Sandbox FAQs

The Sandbox is intended for:

• early‑stage businesses developing innovative financial products or services;
• firms whose proposed activities do not fit neatly within existing regulatory categories;
• existing licensees seeking to expand into new or materially different activities.

Firms with straightforward, well‑understood business models are likely to be better suited to the Commission’s standard application process.

Firms participating in the Sandbox can expect:

• greater flexibility in how entry requirements are evidenced, particularly for start-ups;
• early engagement with the Commission;
• regulatory signposting where there is uncertainty about licensing requirements;
• tailored licence conditions or approvals that reflect the testing and incubation nature of the activity;
• defined review points during the Sandbox period;
• a clear pathway towards licensing without restrictions, where appropriate.

No. The Sandbox is not a separate licence category and is not an approval in its own right. Firms operate under a licence, authorisation or registration granted under existing regulatory laws, with conditions tailored to reflect the testing and incubation nature of the activity.

All firms must meet minimum regulatory requirements before carrying on regulated activity. What it allows is flexibility in how requirements are applied during initial application and the testing phase, in a way that is proportionate to the risks involved.

While digital finance is a common use case, the Sandbox is not limited to fintech or technology‑based businesses. It may be used for any innovative or novel proposition where there is an unusual degree of uncertainty.

Yes. The Sandbox is open to existing licensees as well as new applicants. It may be appropriate where an existing firm is seeking to introduce a new product, service or business line that differs materially from its existing activities and which requires a change of regulatory permissions.

The best way to begin is by submitting a Concierge Connect Form. This allows you to outline your proposal at a high level and helps the Commission determine the most appropriate next steps.

Not for the early engagement stage which is intended to be exploratory, although more developed proposals are generally easier to assess. As part of any Sandbox application, a developed business plan will need to be submitted alongside the application.

No. The Commission cannot provide legal advice. Early engagement is intended to provide regulatory signposting and help firms understand potential pathways and next steps.

 

Considerations for the traditional route as opposed to the Sandbox would include where the proposal is:

• sufficiently mature;
• able to meet all applicable rules and regulations without modification; and/or
• not well‑suited to Sandbox testing.

Priority is given to the most credible and developed proposals. Repeated or prolonged meetings at an early scoping stage may be limited, and firms may be encouraged to progress their proposal independently or provide further information.

The Sandbox is designed to support testing and learning and the Commission recognises that aspects of a firm’s business model may evolve during the incubation phase. During the incubation phase, firms may refine or adapt their business model accordingly, subject to ongoing regulatory engagement.

Towards the end of the Sandbox phase, the Commission will assess, in discussion with the firm, whether it is appropriate to graduate to operation without tailored conditions, continue with modified conditions, or exit the Sandbox in an orderly manner.

No. Participation in the Sandbox does not constitute endorsement, approval of commercial viability or confirmation of regulatory favourability.

Sandbox firms will appear on the Commission’s public register in the same way as other licensed or registered entities. They may be identified as Sandbox participants, but specific licence conditions are not routinely published.

Any public references to Sandbox participation must be accurate and not misleading. Licensing by the Commission is normally referred to by firms and we would expect Sandbox participants to do the same with it probably also being appropriate for such firms to make clear their licence is held within the Sandbox.