Finance in a Payments or E-Money Firm: What Changes

Finance in an authorised payments or e-money firm looks familiar from the outside and works differently in almost every respect that matters. Money flows through the business that does not belong to it, settlement happens on scheme timetables rather than commercial ones, and a reconciliation that would be a monthly control elsewhere is a daily regulatory obligation. This guide sets out what the Financial Controller actually owns in these firms, where the difficulty concentrates, and what the sector pays in 2026. For the hiring question specifically, see our guide to testing safeguarding experience.

The first question: what is the firm authorised as?

Everything follows from this and it is regularly assumed rather than established. An authorised payment institution or electronic money institution holds relevant funds and must safeguard them. A small payment institution may not. An agent or distributor of a principal firm does not safeguard at all — the principal does.

That last category matters more than it sounds, because a large share of businesses describing themselves as fintechs operate as agents. Their finance people have genuinely never safeguarded anything, which is the single most common mismatch in hiring for this sector. The FCA’s payment services and e-money pages set out the permissions, and our guide to e-money and payments regulation covers the framework.

Safeguarding: the defining obligation

Where the firm holds relevant funds, it must safeguard them — either by segregating them in a designated account with an authorised credit institution, or through an insurance or guarantee arrangement. Some firms use both across different products.

What that means for finance day to day: a daily reconciliation of safeguarded funds against the firm’s obligation to customers, with any shortfall made good; evidence that the reconciliation was performed and reviewed; acknowledgement arrangements with the safeguarding institution; and a clear scoping position on what counts as relevant funds — when they become relevant, when they cease to be, and how fees and own funds are kept out.

The discipline is closer to client money than to treasury, and our guide to safeguarding for payments and e-money firms covers the mechanics. It is also audited separately, with findings of its own.

Scheme settlement and the flow of money

The second sector-specific area, and the one that makes the reconciliation genuinely difficult rather than merely daily.

Money moves through acquirers, schemes, correspondent banks and partner institutions on timetables the firm does not control. At any moment a meaningful balance is in flight — authorised but not settled, settled but not allocated, or in a scheme’s hands over a weekend. The safeguarding calculation has to account for all of it correctly, and the timing differences are where errors accumulate.

Add chargebacks and refunds, which reverse flows after the fact, FX where the firm operates across currencies, and interchange and scheme fees, which affect both revenue recognition and the customer obligation. Getting the whole picture reconciled daily is a real operational discipline and it is the part of the job an FC from a commercial background most under-estimates.

Capital, reporting and the rest

Own funds requirements. Payment institutions and EMIs are subject to initial capital and ongoing own funds requirements calculated by prescribed methods — different from the MIFIDPRU regime that applies to investment firms, and worth being precise about in a job specification.

Regulatory reporting on the FCA’s calendar, with submission dates that do not move for a difficult month.

Wind-down planning, which supervisors have paid increasing attention to in this sector — and which requires finance to model an orderly exit including the cost of returning customer funds.

And the ordinary FC remit underneath all of it: the close, the balance sheet, statutory accounts, the audit and the team. The prudential and safeguarding work sits on top rather than instead, which is why these roles are heavier than the equivalent commercial seat.

Where firms struggle

Manual daily reconciliation. Built in spreadsheets, understood by one person, and increasingly fragile as volumes grow. The commonest issue in the sector by a distance.

Scoping errors at the edges. Fees taken from safeguarded funds before they are earned, own funds commingled in error, or funds treated as relevant later than they should be. Each is recoverable if found quickly and expensive if not.

Growth outpacing the process. A reconciliation that worked at a thousand transactions a day does not at fifty thousand, and firms scale volume faster than they scale finance.

And key-person concentration — one person who understands the safeguarding calculation, with nothing documented. The safeguarding audit will ask what happens when they are on leave.

Payments and fintech finance salaries 2026

Two things move the bands. Genuine safeguarding experience adds 12–18% over an equivalent commercial role and is the scarcest element. Scale and complexity — multi-currency, multiple schemes, an agent or distributor network — adds further. Note that equity frequently forms a meaningful part of the package in venture-backed fintechs, and the leaver provisions matter as much as the allocation. Wider benchmarks are in our regulated-firm finance salary guide and bonus benchmarks.

Hiring for the role

Three points, and the first prevents most mis-hires. State the authorisation in the advert — API, EMI, small payment institution, or agent of a principal — because it determines whether safeguarding applies and reaches a much smaller but far more relevant pool. Ask the ten-second question at screening: was your firm authorised, and did it hold relevant funds? And describe the operational shape: volumes, currencies, schemes, and whether finance performs the reconciliation or reviews an operations team’s.

Qualification — ICAEW, ACCA or CIMA — is the baseline. Adjacent client money experience under CASS transfers reasonably well, since the mindset is the same even where the rules differ; a purely commercial background does not, and our guide to client money regimes covers why. The fintech finance practice covers the search.