Innovation Sandbox + Concierge
Where financial innovation meets collaboration
The Innovation Sandbox + Concierge offers an environment for firms to launch innovative products and services within a structured framework paired with a regulatory concierge service. Whether you're exploring blockchain, tokenisation, AI-driven finance, or other innovative solutions, the Innovation Sandbox + Concierge is designed to help you engage with the regulatory landscape in a constructive and informed way.
Guernsey Finance supports the Commission in delivering the Concierge service. It is able to help you make meaningful connections across Guernsey’s dynamic financial services sector. Whether you're seeking strategic partnerships, local expertise, or insights into Guernsey’s financial services community, Guernsey Finance can guide you to the right people and resources.
What is the Innovation Sandbox?
Rather than creating a new type of licence, the Sandbox provides a framework for applying existing regulatory laws and supervisory tools in a way that reflects the nature, scale and risk of the proposed activity. It supports testing and development, with a clear pathway towards either operation outside the Sandbox or an orderly exit if the proposal does not proceed.
Participation in the Sandbox does not reduce regulatory standards or remove statutory requirements. All firms must meet minimum regulatory requirements before carrying on regulated activity.
What the Sandbox offers is flexibility in how those requirements are evidenced at application and during the testing or incubation phase, in a way that is proportionate to the risks involved. This is typically achieved through tailored licence conditions attached to a licence or approval granted under existing regulatory laws.
Examples of tailored conditions could be:
|
Condition Type |
Example |
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Scope limitations |
Restricted client base or numbers, capped transaction volumes |
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Disclosure |
Reporting of outcomes, risks and incidents/the provision of data to help us manage and monitor emerging risks |
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Consumer protection |
Use of disclaimers, opt-in participation, cooling-off mechanisms |
The Sandbox is not limited to digital finance. While digital finance is expected to be a common use case, the Sandbox may be used for novel and innovative propositions where there is uncertainty around the standard regulatory framework.
How it works:
“We understand that innovation doesn’t always fit neatly into existing categories. That’s why our sandbox begins with a conversation—not a checklist. Submit a Concierge Connect Form and we can explore how we can support your application.” Alison Gavey, Co-Director of Authorisations and Innovation Division
1. Early engagement
The Sandbox pathway begins with an early engagement stage. This is designed for firms that are exploring a new, complex or uncertain proposition and want to understand how it may be treated from a regulatory perspective.
At this point, firms can engage with the Commission to:
- outline their proposal at a high level;
- discuss areas of regulatory uncertainty or complexity;
- explore whether the Innovation Sandbox is likely to be an appropriate route; and
- understand what further information would be needed to progress.
To start a conversation as part of the early engagement stage, please submit a Concierge Connect Form.
Early engagement does not constitute approval or a commitment to license. Its purpose is to provide regulatory signposting and help firms make decisions about next steps. To ensure that engagement is effective and proportionate, we will focus our time and resources on the most credible and developed proposals and may prioritise approaches accordingly. We cannot provide legal advice.
Possible outcomes at this stage include:
- regulatory information or signposting being provided; and
- confirmation of an appropriate regulatory pathway, either through the Sandbox or via the standard licensing process (taking into account a firm’s view); or
- a conclusion that the proposal is not currently suitable for further regulatory engagement.
Where early engagement concludes without progression, firms may return at a later stage if their proposal develops or circumstances change. Some complex enquiries may take longer to assess, but firms will be kept informed of progress and next steps.
2. Sandbox entry
Where, following early engagement, a proposal is considered suitable for the Sandbox, the firm will be invited to make an application through the Commission’s Applications and Authorisations portal under the existing regulatory laws.
Each firm entering the Sandbox will be assigned a dedicated contact within the Authorisations and Innovation Division. Applications are assessed against the minimum criteria for licensing, with any proposed conditions, limitations or testing arrangements discussed between the firm, authorisations staff and the relevant supervisory division.
On licensing, we will set a timeframe for the incubation phase, in conversation with the firm, to provide clarity on review points and expectations around graduation or exit.
3. Incubation
The incubation phase is the period during which a firm is licensed and operating within the Sandbox framework. The detail of this phase will vary depending on the firm and the nature of its activity, but firms should expect regular engagement with the Commission. This may include review points, consideration of information or reporting provided, and adjustments to licence conditions where appropriate. During this phase, firms may also continue to benefit from concierge support, particularly in relation to regulatory expectations or making appropriate connections.
The Sandbox recognises that innovative propositions often evolve as they are tested in a live environment. During the incubation phase, firms may refine or adapt their business model accordingly, subject to ongoing regulatory engagement.
4. Graduation or exit
The Sandbox is intended to be a launchpad, not an indefinite arrangement. Each firm will be given a scheduled end date for the Sandbox phase. Around three months before that date, the relevant supervisory division will assess, in discussion with the firm, whether it is appropriate to:
- graduate to full operation outside the Sandbox without tailored conditions;
- continue operating with modified conditions; or
- exit the Sandbox in an orderly manner.
Related news and updates
- Guernsey Financial Services Commission Launches Digital Finance Initiative — GFSC
- Online Applications and Authorisation Portal goes live with Beta launch
- Developing Technology and Helping Facilitate Prosperity
- The Commission’s approach to crypto currency funds — GFSC
- Finovation: The Guernsey Edge
- Policy Statement – Approach to Fund Tokenisation — GFSC
- AI & Finance in Guernsey: The Power and the Implications
Contact & Support
Ask us about Innovation Sandbox + Concierge: [email protected] or submit a Concierge Connect Form.
Innovation at the Commission
The Commission is committed to innovation and using technology and supporting the use of technology by industry that improves efficiency and effectiveness. Read more about how were using technology, including our innovative Applications and Authorisations Portal, and supporting industry in using technology on the Technology at the Commission page on our website.