PSR & EMR Compliance Services

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Under the Payment Services Regulations 2017 (PSRs) and the Electronic Money Regulations 2011 (EMRs), firms authorised or registered in the UK are subject to a wide range of ongoing regulatory obligations. These requirements go well beyond anti-money laundering, safeguarding, regulatory applications and change-in-control notifications.

The FCA expects firms to demonstrate effective governance, strong operational controls, fair customer outcomes and resilience across their business. This is set out clearly in the FCA’s Approach Document for Payment Services and Electronic Money.

Payment Practice supports firms with the design, implementation and review of PSR and EMR compliance frameworks, helping them meet supervisory expectations in a practical and proportionate way.

PSR and EMR compliance relates to the ongoing obligations placed on payment service providers and electronic money institutions, including authorised payment institutions, small payment institutions, electronic money institutions and account information or payment initiation service providers.

Firms must be able to show that they comply with both the technical requirements of the regulations and the FCA’s broader expectations around consumer protection, operational resilience and market integrity.

Our support focuses on all areas of the FCA Approach Document except anti-money laundering, safeguarding, applications and change-of-circumstances notifications.

Firms must operate in a way that ensures customers are treated fairly, provided with clear and accurate information and protected from avoidable harm.

This includes ensuring that terms and conditions are transparent, fees and charges are clearly disclosed, complaints are handled appropriately and customer communications are fair, clear and not misleading.

These conduct requirements align closely with the FCA’s Consumer Duty and form a core part of how firms are supervised.

The Consumer Duty introduces a higher standard of care for retail customers and applies alongside the PSRs and EMRs.

Firms are expected to demonstrate that they are delivering good outcomes for customers across four key areas: products and services, price and value, consumer understanding and consumer support.

Payment Practice helps firms assess how the Consumer Duty applies to their payment or e-money activities and supports with gap analysis, target market assessments, governance arrangements and ongoing monitoring frameworks.

The FCA expects payment and e-money firms to have governance arrangements that are appropriate for their size, nature and complexity.

This includes clearly defined roles and responsibilities, effective oversight by senior management, robust risk identification and management processes, and internal controls that operate in practice rather than only on paper.

We assist firms with governance frameworks, risk registers, policy reviews, management information design and documentation that supports regulatory scrutiny.

Firms must comply with regulatory reporting obligations under the PSRs and EMRs, including routine regulatory returns and ad-hoc notifications where required.

This includes reporting of operational and security incidents, complaints data and other information the FCA reasonably requires to supervise the firm.

We support firms in designing reporting calendars, internal escalation processes and management information that aligns with FCA expectations and reduces the risk of late or incomplete submissions.

Operational resilience is a key regulatory priority for payment and e-money firms.

Firms are required to identify their important business services, set impact tolerances for disruption, map critical resources and test their ability to remain within tolerance during severe but plausible scenarios.

Payment Practice supports firms with operational resilience frameworks, business service mapping, scenario testing, third-party dependency analysis and board-level reporting aligned with FCA policy.

The FCA expects payment and e-money firms to be able to exit the market in an orderly way without causing harm to customers or the wider financial system.

Wind-down planning should be proportionate but credible and integrated into the firm’s overall risk and financial planning.

We assist firms with wind-down strategies, trigger frameworks, financial stress testing, governance oversight arrangements and supporting documentation suitable for FCA review.

We support payment and e-money firms in two flexible ways, depending on their regulatory needs, maturity and supervisory risk profile.

Many firms choose to engage us to carry out an annual independent compliance audit covering the full spectrum of PSR and EMR obligations outlined above.

These reviews assess governance, conduct of business, Consumer Duty alignment, regulatory reporting, operational resilience and wind-down preparedness against the FCA’s Approach Document and supervisory expectations.

Our audits provide clear findings, practical recommendations and prioritised remediation actions, helping firms demonstrate to the FCA that they are ready, willing and organised on an ongoing basis.

Where firms require deeper support in a specific area, we also undertake standalone compliance projects focused on individual regulatory themes.

This may include Consumer Duty implementation, operational resilience frameworks, wind-down planning, governance redesign or regulatory reporting enhancements.

Targeted projects are scoped to address specific risks, supervisory feedback or upcoming regulatory milestones and are delivered with clear outcomes and implementation support.

We specialise in payments regulation and work with firms across the full lifecycle, from early-stage businesses to established authorised firms.

Our approach is practical, proportionate and aligned with how the FCA supervises firms in reality, not just how the rules read on paper.

We help firms embed compliance into day-to-day operations and prepare for supervisory engagement with confidence.