Disclaimer: This blog post is provided for general information purposes only. It does not constitute legal advice and should not be relied upon as such. Specific legal advice should be sought in relation to your particular circumstances.

The electronic money institution and payment services provider Guavapay Limited (“Guavapay”) was suspended by the Financial Conduct Authority in September 2025, leaving many customers with urgent questions about what has happened and how their funds can be recovered.

Following the suspension, the FCA prevented Guavapay from carrying on new business or accepting further electronic money, and Guavapay has since entered compulsory liquidation.

Below we explain what this means for customers and the potential route for recovering monies held with Guavapay.

How were customer funds meant to be protected by Guavapay?

The amounts held in individual or company Guavapay accounts were required to be protected under Guavapay’s Safeguarding Policy (available on Guavapay’s website) and under the Electronic Money Regulations 2011 (“EMRs”).

Pursuant to Guavapay’s Safeguarding Policy, once customer funds are received, Guavapay is obliged to place the funds in a dedicated safeguarding account and such safeguarded funds must remain in that account until they are spent by the customer. The Policy also states that if Guavapay becomes insolvent, claims made by customers, will be paid in priority over other creditors.

Legal protections under the Electronic Money Regulations 2011 (“EMRs”)

In addition to its Policy, Guavapay, as an electronic money institution is required to comply with the EMRs.

Under regulations 21 and 24, Guavapay must safeguard customer funds and, if it becomes insolvent, ensure that electronic money holders are paid in priority from the “asset pool”.

What if safeguarding rules were not followed?

The courts have confirmed that a failure to comply properly with safeguarding obligations does not necessarily prevent customers from benefiting from the statutory protection regime under the EMRs.

In particular, case law has established that where there is a shortfall in safeguarded funds, an amount equal to that shortfall may still be required to be made good to the asset pool from the insolvent estate.

What does this mean for Guavapay account holders?

We understand that this situation has caused significant inconvenience and loss to affected account holders.

Individuals and companies with Guavapay accounts have a strong legal basis to seek the return of their funds.

How can Edwin Coe help?

If you or your company have funds held in a Guavapay account, or if Guavapay failed to process a transfer request and you are seeking a refund of funds held in your account, please contact David Greene and Charlotte Kessler.

Please note that this blog is provided for general information only. It is not intended to amount to advice on which you should rely. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of the content of this blog. Please also see a copy of our terms of use here in respect of our website which apply also to all of our blogs.