The issuer is the card scheme member that contracts with the cardholder, and that member holds the cardholder funds. Under UK law a sponsor cannot lend you issuance: an e-money institution may not issue through a distributor, agent or anyone acting on its behalf. You distribute; it issues. And in Switzerland, Hong Kong and Singapore your own role may need its own authorisation.
Three public documents, three parts of the question
Which licence a card business needs is a separate question, answered in which licence for stablecoin payments and card issuing. This page is the layer underneath: how the roles in a programme agreement divide, and which one you are signing up for. Wording quoted below was retrieved on 13 October 2026.
Who issues, who distributes and who holds the cardholder funds are decided when a card programme is set up, which is work that starts once a licence is in place. After the licence has a section on cards specifically. If the permission your own role needs is still open, start with choosing a licence.
Key takeaways
- The issuer of record is a scheme member. A BIN has exactly one licensee, and that member carries the liability for everything done on it.
- Under UK law, issuance cannot be delegated: the rules permit distribution and redemption through an agent or distributor and prohibit issuance through either.
- Under the UK rules, safeguarding stays with the institution: money an agent receives counts in law as money the issuer received.
- Your own link in the chain may still be licensable — Switzerland's anti-money-laundering law names issuing or managing means of payment among the activities it catches, which brings the Swiss SRO route into play.
Who is the issuer of record?
The answer sits in the scheme rulebook, not in the programme agreement. The public Visa Core Rules define an Issuer as a Member that enters into a contractual relationship with a cardholder for the issuance of one or more card products. Membership is not something a sponsor can confer: its requirements are set by Visa's own charter documents.
The BIN layer is singular in the same way: a BIN may have only one licensee, and that member is liable for all activity associated with it. Visa's own partner guidance is blunter: the BIN sponsor is the issuing bank, it owns the BIN, it holds cardholder funds, it manages risk and local country regulation and often acts as settlement agent, and the programme manager oversees your card programme on the issuing bank's behalf. The same page names a third contracted party, the issuer processor, alongside the banking relationship and the programme manager. In most crypto card deals, the programme manager role is yours.
Can a sponsor lend you its licence?
Not under UK law, and the clearest statement of it is English. Regulation 33 of the Electronic Money Regulations 2011 permits an e-money institution to distribute or redeem e-money through a distributor or agent, and the next paragraph prohibits it from issuing e-money through a distributor, agent or any other entity acting on its behalf. The licence itself does not move to you.
An electronic money institution may not issue electronic money through a distributor, agent or any other entity acting on its behalf.Electronic Money Regulations 2011, regulation 33(2), legislation.gov.uk
The FCA restates it for applicants in Payment Services and Electronic Money: Our Approach, and adds two sentences that matter in a negotiation. A party that simply loads or redeems e-money on an institution's behalf is, in the regulator's view, a distributor (paragraph 5.5), and as with agents the institution is responsible for anything a distributor does or omits (paragraph 5.6).
Which is why the standard vendor framing — the sponsor lends its membership and licence, you build the product and own the customer — describes something UK law does not permit. The responsibility runs one way: you take a distributor's or agent's position, the institution answers for you, and you gain none of its permissions.
Whose money is it, and who has to safeguard it?
The issuer's, and no contract changes that. Visa states that the issuing bank holds cardholder funds. The FCA adds the point most programme agreements skate over: if an agent of an e-money issuer receives funds, those funds are considered in law to have been received by the issuer itself.
The FCA's wording is that in those circumstances safeguarding remains with the institution, not with the agent or distributor.
Singapore puts a clock on it: under section 23 of the Payment Services Act 2019 a licensee in scope must safeguard the whole or prescribed part of customer money no later than the next business day after receipt. The pre-funded balance in your app is what that rule governs.
Does your own role need its own licence?
Often yes, and separately from the issuer's licence. Switzerland's anti-money-laundering law reaches anyone who on a professional basis holds or helps transfer other people's assets, and names issuing or managing means of payment as one such activity. Hong Kong licenses facilitating the issue of a stored value facility, not only issuing it. Singapore presumes a secondary payment-service business.
Your own link in the chain: what pulls you in, and what it requires
| Jurisdiction | What pulls you in | What it requires |
|---|---|---|
| Switzerland | Article 2(3) of the Anti-Money Laundering Act: persons who on a professional basis hold or help transfer assets belonging to others are financial intermediaries, and letter (b) names issuing or managing means of payment | Article 14(1): affiliation to a self-regulatory organisation. Without it, Article 20 lets FINMA act, including ordering liquidation of the legal entity; Article 18a requires a public online FINMA directory |
| Hong Kong | The HKMA register of SVF licensees covers a licence to issue or facilitate the issue of a stored value facility, so facilitation alone is not outside the regime | A licence on the conditions in a government paper to the legislature — these attach to any SVF licensee: Hong Kong incorporation, stored-value issue as the principal business, a chief executive ordinarily resident there. Licensed banks are treated as licensed under section 8G |
| Singapore | Section 5(1) of the Payment Services Act 2019: no business of providing any type of payment service without the matching licence or an exemption | Section 5(2) removes the incidental defence — the person is presumed to carry on a secondary business of providing that type of payment service, and relatedness to the main business does not rebut it |
What the entity itself has to carry — directors, office, AML officer, capital — is in local substance requirements explained; the Singapore tiers are in which Singapore crypto licence you need.
Can the card scheme refuse you?
Yes, and that decision is independent of any regulator's. Visa classes a non-member supplying payment-related services to a member as a Third Party Agent, and sets three conditions: a direct written contract with a member; registration by that member, completed before any contracted service or transaction activity; and a senior officer of the member reviewing all documentation before signing.
Visa may deny or reject a Third Party Agent's registration at any time with or without cause.Visa Core Rules, section 1.9.8.6, Visa Rules (public edition)
The scheme rules above are Visa's own published rulebook; Mastercard publishes its rules separately and is not covered here.
What should you ask a supplier offering BIN sponsorship?
A sound arrangement has four visible parts: a named licensed issuer, the customer money on that issuer's side, your role registered with the scheme under that member before launch, and your own authorisation checked at home.
- Which institution is the issuer, and which jurisdiction licensed it? If the entity cannot be named, there is no issuer in the chain.
- Who holds the customer money, and who carries the safeguarding duty? It should be the same entity as the answer above.
- Is our role registered with the scheme, and under which member? Registration has to precede the service, not follow the launch.
- Where is the checkable evidence? FINMA's directory and the HKMA register are both open; how to check a crypto licence is real walks each one.
Frequently asked questions
If the sponsor holds the licence, do we need one at all?
Separate the two questions. Under UK law issuance cannot be borrowed: regulation 33(2) of the Electronic Money Regulations 2011 bars issuing through a distributor, agent or any other entity acting on the institution's behalf. That is not the same as your role being unregulated — Switzerland, Hong Kong and Singapore each reach a party that is not the issuer.
Can customer funds sit in our company account?
Not under the UK rules, and the direction is the opposite of what most agreements assume: funds received by an agent are considered received by the issuer itself, and safeguarding stays with the institution rather than the agent or distributor. Singapore requires a licensee in scope to safeguard by the next business day after receipt.
How long does it take to become an issuer in Hong Kong?
No timeline can be given, and nobody outside the authority can give one. What is checkable is the register: eleven non-bank licensees, the newest effective 19 December 2022, and conditions including a Hong Kong-incorporated company whose principal business must be issuing stored value facilities. No application is guaranteed approval; whether and when it is granted is at the regulator's discretion.
This page states the wording of public regulatory documents as at October 2026 and is not legal advice. CryptoLicense is the licensing advisory brand of CL GLOBAL SDN BHD (1421939-T). Its service lines are crypto licences, fintech licences, licence transfer, card issuing and bank account opening; the Swiss SRO route is its largest revenue line, and it has served 100+ companies across 10+ jurisdictions. Registration details are on the entity proof page; the card side of the practice is banking and card issuing, and the account side of this question is can a licensed crypto business actually open a bank account.