AFEP would encourage members to read the Dear CEO letter to wholesale brokers. Whilst not applicable to APIs and EMIs, it gives a good insight into the FCA's approach to Financial Risk and implications on wind down plans, remuneration and governance & controls.
The FCA have already suggested SMCR will be applied to Payment Services in the future, so firms are advised to understand the rules and regulations early and prepare accordingly.
https://www.fca.org.uk/publication/correspondence/wholesale-brokers-portfolio-letter-2023.pdf