EMI Licence Reference Numbers: What They Mean and How to Verify

TL;DR: Verification Take

A Firm Reference Number (FRN) is a unique identifier assigned by the Financial Conduct Authority (FCA) to authorised e-money institutions (EMIs) in the United Kingdom. Equivalent identifiers exist across European regulators: the Bank of Lithuania (LB) uses registration numbers, the Dutch Authority for the Financial Markets (AFM) uses firm numbers, and the European Banking Authority (EBA) maintains EUCLID - a centralised register. Always verify the reference number against the official national competent authority (NCA) register before trusting claims of authorisation. Fake reference numbers are a common fraud tactic; matching the number to the exact entity name is your first line of defence.

What Is a Firm Reference Number?

The Firm Reference Number (FRN) is a seven-digit identifier issued by the FCA to regulated financial services firms, including EMIs. It appears on the FCA Financial Services Register and serves as proof of authorisation. Each FRN maps to exactly one legal entity and cannot be reused or transferred. The FRN is distinct from the firm's company registration number (Companies House) and must be cited in all regulatory correspondence.

The FCA authorised approximately 287 EMIs as of Q1 2025, each holding a unique FRN. This number has grown steadily since the Electronic Money Directive (EMD2, Directive 2009/110/EC) transposition deadline on 30 April 2011, which harmonised EMI regulation across the European Union (EU).

Equivalent Identifiers Across Europe

Not all European regulators use the term "Firm Reference Number." Each national competent authority (NCA) maintains its own naming convention and register format:

| Regulator | Country | Identifier Name | Register Name | Primary Source | |-----------|---------|-----------------|---------------|----------------| | FCA | United Kingdom | Firm Reference Number (FRN) | Financial Services Register | fca.org.uk/register | | Bank of Lithuania (LB) | Lithuania | Registration Number | EUCLID | euclid.eba.europa.eu | | Dutch AFM | Netherlands | Firm Number | AFM Register | afm.nl/register | | BaFin | Germany | Registration Number | BaFin Register | bafin.de | | CNMV | Spain | Registration Number | CNMV Registry | cnmv.es |

The European Banking Authority (EBA) operates EUCLID - a centralised database of all authorised EMIs, payment institutions (PIs), and account information service providers (AISPs) across the EU, European Economic Area (EEA), and certain third countries. EUCLID contains approximately 2,847 EMI records as of Q1 2025 and is freely searchable by entity name, registration number, or country.

How to Verify a Licence Reference Number

Step 1: Identify the Regulator

Determine which country the EMI claims to be regulated in. This dictates which register to consult. A UK-regulated firm must hold an FRN and appear on the FCA Financial Services Register. A Lithuanian firm must appear in EUCLID under the Bank of Lithuania's supervision.

Step 2: Access the Official Register

Navigate directly to the official register - do not use links provided by the firm under scrutiny. For UK firms, visit fca.org.uk/register. For EU/EEA firms, visit euclid.eba.europa.eu. Bookmark these URLs to avoid phishing redirects.

Step 3: Search by Reference Number or Entity Name

Enter the claimed reference number or the firm's legal entity name (as it appears in official documents, not trading names). Most registers support both search methods. The FCA register requires exact or partial name matching; EUCLID supports wildcard searches.

Step 4: Verify the Entity Name Matches Exactly

Confirm that the search result shows the exact legal entity name provided by the firm. Scammers often register similar-sounding names (e.g., "PaymentsHub Ltd" vs. "Payment Hub Ltd") to exploit confusion. The register must show the same registered address, authorisation date, and scope of permitted activities.

Step 5: Check the Authorisation Status and Scope

Verify that the status field reads "Authorised" or equivalent (not "Suspended," "Cancelled," or "Pending"). Confirm the firm is authorised to conduct the activities it claims - for example, issuing e-money or operating a payment system. The FCA register lists permitted activities under "What the firm is authorised to do."

Step 6: Cross-Reference Contact Details

Compare the registered address and contact information shown in the register against what the firm provides. Legitimate firms publish their FRN or equivalent on their website and official communications. Mismatches suggest fraud or outdated information.

Red Flags and Warning Signs

Spot fake or misused reference numbers by watching for these indicators:

• The reference number does not appear in the official register despite multiple searches.
• The firm claims authorisation but the register shows "Suspended" or "Cancelled" status.
• The entity name in the register differs materially from the trading name used in marketing materials.
• The firm provides a reference number but refuses to disclose which regulator issued it.
• The register shows a different regulated activity scope than the firm claims (e.g., the firm claims to issue e-money but the register lists only payment initiation services).
• The firm's website URL or email domain differs from the registered address shown in the official register.
• The reference number format does not match the expected pattern for the claimed regulator (e.g., a seven-digit FRN claimed for a Netherlands-regulated firm, which should use a different format).
• The firm provides a screenshot of a register entry instead of directing the customer to the live register.

What This Article Does Not Cover

This post focuses exclusively on verifying licence reference numbers and authorisation status. It does not address:

• Anti-money laundering (AML) and counter-terrorist financing (CFT) obligations under the Fourth or Fifth Anti-Money Laundering Directives.
• Prudential capital and liquidity requirements under the Capital Requirements Regulation (CRR) or Capital Requirements Directive (CRD).
• Crypto-asset regulation under the Markets in Crypto-Assets Regulation (MiCAR).
• Deposit guarantee schemes or investor compensation arrangements.
• Ongoing compliance monitoring or enforcement actions (beyond public register status).
• Payment Services Directive 2 (PSD2) or Open Banking rules, which govern payment services but not e-money issuance per se.

For questions about these topics, consult the relevant NCA directly or seek legal advice.

Frequently asked questions

Q: What is the difference between an FRN and a company registration number?

An FRN is issued by the FCA to regulated financial services firms and appears only on the FCA Financial Services Register. A company registration number is issued by Companies House to all UK companies and appears on the Companies House register. A single firm may hold both numbers, but they serve different purposes and cannot be used interchangeably.

Q: Can an EMI hold multiple Firm Reference Numbers?

No. Each legal entity holds exactly one FRN. If a firm operates under multiple trading names or in multiple jurisdictions, it must hold separate FRNs in each country where it is regulated. A single FRN cannot be transferred or reused.

Q: Is EUCLID the only register for EU/EEA EMIs?

EUCLID is the centralised register maintained by the European Banking Authority (EBA), but each national competent authority (NCA) also maintains its own national register. EUCLID aggregates data from all NCAs, so searching EUCLID is the fastest way to verify an EU/EEA EMI. However, the NCA's national register may contain additional details not shown in EUCLID.

Q: How often is the FCA Financial Services Register updated?

The FCA updates the Financial Services Register in near real-time when authorisations are granted, suspended, or cancelled. However, there may be a delay of 1-2 business days between a regulatory decision and its appearance on the public register. If a firm claims recent authorisation but does not yet appear, contact the FCA directly to confirm.

Q: What should I do if I find a fake reference number?

If an entity claims authorisation using a fake or misused reference number, report it to the FCA (in the UK) or the relevant NCA in the firm's claimed jurisdiction. Provide the false reference number, the firm's website, and any communications in which the false claim was made. The FCA's report page is located at fca.org.uk/scamsmart. You may also report to local law enforcement and your financial regulator if the firm attempted to defraud you.