The application process for a licence under the Financial Services Act  or authorisation under the Insurance Act remains largely the same whether there is the use of technology in the business or not. The new business guidance and sandbox approach clarify potential differences in the process. The Authority encourages prospective applicants to contact the Authority before making an application to discuss the proposals.


No, a financial services licence or insurance authorisation is only required where a person is undertaking regulated activity by way of business. Merely testing and developing a product in-house is not undertaking business.

Because beta testing involves external consumers using the product (even on a restricted basis) a relevant financial services licence or authorisation will be required prior to beta testing.

The Authority’s new business guidance and sandbox approach set out our application expectations.