Money Transfer Agent Licence in the UK: Do You Need Your Own?

Who this is for

Two different people search for a “money transfer agent licence”. A shop owner or sole trader who wants to offer remittances over the counter for a brand they trust. And a founder who is deciding whether to become an agent of an existing operator or to apply for their own FCA registration. The regulatory answer is the same for both, so both are covered here. This is educational, not regulatory advice. Every point is sourced to the FCA Handbook, the FCA’s Approach Document (May 2026, version 8), or HMRC’s published guidance, with the reference given so you can check it.

1. The short answer: agents are registered, not licensed

The FCA’s perimeter guidance puts it directly. Asked “We only wish to be an agent. Do we need to apply to the FCA and/or PRA for registration?”, the Handbook answers: “No. If your principal is a payment institution, it is its responsibility to register you as its agent. You are required to be registered on the Financial Services Register before you provide payment services.” (PERG 15.4, Q28)

The limits are in the same answer. “An agent can only provide its principal’s payment services; the agent cannot provide or purport to provide the services in its own right.” Holding yourself out as a payment service provider when you are not one is an offence under regulation 139 of the PSRs 2017, and “it must be clear to a customer that the agent is acting on behalf of the principal”.

The principal carries the responsibility. Regulation 36(2) makes payment institutions “responsible for anything done or omitted by an agent”, to the same extent as if they had expressly permitted it (Approach Document, 5.3). That is why the principal, not the agent, does the registering, and why a serious principal will ask you for more than a signature.

2. Agent or your own licence: the two routes side by side

Fees are quoted as the regulators publish them today, with the page date, and change each year.

The pattern is clear. Being an agent is cheap and fast to enter, and everything you do belongs to someone else’s permission. Your own registration costs more up front and brings the obligations with it. If you are weighing the second route, the UK launch guide walks through the application.

3. How to become a money transfer agent

There is no form for you to file. The route is an agency agreement with a principal that is already on the Financial Services Register, followed by the principal’s application to add you. Check the principal first: the Register shows every authorised and small payment institution and their agents, and you should not accept remittance transactions for a firm that is not on it.

Expect the principal to ask for the following, because the FCA requires it to submit or certify each item (Approach Document 5.12, 5.18 to 5.25):

• Your name and address, trading names, and your Companies House number if incorporated.
• The identity of your directors and the people who manage the business. For incorporated agents that is the board; for unincorporated agents the partners or sole trader, plus anyone with day-to-day management responsibility. The FCA takes name, National Insurance number, and date and place of birth for each.
• Evidence that those people are fit and proper. The principal must make its own “due and diligent” enquiry into honesty, integrity and reputation, and competence and capability, and certify the result. HMRC expects a DBS basic check and right-to-work checks, with your consent; if you refuse consent, HMRC expects the principal not to use you (AMLG2400).
• A description of the anti-money-laundering controls you will operate, which in practice means the principal’s policies applied at your counter.
• The payment services you are appointed for.

Then you wait. You cannot provide payment services “until the agent is included on the Register” (Approach Document 5.31). Once live, you will be trained at onboarding and at intervals after that, you will refer the transactions the principal’s procedures say to refer, and suspicious activity goes to the principal’s nominated officer, who reports to the National Crime Agency. HMRC’s previous MSB guidance put the training interval at least every two years or on significant change; the current AMLG manual says “at appropriate intervals”.

4. How a principal registers an agent

For operators, this is the sequence the FCA and HMRC describe.

Before the first agent. If you told the FCA at authorisation that you would use agents, submit the agent application through Connect. If you did not, the FCA’s applicant page (updated 16 June 2026) says you must first notify under SUP 15 and receive confirmation that it has no material concerns with your oversight framework, or apply to vary your permission if your authorisation restricts agent onboarding.

The application. One Connect form serves agents of authorised and small payment institutions alike (Approach Document 5.11). Regulation 34 requires the agent’s name and address; the internal control mechanisms the agent will use to comply with the Money Laundering Regulations 2017; the identity of its directors and managers and, where the agent is not itself a payment service provider, evidence they are fit and proper; the services the agent is appointed for; and the agent’s identification codes (Firm Reference Number, Companies House number or National Insurance numbers, and LEI if it has one). The controls description “only needs to be supplied once” if you apply the same controls to every agent (5.16).

Timing and cost. The FCA “must make a decision on applications to register an agent within two months of receiving a complete application” (5.28) and updates the Register “usually within one business day” of approval (5.30). An agent application combined with your own authorisation application follows that application’s timetable (5.29). There is no FCA fee: the £3 per-agent charge in FEES 3 Annex 8R was deleted with effect from 1 April 2026 by the Application, Periodic and Other Fees (2026/2027) Instrument, after the FCA consulted in CP25/33 and received no objections. One widely read consultancy page states a “60 working days” period; the FCA’s own text says two months.

Refusal grounds are narrow. The FCA may refuse only where information is missing, where it is not satisfied the agent’s management are fit and proper, or where it has reasonable grounds to suspect money laundering or terrorist financing in connection with the agent (5.32).

HMRC, in parallel. Your HMRC money laundering registration must list every agent premises; HMRC’s registration page says “both branches and agents of a business must be listed as part of that business’s registration”, and its current manual charges “a registration fee for each premises… (including agents’ premises and branches)”, £400 each as published from 1 December 2025. HMRC “does not normally conduct fit and proper test on the agents of MSBs” and “agents do not apply to HMRC for the fit and proper test”; you must be satisfied they would pass it, and allowing an agent to trade without that assessment is grounds for HMRC to suspend or cancel your registration (AMLG1600). Report changes to your agent network within 30 days (AMLG1500). The FCA expects the same: make sure “any agent submissions made to us have been included in the list of premises notified to HMRC” (5.37).

After approval. You own the oversight. Regulation 19(4) of the Money Laundering Regulations requires specific measures in your written policies for agent-network risk (AMLG2400, 7). The FCA expects you to satisfy yourself that each agent’s controls “remain appropriate throughout the agency relationship” (5.17), to tell it “without undue delay” about changes to an agent’s fitness and propriety (5.27), and to remove an agent through Connect when you stop dealing with it (5.34). HMRC lists agents sharing log-in details, acting for multiple principals, and self-sending as additional risk factors (AMLG11210). Your bank will ask about this too: JMLSG tells banks that an MSB operating through an agent network “presents a different risk profile” and to understand how it confirms agent compliance (Part II, 1A.19).

5. Three arrangements that are not agency

• An independent franchisee. Where the franchise agreement makes the franchisee independent and not acting on the franchisor’s behalf, it is not an agent and “must register with HMRC in its own right”, and a principal must not use a franchise agreement to disguise what is in practice an agency (HMRC MSB guidance, 9.38 to 9.39).
• A technical service provider. Software that supports a payment service without the provider ever possessing the funds is not an agent (Approach Document 5.10). That is where Remitz’s remittance software sits.
• A distributor. An e-money concept only: distributors load and redeem e-money for an EMI, cannot provide payment services, and are not registered (5.4 to 5.5, 2.52).

“Sub-agent” is not an FCA term; every agent is registered against a principal. HMRC does recognise chains, and expects a principal to hold “an up-to-date record of any agents that are appointed through their agents”.

6. What the software has to evidence

Everything above produces a paper trail that a supervisor, an auditor or a bank can ask to see: the agent register with its Connect references, the fit and proper file for each agent’s managers, agreements, training records, per-agent limits and the referrals those limits trigger, and the suspicious-activity reports that reached the nominated officer. Agent management software is where that evidence lives day to day. The agent-based money transfer page describes how Remitz handles agent and branch workflows, and the agent network guide covers hierarchy, commission and settlement design. Remitz supplies the software; the registrations, the oversight and the accountability stay with the principal.

Sources

• FCA Handbook, PERG 15.4 “Small payment institutions, agents and exempt bodies”, Q26 to Q30 (page dated 1 January 2021).
• FCA, Payment Services and Electronic Money: Our Approach, version 8, May 2026, chapter 5 “Appointment of agents and use of distributors” and paragraphs 2.24, 3.7, 3.47, 3.95, 19.13.
• FCA, “Payment institution applicants” (updated 16 June 2026), Registering agents section.
• FCA Handbook, FEES 3 Annex 8R (1 April 2026) and FEES 3 Annex 1AR (2 July 2026); CP25/33 (November 2025); Handbook Notice 139 (March 2026); instrument FCA 2026/11.
• FCA PS25/12, Changes to the safeguarding regime for payments and e-money firms (7 August 2025).
• HMRC, Anti-money laundering guidance for supervised businesses (AMLG), first published 8 July 2026: AMLG1500, AMLG1600, AMLG2400, AMLG11030, AMLG11210.
• gov.uk, “Who needs to register for money laundering supervision” (23 August 2023); “The fit and proper test” (12 February 2026); “Fees you’ll pay for money laundering supervision” (22 December 2025).
• HMRC, Money service business guidance for money laundering supervision (effective 1 October 2025), sections 8 and 9, cited as previous guidance.
• JMLSG Guidance Part II, Sector 1A (June 2023, updated December 2025).