Become an Agent
Registering as an appointed representative or agent under an authorised payment institution or EMI licence.
Speak to a licensing expertSpeak to a licensing expert
Tell us the business, the markets and your timing. Every enquiry is answered the same business day, with a written proposal: the licence, the requirements, the cost and the timeline.
Your enquiry
What we do
Many payment institutions and electronic money institutions distribute their services through networks of agents. The agent model allows firms to extend their reach without requiring each distribution point to hold its own regulatory authorisation.
However, appointing agents requires careful regulatory process: agents must be registered with the FCA and other regulators, and the principal firm remains fully responsible for the agent's compliance.
We help both principal firms seeking to build agent networks and businesses seeking to become agents of regulated firms. Our service covers the entire agent registration process and ongoing oversight arrangements.
Suitability Assessment
We assess the suitability of the agent arrangement and regulatory requirements.
Due Diligence
We conduct regulatory due diligence on prospective agents.
Registration & Agreements
We prepare and submit agent registrations and draft agent agreements.
Oversight Framework
We establish ongoing agent monitoring and oversight frameworks.
What's Included
Agent Registration Application
Complete application for agent registration with the relevant regulator.
Due Diligence Report
Regulatory due diligence assessment of the prospective agent.
Agent Agreement
Comprehensive agreement covering regulatory obligations and responsibilities.
Oversight Framework
Ongoing monitoring and compliance oversight arrangements for agents.
Training Materials
Regulatory training programme for agents covering compliance obligations.
Passporting Notifications
Cross-border agent registration through EU passporting procedures.
Who this service is for
Firm types
- - Payment institutions building agent networks
- - EMIs seeking distribution partners
- - Businesses wanting to offer payment services as agents
- - Firms with existing agent networks needing compliance support
Situations & Triggers
- - Launching an agent distribution model
- - Expanding agent networks into new markets
- - Responding to regulatory findings on agent oversight
- - Restructuring existing agent arrangements
Why firms choose Regulatory Counsel
200+ licence and registration engagements
Applications taken through regulators in the United States, the United Kingdom, Europe, Canada, Australia, the Middle East and Asia.
Senior-led
The same senior practitioners run your engagement from the first assessment to the last regulator question.
Every regulated sector
Payment, e-money, money transmission, crypto, banking, lending, insurance, mortgage and investment firms.
In writing, the same day
Every enquiry is answered the same business day, and scope, timeline and fees are set out in writing before work begins.
Ready to get started?
Every enquiry is answered the same business day, with a written proposal.
Speak to a licensing expertFrequently asked questions
An agent is a person or business that provides payment services on behalf of an authorised payment institution or EMI under the principal firm's authorisation.
No. Agents operate under the principal firm's authorisation and do not need their own licence, but they must be registered with the regulator.
The principal firm is fully responsible for the agent's compliance, including ensuring fit and proper standards, implementing adequate AML controls, and maintaining ongoing oversight.
FCA agent registration typically takes 2 to 3 months, depending on the complexity of the arrangement and submission quality.
EU-authorised firms can register agents in other EEA member states through the passporting process, involving notification to both home and host state regulators.
Principal firms must conduct regular oversight including compliance monitoring visits, transaction monitoring, complaint handling review, and annual fitness assessments.
This depends on the regulatory framework and the terms of each agent agreement. Some jurisdictions permit multi-principal arrangements subject to appropriate controls.
The principal firm bears regulatory responsibility for agent breaches. This can result in enforcement action against the principal, reinforcing the importance of robust agent oversight.