- The FCA issued a First Supervisory Notice to Sendsii Ltd on 23 January 2026, prohibiting the firm from conducting any regulated activity in the UK.
- The action was triggered by HMRC suspending Sendsii Ltd’s registration on 9 October 2025, which caused the firm to fall out of compliance with FCA authorisation conditions.
- The case highlights how a lapse in HMRC registration status can directly and automatically jeopardise a payment firm’s FCA authorisation under the Payment Services Regulations 2017.
What the FCA Has Done — and Why
On 23 January 2026, the Financial Conduct Authority (FCA) served a First Supervisory Notice on Sendsii Ltd, a UK-authorised payment services firm, imposing requirements that effectively bar the company from carrying out any regulated activity. The action was not triggered by a conduct failing discovered directly by the FCA, but by a prior regulatory event upstream: on 9 October 2025, HM Revenue and Customs (HMRC) suspended Sendsii Ltd’s registration, removing a foundational condition the firm was required to maintain under its FCA authorisation framework.
Under the Payment Services Regulations 2017 (PSRs 2017), firms authorised by the FCA to provide payment services must satisfy — and continuously maintain — a defined set of conditions. HMRC registration is one such condition for firms in scope of anti-money laundering oversight. When HMRC acted in October 2025, Sendsii Ltd ceased to meet those baseline requirements, creating the legal grounds for the FCA’s January intervention.
The Mechanics of a First Supervisory Notice
A First Supervisory Notice (FSN) is a formal regulatory instrument the FCA deploys when it determines that immediate requirements must be imposed on an authorised firm, typically without prior consent from the firm itself. It is distinct from a final notice in that it represents an early-stage enforcement step — but its practical effect can be equally severe. In Sendsii Ltd’s case, the FSN carries an absolute prohibition on regulated activity, meaning the firm cannot legally process payments, hold client funds, or execute any service within its authorisation scope for the duration the requirements remain in place.
“Sendsii Ltd no longer met the conditions required for its FCA authorisation under the Payment Services Regulations 2017 following HMRC’s suspension of its registration on 9 October 2025.”
Implications for Payment Firms and Their Compliance Obligations
The Sendsii Ltd case is a sharp reminder that FCA authorisation does not exist in isolation. Payment firms operating under the PSRs 2017 must maintain concurrent compliance across multiple regulatory bodies — including HMRC for Anti-Money Laundering (AML) supervision purposes. A lapse with any one regulator can create an automatic cascade, stripping a firm of its operating licence without the FCA needing to identify a separate misconduct event. Compliance officers at authorised payment institutions should treat HMRC registration renewal and status monitoring as a tier-one obligation, not a secondary administrative task.
What Affected Customers and Counterparties Should Do
Any individuals or businesses that hold funds with Sendsii Ltd or have pending transactions routed through the firm should treat the FSN as an immediate alert. Regulated activity is suspended, meaning the firm has no legal basis to process new instructions. Counterparties should seek written confirmation of fund safety and explore formal complaints or claims routes if access to funds is obstructed. The FCA’s Financial Services Register will reflect the firm’s restricted status and should be consulted for the latest position on authorisation.
The Sendsii Ltd shutdown illustrates a growing compliance blind spot in the UK payments sector: firms investing heavily in FCA-facing governance while underestimating the operational risk of their HMRC registration status. With the FCA increasingly treating multi-regulator non-compliance as grounds for immediate restriction rather than remedial dialogue, payment institutions — particularly smaller authorised firms — should urgently audit whether their HMRC obligations are being tracked with the same rigour as their FCA reporting cycles. For investors holding positions in mid-tier UK payments fintechs, this case adds a new due diligence dimension: HMRC registration continuity is now demonstrably a business-continuity risk.
