Payments Firm CFO Recruitment

Payments & E-Money Firm CFO Recruitment for UK PSR/EMR-Authorised Firms

FD Capital places CFOs, Finance Directors, Heads of Treasury, Heads of Reconciliations, and senior finance leadership into UK Authorised Payment Institutions (APIs), Small Payment Institutions (SPIs), Authorised Electronic Money Institutions (AEMIs), Small Electronic Money Institutions (SEMIs), and Registered Account Information Service Providers (RAISPs) operating under the Payment Services Regulations 2017 and the Electronic Money Regulations 2011. Payments and e-money finance leadership sits at the intersection of conventional CFO scope (commercial finance, board reporting, capital structure, treasury, FP&A, fundraising), prudential finance scope (initial capital and ongoing own funds under PSR/EMR Methods A/B/C, ICARA where applicable, capital adequacy reporting), and the operational architecture that distinguishes payments and e-money firms from other regulated financial services — safeguarding compliance, daily reconciliation across scheme settlements, treasury management at high transaction volumes with low margin economics, and the supervisory engagement that the FCA expects from senior finance leadership at firms holding customer funds. Adrian Lawrence FCA, founder of FD Capital and a Fellow of the ICAEW, leads every payments and e-money finance mandate personally given the regulatory profile of these appointments and the consequences of getting senior finance hires wrong in firms holding material customer funds.

The UK payments and e-money market has expanded materially over the past decade, with London established as a global hub for payments fintech, e-money issuance, embedded finance, cross-border payments, and the broader infrastructure of digital financial services. Regulatory expectations have tightened substantively in parallel — the introduction of mandatory APP fraud reimbursement in October 2024, the FCA’s heightened supervisory focus on safeguarding integrity following several high-profile firm failures, and the broader expectation that authorised firms operate with credible senior finance leadership rather than relying on outsourced finance support. The candidate population genuinely capable of leading finance functions at PSR/EMR-authorised firms — combining payments and e-money regulatory familiarity, scheme operations literacy, treasury management capability at scale, and the FCA-facing credibility that supervisory engagement requires — is observably scarce in the current UK market.

Call 020 3287 9501 or email recruitment@fdcapital.co.uk. Shortlists typically delivered within seven to ten working days for senior payments and e-money finance mandates.

Why Payments & E-Money CFO Recruitment Requires Specialist Sector Experience

Finance leadership at PSR/EMR-authorised firms differs materially from conventional CFO appointments and from finance leadership at other categories of regulated firm. The single most distinctive feature is safeguarding — the regulatory requirement that customer funds (received for payment services or held against issued e-money) be segregated, protected, and demonstrably available for return to customers in the event of firm failure. Safeguarding under PSR Regulation 23 and EMR Regulation 20 imposes daily reconciliation obligations, restrictions on commingling, requirements around safeguarding accounts at credit institutions or insurance, and the operational architecture to evidence compliance at any point. The CFO carries personal accountability for safeguarding integrity in most authorised firms — typically through SMF designation — and the consequences of failure are severe, with multiple firm authorisations cancelled by the FCA over recent years specifically for safeguarding failures.

Capital adequacy under PSR/EMR follows a distinctive framework that differs from CRR/CRD (banks), Solvency II (insurers), and IFPR (investment firms). Initial capital requirements vary by firm type and service portfolio — €350,000 for AEMIs, €125,000 for APIs offering payment services 1-7, lower amounts for SPIs and SEMIs. Ongoing own funds requirements operate on three alternative methods: Method A (10% of fixed overheads), Method B (a percentage of payment volume on a sliding scale), and Method C (a percentage of relevant indicators). The choice of method, the methodology for calculating each input, the management of buffer above minimum, and the prudent capital planning that withstands FCA supervisory challenge all sit within CFO accountability. AEMIs face an additional own funds calculation tied to the firm’s average outstanding e-money balance.

Reconciliation and breaks management sit at operational scale that has no equivalent in unregulated CFO roles. Payment institutions and e-money firms typically process millions of transactions through scheme infrastructure (Visa, Mastercard, Faster Payments, BACS, SEPA, SWIFT) with reconciliation cycles operating daily across nostro accounts, scheme settlement accounts, customer account positions, and safeguarding positions. Breaks must be identified, investigated, and resolved within tight tolerance windows, with senior finance accountability for the integrity of the firm’s books at any point. The CFO who cannot engage substantively with reconciliation operations is observably constrained in the payments market.

The supervisory engagement dimension has tightened materially through 2024-2026. The FCA’s “Dear CEO” letters on safeguarding and the broader supervisory focus on payments firm financial integrity have raised the credibility threshold for senior finance leadership. Supervisors increasingly engage directly with the CFO on safeguarding methodology, reconciliation processes, capital adequacy assumptions, and the firm’s broader financial governance. The CFO who can engage productively with supervisory dialogue — distinct from the candidate profile typical for unregulated CFO roles — commands material premiums in the recruitment market.

The unit economics of payments and e-money businesses introduce commercial finance challenges that conventional CFO backgrounds rarely cover. Take rate compression, scheme fee economics, interchange dynamics post-Mastercard/Visa cap regulation, working capital intensity in cross-border flows, foreign exchange revenue management, and the high-fixed-cost technology investment that competitive payments firms require all sit within commercial finance scope. Senior CFO candidates require sufficient commercial finance depth to engage with these dynamics substantively rather than treating them as operational details outside the finance remit.

Payments & E-Money Finance Roles We Recruit For

CFO of Payment Institution / E-Money Institution

The senior finance leader at the firm, accountable for both regulated finance scope (initial capital and own funds methodology, safeguarding integrity, capital adequacy reporting, FCA supervisory engagement) and conventional CFO scope (commercial finance, board reporting, treasury, FP&A, fundraising support, M&A). The role typically holds SMF2 designation under SMCR for FCA-authorised payments and e-money firms. For larger firms the CFO sits on the Executive Committee and reports to the CEO; for earlier-stage firms the role may combine with COO responsibilities. Senior candidates typically combine prior payments or e-money experience with sufficient commercial finance depth for fundraising and growth-stage business contexts.

Finance Director — Mid-Scale and Smaller Authorised Firms

For mid-scale APIs, AEMIs, and the smaller SPIs and SEMIs below the scale where a full CFO appointment is operationally justified, the SMF2-designated finance role is typically held by an FD. The role carries the same regulatory accountability as the CFO equivalent but with narrower commercial scope, a smaller finance team, and typically more direct hands-on involvement in reconciliation oversight, regulatory reporting production, and safeguarding governance. FD-level appointments are particularly common in the £5m–£30m revenue band for payments and e-money firms.

Head of Treasury

Treasury management at payments and e-money firms differs materially from conventional corporate treasury given the high transaction volumes, the multi-currency nature of cross-border flows, the scheme settlement timing dynamics, and the need to maintain liquidity for both customer-facing operations and prudential requirements simultaneously. Heads of Treasury at scaled payments firms typically own the firm’s nostro account architecture, scheme funding strategy, foreign exchange position management, and the broader liquidity governance framework. The role typically reports to the CFO.

Head of Safeguarding (Finance-Discipline Variant)

While safeguarding is sometimes structured as an operations or compliance function, an increasing number of authorised firms position the Head of Safeguarding within Finance given the centrality of reconciliation, financial control disciplines, and capital interaction to safeguarding integrity. Where structured as a finance role, the Head of Safeguarding owns the safeguarding methodology, the daily reconciliation process, the relationship with the safeguarding account credit institution, and the production of the safeguarding return (REP018). Reports to the CFO with dotted-line accountability to the firm’s MLRO and Head of Compliance.

Head of Regulatory Reporting

The senior specialist owning the production of regulatory financial reporting — REP017, REP018 (where applicable), FIN066, PSD2 reporting, fraud reporting (RTS-DR), and operational and security risks reporting. The role typically reports to the CFO and combines accounting qualifications with substantive prior payments or e-money experience and the technical depth required for the specific reporting frameworks applicable to the firm’s authorisation type.

Head of Reconciliations

The senior operational leader owning the firm’s reconciliation architecture — scheme settlement reconciliation, nostro reconciliation, safeguarding position reconciliation, internal customer balance reconciliation. The role typically reports to the CFO or to the Head of Operations with strong dotted-line accountability to the CFO. Particularly common at scaled payments and e-money firms where reconciliation operations are sufficiently substantial to warrant dedicated senior leadership.

Financial Controller

The senior accounting leader at the payments or e-money firm, owning the general ledger, statutory accounts, audit relationship, regulatory reporting production, tax compliance, and the day-to-day finance operations. Reports to the CFO. The role typically requires accounting qualifications (ACA, ACCA) plus substantive prior payments or e-money sector experience.

Interim and Fractional Payments / E-Money CFO

Interim and fractional CFO arrangements are common during firm scale-up, post-authorisation embedding, fundraising preparation, audit remediation, FCA supervisory remediation programmes, and at smaller authorised firms below the scale where full-time CFO appointment is operationally justified. Interim candidates typically require existing SMF approval where they take on the SMF2 designation, and FCA approval timing materially affects placement structuring.

Recruitment by Firm Type

Authorised Payment Institutions (APIs)

APIs offer one or more of the eight defined payment services under the PSR — money remittance, account services, card acquiring, cross-border payments, foreign exchange, payment initiation, account information, and similar. CFO requirements vary by service portfolio — money remittance firms face distinctive working capital and safeguarding intensity, card acquiring firms face scheme economics and chargeback management, FX firms face position management and revenue volatility. Candidates typically combine API-specific experience with the commercial finance depth that growth-stage business contexts require.

Authorised Electronic Money Institutions (AEMIs)

AEMIs issue electronic money — typically through prepaid cards, e-wallets, or stored-value platforms — with the corresponding obligation to hold customer funds against issued e-money. CFO requirements at AEMIs centre on the additional own funds calculation tied to average outstanding e-money balance, the operational complexity of e-money issuance and redemption, and the safeguarding architecture for the customer fund pool. Candidates typically combine AEMI-specific experience with commercial fluency in card programme economics and e-wallet platform operations.

Cross-Border Payments and Money Remittance Firms

Cross-border payments firms — operating typically as APIs offering money remittance and FX — face the most substantive treasury and working capital intensity in the payments sector. Multi-currency liquidity management, FX position management, correspondent banking relationships, and the timing dynamics of cross-border settlement all sit within senior finance scope. The candidate population with substantive prior cross-border payments experience is particularly valued.

Embedded Finance and Banking-as-a-Service Platforms

The growth of embedded finance and BaaS platforms — where authorised payment or e-money firms provide infrastructure to non-regulated brand partners — has introduced distinctive finance challenges around platform partner economics, sub-account architecture, programme P&L attribution, and the regulatory perimeter management between the authorised platform and the non-regulated brand partners. CFO candidates typically require prior platform-economics experience and the operational sophistication that multi-tenant authorised platforms demand.

Card Acquiring and Merchant Services Firms

Card acquiring firms face distinctive economics around interchange, scheme fees, take rate, chargeback exposure, and the working capital implications of merchant settlement. CFO requirements typically combine acquiring-specific experience with the commercial finance depth that pricing strategy and merchant economics require.

Crypto-Asset Firms with Payments Authorisations

A growing population of crypto-asset firms hold payments or e-money authorisations alongside their crypto registrations, particularly where the business model includes fiat on/off-ramps or stablecoin issuance and redemption. CFO candidates require both payments and crypto-asset familiarity, with the candidate population genuinely combining both being structurally constrained.

Smaller PIs and EMIs (SPIs and SEMIs)

Small Payment Institutions and Small E-Money Institutions operate under simplified authorisation regimes with reduced ongoing requirements but substantively similar safeguarding and reconciliation obligations. CFO appointments at SPIs and SEMIs are often FD-level with broader operational scope, given the smaller scale of the underlying business. Many SPIs and SEMIs grow through the threshold to AEMI/API status, requiring CFO candidates with sufficient capability for the firm’s likely future state.

Engagement Models for Payments & E-Money Senior Finance Roles

Permanent Appointments

The substantial majority of payments and e-money CFO appointments are permanent given the multi-year nature of senior finance leadership in regulated firms, the regulatory approval process for SMF2 designation, and the depth of relationship-building required for productive supervisory engagement. Permanent recruitment typically involves comprehensive search, structured candidate assessment including specific evaluation of payments experience and SMCR readiness, and substantial board engagement given the regulatory profile of the appointment.

Interim and Transition Appointments

Interim CFO appointments are common for transition cover between permanent appointments, post-authorisation embedding (where the application CFO transitions to the operational CFO), audit remediation, FCA supervisory remediation, and capability gaps during scale-up. Interim candidates typically require existing SMF approval; FD Capital’s network of pre-approved senior candidates enables interim placements to commence materially faster than the standard new-appointment regulatory approval timeline. Interim engagements typically run six to eighteen months.

Fractional and Portfolio Arrangements

For smaller authorised firms below the scale where full-time CFO appointment is operationally justified, fractional or portfolio CFO arrangements with senior candidates holding existing SMF approval can provide credible regulated finance leadership at appropriate cost. Fractional payments CFO arrangements require careful structuring to satisfy regulatory expectations around the substantive performance of the SMF2 function; we advise on appropriate engagement structures and identify candidates with both fractional working preferences and the payments-specific credibility that the role demands.

What to Look for in a Payments & E-Money Senior Finance Hire

Substantive prior PSR/EMR firm experience. Candidates with demonstrable prior senior finance experience at authorised payment institutions or e-money institutions — ideally with prior SMF approval history at PSR/EMR-authorised firms — bring pattern recognition, regulatory familiarity, and operational depth that conventional CFO backgrounds cannot replicate. The transition for first-time payments finance leaders is genuinely steep and warrants explicit recognition in placement decisions.

Safeguarding methodology and operational depth. Safeguarding under PSR Regulation 23 / EMR Regulation 20 sits at the heart of payments and e-money finance integrity. Candidates with substantive prior safeguarding experience — methodology design, daily reconciliation oversight, supervisory engagement on safeguarding matters, REP018 production — bring capability that the role requires. The candidate population with substantive safeguarding leadership experience is particularly valued in the current market.

Capital adequacy methodology under PSR/EMR. The choice between Method A, B, and C for ongoing own funds, the calculation methodology, the buffer management, and the supervisory dialogue around capital adequacy all sit within CFO scope. Candidates with substantive PSR/EMR capital adequacy experience bring the regulatory finance depth that the regime requires.

Scheme operations literacy. Payments and e-money firms typically operate through scheme infrastructure (Visa, Mastercard, Faster Payments, BACS, SEPA, SWIFT) with finance scope extending into scheme settlement timing, scheme fee management, scheme reporting, and scheme-driven reconciliation operations. Candidates with substantive scheme operations literacy bring credibility that the role demands.

Treasury management at scale. High transaction volumes, multi-currency operations, and the working capital intensity of payments businesses require treasury management capability that conventional corporate treasury experience does not always replicate. Candidates with prior payments treasury experience or with banking treasury backgrounds appropriate for payments contexts bring relevant capability.

FCA supervisory engagement experience. The FCA’s heightened supervisory focus on payments and e-money firms means CFO supervisory engagement is more substantive than at many other regulated firm categories. Candidates with prior supervisory engagement experience — whether through previous in-house roles, regulatory secondments, or audit/consulting positions — bring the credibility and judgement that productive supervisor relationships depend on.

Commercial finance depth for growth-stage business. Most UK payments and e-money firms operate at growth stage with ongoing fundraising, M&A activity, and commercial pressure on take rate and unit economics. Candidates appropriate for payments CFO roles typically combine regulated finance capability with sufficient commercial finance depth for fundraising support, board-level commercial dialogue, and unit economics engagement.

Payments & E-Money CFO Compensation Benchmarks

Current UK market ranges FD Capital is recruiting to in 2026. Payments and e-money finance compensation reflects both the conventional CFO market rate for the firm’s scale and a meaningful premium for sector-specific experience that has widened materially through 2024-2026 as supervisory expectations have tightened.

Compensation varies materially by firm size, growth stage, sub-sector (cross-border payments, e-money issuance, embedded finance, and acquiring see different ranges), seniority, and SMCR approval status. Growth-stage firms typically include meaningful equity participation alongside base and bonus; PE-backed platforms typically include sweet equity arrangements appropriate for the holding period.

How FD Capital Recruits Payments & E-Money Senior Finance Hires

The process combines standard executive search methodology with the specific benefit of dedicated PSR/EMR-authorised firms expertise built over the past eight years. Briefing call within 24 hours of enquiry, with Adrian Lawrence personally handling briefings for senior payments CFO mandates given the regulatory profile of the role. Written role specification by day two, covering the firm’s authorisation type and service scope, the safeguarding architecture, the capital adequacy methodology, the existing senior management structure, the SMCR allocation, and the supervisory engagement context. Discreet search through days two to ten, drawing on FD Capital’s network of senior finance candidates with substantive PSR/EMR experience including pre-approved SMF candidates where rapid deployment is required. Shortlist presentation at day seven to ten — typically four to five candidates, each with our written assessment of their payments sector experience, safeguarding methodology depth, capital adequacy capability, scheme operations literacy, FCA supervisory engagement experience, and SMCR readiness. Interviews over two to three weeks. Appointment typically completing within 35 to 56 days of initial briefing for senior permanent roles, with regulatory approval following appointment typically adding four to twelve weeks before the candidate can commence the SMF2 role.

Frequently Asked Questions

What is safeguarding and why does it matter for payments CFO recruitment?

Safeguarding under PSR Regulation 23 and EMR Regulation 20 is the regulatory requirement that customer funds received for payment services or held against issued e-money be segregated, protected, and demonstrably available for return to customers in the event of firm failure. Safeguarding sits at the heart of FCA supervisory focus on payments and e-money firms, with multiple firm authorisations cancelled in recent years specifically for safeguarding failures. The CFO typically carries personal accountability for safeguarding integrity through SMF designation, making safeguarding methodology and operational depth core to CFO recruitment.

What is the difference between Methods A, B, and C for own funds calculation?

PSR Regulation 22 provides three alternative methods for calculating ongoing own funds at APIs. Method A uses 10% of fixed overheads. Method B applies a percentage of payment volume on a sliding scale. Method C applies a percentage of relevant indicators (gross income from payment services). Each method produces different capital outcomes for the same underlying business and the choice of method materially affects capital efficiency. Senior CFO candidates require fluency in all three and the methodology depth to make appropriate method choices for the firm’s context.

Do payments and e-money CFOs need SMF2 designation?

Most CFOs at FCA-authorised payments and e-money firms hold SMF2 designation under SMCR, carrying personal regulatory accountability for the firm’s financial position, regulatory financial reporting integrity, and prudential compliance. Smaller firms (SPIs and SEMIs) face lighter SMCR requirements but the senior finance leader typically still holds equivalent regulatory accountability. Where the CFO holds SMF2, FCA approval is required before the appointment commences — typically four to twelve weeks for individuals with prior SMF approval history.

Can a CFO without prior payments experience succeed in the role?

Yes, with caveats. The technical content of payments finance — safeguarding, capital adequacy methodology, scheme operations, treasury at scale, regulatory reporting — is substantial enough that first-time payments CFOs face a steep learning curve. Most authorised firms prefer candidates with prior payments or e-money experience; the candidate’s first sector appointment typically requires substantial induction support. Candidates from banking treasury backgrounds with appropriate transferable experience can sometimes succeed, but pure unregulated CFO backgrounds generally struggle.

Do you place CFOs for firms during the FCA authorisation application process?

Yes — pre-authorisation CFO recruitment is common, particularly for firms in the late application stage where supervisor engagement requires senior finance leadership in place. We work with applicant firms to identify candidates whose track record supports the application narrative, whose presence strengthens FCA confidence in the firm’s financial governance, and who can transition smoothly into post-authorisation operations. See our FCA Authorisation Finance Specialist Recruitment page for finance recruitment specifically focused on the authorisation phase.

How does the APP fraud reimbursement scheme affect payments CFO recruitment?

The mandatory APP fraud reimbursement scheme effective from October 2024 imposed substantial new reimbursement obligations on UK payment service providers. CFO accountability extends into the financial provisioning for APP fraud reimbursement, the operational interface between fraud detection and customer reimbursement, and the supervisory engagement on the scheme’s application. Senior candidates with prior APP fraud framework engagement bring relevant capability for the post-October-2024 environment.

Do you place senior finance hires for crypto-asset firms with payments authorisations?

Yes — a growing population of crypto-asset firms hold payments or e-money authorisations alongside their crypto registrations. CFO candidates for these firms require both payments and crypto-asset familiarity. The candidate population genuinely combining both remains structurally constrained; we advise on the appropriate candidate profile given the firm’s specific business model and regulatory perimeter.

Related Recruitment Services

Firms considering payments and e-money senior finance recruitment may also be interested in: SMF2 Regulated CFO Recruitment | FCA Regulated Firms Recruitment | CFO Recruitment Agency UK | Finance Director Recruitment | AIFM CFO Recruitment | Investment Firm CFO Recruitment | FCA Authorisation Finance Specialist | Interim CFO Recruitment | Fractional CFO UK | Hire an FD or CFO

Find a Payments / E-Money CFO

FD Capital recruits CFOs, Finance Directors, Heads of Treasury, Heads of Safeguarding, Heads of Regulatory Reporting, Heads of Reconciliations, and Financial Controllers into UK Payment Institutions, E-Money Institutions, and PSR/EMR-authorised firms across cross-border payments, e-money issuance, embedded finance, card acquiring, money remittance, foreign exchange, and account information services. Founder-led by Adrian Lawrence FCA. Senior candidates with substantive prior PSR/EMR experience and pre-approved SMF candidates available for rapid deployment. Shortlists in seven to ten working days.

📞 020 3287 9501 ✉ recruitment@fdcapital.co.uk

Start Your Payments CFO Search →