Regulatory and Compliance Advisory
Businesses in the Payments sector are operating in a market where growth, innovation and regulation move quickly.
Whether you are building a payments platform, issuing e-money, scaling an Open Banking proposition, expanding internationally or preparing for investment, the regulatory pressure can shape how fast and confidently you move.
For many firms, the challenge is not simply “being compliant”. It is knowing what the Regulator expects, demonstrating that your controls work in practice and making sure your regulatory frameworks enable your commercial plans rather than slowing them down.
Getting authorised, registered or ready to launch
Payment firms (including payment service providers, e-money institutions and Open Banking providers often need clarity on permissions, safeguarding, financial and non-financial resources, governance, systems and controls before they can move forward.
A weak application, unclear business model or incomplete documentation can attract challenge from the FCA, delay launch plans and affect investor confidence.
Scaling without creating regulatory gaps
As your business grows, new products, new jurisdictions, agent or distributor models, technology partners, acquisitions and senior management changes can all affect your regulatory position.
What worked at launch may no longer be enough once transaction volumes, customer numbers and risk exposure increase.
Managing safeguarding, resilience and ongoing FCA expectations
Payments and e-money firms face increasing scrutiny around safeguarding customer funds, CASS 15 implementation, regulatory reporting, operational resilience, Consumer Duty and financial crime controls.
For lean teams, keeping policies, board reporting, reconciliations, governance and evidence up to date can be difficult while also focussing on running the business.
Typical challenges we see in the sector
Common pressure points include unclear permissions, incomplete safeguarding arrangements, insufficient operational resilience frameworks, underdeveloped wind-down planning, weak compliance monitoring, limited management information, poor audit readiness and insufficient evidence that systems and controls are operating effectively.
Regulation should be an enabler of a good business, not something that holds it back. Our role is to help firms understand what is expected, prepare properly and move forward with clarity, confidence and proportionate support.
Ben Arram
Partner, Head of Regulatory Advisory
Our approach
Our regulatory advisory approach is built around the realities of payment services, e-money, Open Banking and other regulated financial services businesses.
We start by understanding your business model, customer journey, permissions, growth plans, governance and operational risks, along with your shorter and longer-term aspirations. We then focus on what needs to be done to help you meet your objectives in a cost-effective, efficient and proportionate manner.
We help you identify where regulatory expectations touch the commercial decisions you are making, from launch and authorisation through to safeguarding, operational resilience, acquisitions, new products, transaction growth and preparation for external scrutiny.
Our support includes FCA authorisation and registration applications, payment services and e-money permissions, Open Banking regulatory advice, change in control notifications, safeguarding and CASS 15 readiness, compliance framework reviews, policy and procedure updates, compliance monitoring programmes, board reporting, regulatory projects, training and FCA engagement.
Common mistakes that can hold firms back
Firms often run into difficulty when regulatory work is treated as a one-off task rather than part of the growth journey.
Typical mistakes include leaving safeguarding readiness until too late, relying on generic policies, failing to evidence control testing, underestimating FCA questions, not aligning compliance with the business model, and overlooking how transactions or investment activity may affect regulatory permissions.
Risks to value
Regulatory weaknesses can affect more than day-to-day compliance.
They can delay product launches, slow investment or acquisition activity, increase audit pressure, create remediation costs, weaken board confidence and reduce the value of a business during due diligence.
Why work with us
Sector-specific regulatory advisory
You work with specialists who understand payment services, e-money, Open Banking and the practical expectations placed on regulated firms.
A real differentiator
Regulatory and compliance advisory is embedded into our wider financial services support, giving you advice that connects regulation, audit, tax, transactions and growth.
Commercially practical support
We focus on what your business is trying to achieve, helping you make proportionate decisions that stand up to scrutiny.
Support across the journey
We can help at launch, through growth, during transactions and when regulatory change creates new pressure points.
We can provide this support on a one-off, ad-hoc or recurring basis.
Our tailored support options are flexible and can adapt and scale as your business grows and evolves over time.
Outcomes clients value
Our work helps clients move forward with clearer permissions, stronger governance, better safeguarding evidence, more confident board oversight, fewer surprises in audits or due diligence and a more credible position when engaging with the FCA, investors or buyers.
Services covered
Regulatory applications and change in control
- Registration and authorisation applications for payment services and electronic money firms
- Variation of permission and regulatory profile advice
- Change in control notifications and regulatory due diligence
- Application packs, regulatory business plans, key individual and qualifying holding forms and supporting documentation
- Preparation for regulator interviews, assessments and follow-up queries
Regulatory projects
- Regulatory change projects, including CASS 15 safeguarding rules
- Operational resilience frameworks, including SYSC and DORA support
- Consumer Duty framework development and implementation
- Support with regulatory enquiries, interventions and notifiable events
- Internal audit support for second-line control functions
Ongoing compliance support
- Day-to-day regulatory advice and guidance
- Compliance monitoring programmes
- Regulatory reporting support
- Policy and procedure reviews
- Board reporting and staff training
- Support with regulator engagement and business change notifications
Payrnet Limited t/a Railsr
Challenge
Payrnet Limited t/a Railsr needed audit support for a complex engagement involving significant challenges and a high level of coordination. The client needed a team that could respond quickly, manage requests clearly and work collaboratively throughout the process.
What we did
We worked closely with the client to deliver the audit as professionally, efficiently and completely as possible. The team used Inflo to make requests clear and structured, helping the client manage the information process while maintaining a collaborative approach to resolving issues as they arose.
Outcome
The client valued BKL’s agile, knowledgeable and collaborative approach, particularly the clarity of requests through Inflo and the way the team worked with them to manage a difficult audit effectively.
Client testimonial
“We have been really impressed with the agile, quick and knowledgeable BKL team. They have done really well working on a difficult audit as professionally, efficiently and completely as possible. They have taken the challenges in their stride and worked collaboratively to solve them. Two things really stand out: the clear requests through Inflo and the use of this technology; and the collaborative approach on the audit.”
Pixxles Limited
Challenge
Pixxles Limited needed support from incorporation through FCA application and beyond, with ongoing regulatory and audit-related questions as the business developed. This included areas such as regulatory capital, complex cross-border transactions and improvements to systems and processes.
What we did
We have supported the business from incorporation in 2018, assisting with its FCA application and providing ongoing advice after the licence was granted. The team remained available to help with technical queries, regulatory considerations and practical recommendations to strengthen the client’s systems.
Outcome
The client valued BKL’s pragmatic solutions to complex issues and the continuity of support provided throughout its growth journey. Pixxles described the team as excellent to work with and highlighted the value of having advisers on hand when needed.
Client testimonial
“We have worked with BKL since our company incorporated in 2018 and they have been with us every step of the way. They assisted with our application to the FCA and have provided invaluable ongoing support since our licence was granted. From assisting us with queries on regulatory capital, complex cross-border transactions and recommendations to improve our systems, they have always been on hand to support us where needed. We have been impressed with their pragmatic solutions to complex issues when conducting our audits and are an excellent team to work with.”
Talk to BKL
If you are building, scaling, acquiring or operating a payment services, e-money, Open Banking or other regulated financial services business, regulatory uncertainty can slow progress and constrain value.
We help you understand what the FCA expects, strengthen the evidence behind your compliance framework and connect regulatory work to your wider commercial objectives.
Speak to Ben for a practical conversation about where you are now, what may be creating risk and how to move forward with greater confidence.
Contact Ben
Frequently Asked Questions: Regulatory and Compliance Advisory
Who is regulatory advisory for?
It is for payment institutions, e-money institutions, Open Banking providers and other financial services firms that need practical support with FCA authorisation, permissions, safeguarding, compliance frameworks, regulatory change or business growth.
Can you help us apply for FCA authorisation or registration?
Yes. We can help you assess the permissions you need, prepare the application pack, develop supporting documentation and prepare for regulator questions or interviews.
Can you help us apply for regulatory authorisation or registration in the EU?
Yes. We can also support you with preparing, submitting and managing your EU application for regulatory authorisation or registration.
Can you support a change in control process?
Yes. We can support regulatory due diligence, help prepare the notification pack and advise on the regulatory implications of acquiring or restructuring a regulated business.
Do you provide ongoing compliance support?
Yes. We can provide ad-hoc advice or recurring support, including compliance monitoring programmes, regulatory reporting, policy reviews, board reporting, training and regulator engagement.
Can you help with CASS 15 safeguarding requirements?
Yes. We can support firms preparing for safeguarding audits, reviewing gaps, planning remediation and engaging with auditors where appropriate.
What are the main regulatory challenges for payment services and e-money firms?
Common challenges include FCA authorisation, safeguarding customer funds, CASS 15 readiness, regulatory reporting, operational resilience, financial crime controls, governance, Consumer Duty and keeping compliance frameworks up to date as the business grows.
How can regulatory weaknesses affect a transaction or investment process?
Weak governance, unclear permissions, poor safeguarding evidence or incomplete compliance documentation can create due diligence issues, delay deals, reduce confidence and increase the risk of remediation before completion.
When should we seek regulatory advice?
It is worth seeking advice before you submit an FCA application, launch a new product, change your business model, appoint agents or distributors, acquire or sell a regulated business, prepare for audit or respond to new regulatory requirements.
Can you help Open Banking businesses?
Yes. We support firms involved in payment initiation services, account information services and wider Open Banking models, helping them understand regulatory requirements, permissions, governance, controls and the implications of regulatory change.
