Electronic Money Institutions continue to gain ground in the UK financial services sector. With a more focused regulatory perimeter than a full banking licence, the EMI route has become a preferred choice for many fintechs offering payments, stored value accounts, and embedded finance services.

As more firms pursue FCA authorisation, a consistent challenge emerges. Hiring the right compliance professionals, particularly early in a firm’s lifecycle, is more difficult than it appears. At the same time, the regulator’s expectations around governance, oversight, and operational substance are increasing.

For businesses preparing for authorisation or in the early stages of mobilisation, compliance recruitment is no longer a procedural task. It is central to building a credible and scalable platform. Whether hiring a Head of Compliance, appointing SMF16 or SMF17 functions, or working to build out an internal control environment, the stakes are high. A strong appointment not only improves regulatory confidence, it also helps lay the foundations for growth.

Leadership teams in early-stage businesses often operate with lean structures. There is sometimes a reluctance to hire senior roles before revenue builds. However, in the case of EMIs, the FCA expects key appointments to be in place before granting approval. This includes individuals with sufficient experience, board access, and the ability to provide independent challenge.

This makes the hiring strategy critical. Many searches focus heavily on prior EMI or payments experience. While helpful, sector background is only one part of the equation. Communication skills, operational judgment, and the ability to build suitable frameworks matter just as much. Strong candidates may come from other parts of financial services, including asset management, wealth, or operations-focused roles within regulated firms. What matters most is their ability to deliver compliance oversight within a regulatory environment shaped by PSD2 and the Electronic Money Regulations.

It is also worth considering whether the Head of Compliance will operate as a standalone figure or have access to third-party consultants. The level of support will influence the type of candidate required. If the role includes SMF responsibilities, firms must be prepared to reflect that in their hiring budget. These roles carry significant responsibility and should be resourced accordingly.

Fram has worked extensively with buy-side firms, particularly asset managers and private wealth firms. Increasingly, we are supporting early-stage fintechs and specialist financial services firms preparing for or adapting to FCA authorisation. These searches require a thoughtful approach. We are familiar with the demands of building lean but effective governance functions, and with the operational pressures that new licence holders face.

Becoming an EMI is a strategic step. It opens up commercial opportunity, but also comes with greater expectations. Compliance cannot be viewed as a back-office function. It needs to be embedded across the firm, with clear leadership and proper investment. Hiring the right people at the right time is essential.

If you are navigating compliance recruitment for an EMI in the UK, or preparing your business for authorisation, we are happy to share insight and support your hiring plans in confidence.