Small Payment Institution (SPI)?

A Small Payment Institution (SPI) is a lighter and more accessible payment registration for fintechs with limited transaction volumes. It is ideal for businesses launching an MVP, testing product–market fit, or operating within a controlled monthly processing limit.

  • Can operate only within the UK
  • Limited to €3 million average monthly transaction volume
  • Cannot offer Payment Initiation Services (PIS)
  • Cannot offer Account Information Services (AIS)
  • Lower reporting and compliance requirements
  • Perfect entry point for new fintechs

Many companies start as SPIs to build operational maturity before upgrading to full API licensing.

Core Differences Between API and SPI

APIs and SPIs differ significantly in scope, regulatory oversight, and scalability. Below is a summary that shows why APIs are ideal for scaling, while SPIs serve early-stage payment models.

  • Geographical reach: SPI = UK only, API = UK + structured EEA expansion
  • Transaction volume: SPI up to €3m monthly; API has no cap
  • AIS/PIS capability: Only API can provide open-banking services
  • Initial capital: API requires adequate initial capital under PSRs
  • FCA scrutiny: API requires full governance and risk frameworks
  • Scalability: API supports enterprise-level operations

FCA Requirements for Becoming an Authorized Payment Institution (API)

API applicants must meet stringent FCA conditions that demonstrate operational resilience, compliance maturity, and governance capability across all payment-related activities.

  • Be a UK-registered body corporate
  • Head office and operational control located in the UK
  • Fit and proper shareholders and managers
  • Directors with proven experience and good repute
  • Robust governance, internal controls, and risk management
  • A detailed business plan and financial projections
  • Safeguarding arrangements (segregated accounts or insurance)
  • Full AML and financial crime controls under MLRs
  • Security policies and incident-reporting procedures
  • Wind-down planning demonstrating orderly exit

Safeguarding & Capital Requirements

All APIs must safeguard customer funds through segregated accounts or approved insurance mechanisms. They must also hold adequate initial capital depending on the services they offer—aligned strictly with FCA and PSR standards.

Small Payment Institution (SPI) Requirements

SPI approval is more accessible but still requires compliance with UK Money Laundering Regulations, responsible governance, and a defined operational model.

  • Monthly volume below €3m
  • No AIS/PIS permissions
  • UK-only operations
  • Fit and proper owners and directors
  • Appropriate AML/MLR controls
  • Clear organizational structure and reporting systems
  • Complaints handling and incident reporting processes

Strategic Differences Between API and SPI

The decision between SPI and API depends on a firm’s growth trajectory, funding strategy, and long-term payment model.

  • API: Best for enterprise scaling, EEA structuring, high volume, and open-banking services.
  • SPI: Best for early-stage fintechs testing limited flows or operating under volume caps.

When Should a Firm Choose SPI?

SPI is suitable for firms that want a simple, faster entry into the payments ecosystem.

  • Early-stage fintechs testing MVP
  • Limited initial capital
  • No AIS/PIS requirements
  • Planning to scale gradually

When Should a Firm Choose API?

API is the right choice for businesses with ambitious growth plans and regulated service requirements.

  • High-volume remittance or payment platforms
  • Multi-currency and cross-border operations
  • Corporate/enterprise client needs
  • Open banking products (AIS/PIS)
  • EEA-structured expansion

Understanding the SPI → API Upgrade Path

Many fintechs intentionally start as SPIs and upgrade to API once they gain financial resilience, compliance maturity, and FCA supervisory familiarity.

Why Compliance Quality Determines FCA Success

The FCA prioritizes security, governance, and customer protection over commercial opportunity. Strong compliance frameworks dramatically increase approval success.

  • Strong AML/CTF systems
  • Clear business model & customer flows
  • Proven safeguarding controls
  • Competent MLRO & directors
  • Accurate documentation & data methodologies

Common Reasons FCA Rejects Applications

  • Weak AML/CTF frameworks
  • Unclear business model and risk exposure
  • Poor safeguarding structures
  • Inexperienced leadership
  • Incomplete documentation

Why Payment Firms Need Robust Remittance Management Software

Both SPI and API firms must maintain accurate reporting, AML checks, transaction monitoring, and audit trails. A robust platform is essential for meeting FCA expectations.

  • AML/KYC automation
  • Risk scoring & alerts
  • Audit logs
  • Safeguarding fund management
  • Operational governance
  • Multi-currency FX and payout tools

How RemitSo Helps Firms Become FCA-Compliant

RemitSo provides the compliance backbone required for payment institutions through automated KYC, AML monitoring, audit trails, multi-currency tools, and risk management frameworks.

Conclusion

Choosing between SPI and API is a critical strategic decision. SPIs offer a low-barrier entry, while APIs provide enterprise scalability, broad permissions, and cross-border capability. Regardless of the path, strong governance, AML controls, and operational resilience are non-negotiable for long-term success.

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FAQs

An API can operate without transaction volume limits and may expand across the EEA through structured licensing. An SPI is restricted to the UK and limited to €3 million monthly transaction volume.

Yes. Many firms start as SPIs to reduce early compliance burden, then upgrade to API once their governance, operations, and compliance frameworks are more mature.

No. SPIs cannot offer Payment Initiation Services (PIS) or Account Information Services (AIS).

Yes. APIs must hold adequate initial capital as required under the UK Payment Services Regulations. (Specific pricing not included as per your request.)

Timelines vary based on: – Completeness of documents – Governance strength – FCA processing workload Firms with stronger compliance foundations progress faster.

Common reasons include: – Weak AML frameworks – Insufficient safeguarding – Unclear business model – Incomplete documentation – Lack of experienced management

Yes. Both SPI and API firms must comply with UK Money Laundering Regulations and maintain effective AML/CTF systems, monitoring, and controls.

A remittance management system strengthens licensing applications by standardizing KYC, AML monitoring, reporting, audit trails, and safeguarding workflows — all critical for FCA approval and ongoing supervision.

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