Industry Guide

Section 250 Compliance for Payment Institutions

Authorised payment institutions and e-money institutions regulated by the FCA have a distinct Section 250 profile. Many payment firms have lean leadership teams where the CEO, COO, and CFO carry enormous financial authority — and often are not SMF-approved in the same way as a bank. Section 250 captures these individuals directly.

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TL;DR

Payment Institutions face Section 250 obligations under the Crime and Policing Act 2026. Authorised payment institutions and e-money institutions regulated by the FCA have a distinct Section 250 profile. Many payment firms have lean leadership teams where the CEO, COO, and CFO carry enormous financial authority — and often are not SMF-approved in the same way as a bank. Section 250 captures these individuals directly. Typical Section 250 gap: Uncovered executives in a typical payment institution. Key roles in scope: COO / CFO without SMF, MLRO, Head of Payments Operations. Deadline: June 29, 2026. CoverProof automates the SM&CR gap analysis, declarations, and litigation-grade evidence pack generation for payment services firms.

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Uncovered executives in a typical payment institution

The typical Section 250 gap for a payment services firm — individuals with significant financial authority who are not SM&CR-approved and need declarations before June 29, 2026.

Payment institutions face a specific Section 250 exposure profile

C-suite without formal SMF designations

Payment fintechs often grew rapidly and formalised SM&CR compliance after the fact. It is common for COOs, CTOs, and CFOs to have significant financial authority without holding the corresponding SMF. Section 250 reaches these roles.

Money Laundering Reporting Officer (MLRO) obligations

The MLRO at a payment institution sits at the intersection of AML obligations and Section 250 scope. Ensuring the MLRO holds the correct designation and has completed the Section 250 declaration is an urgent compliance step.

Roles typically in scope for payment services firms

  • ⚑COO / CFO without SMF
  • ⚑MLRO
  • ⚑Head of Payments Operations
  • ⚑Technical directors with financial authority

Common questions from payment services compliance teams

We are a small EMI with 15 staff. Are we in scope for Section 250?

Yes, if you are FCA-authorised. All FCA-authorised firms — regardless of size — have Section 250 obligations for individuals in significant roles who are not already SM&CR approved. CoverProof's Essentials plan (£149/month) is designed for small, fast-moving firms.

Fast-moving payment firms need a fast compliance path.

CoverProof's zero-login declaration system means you can send Section 250 declarations to every uncovered individual in minutes. No account required for recipients. Evidence pack downloads instantly.

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