SANDBOX ENVIRONMENT
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FinTech Regulatory Sandboxes
ASIC REGULATORY SANDBOX
AUSTRALIA
DEC 2016
• Australian Securities & Investments Commission (ASIC)
• Australian Securities and Investments Commision Act 2001
• Treasury Laws Amendment (2018 Measures No. 2)) Bill 2019
• Regulatory Guide
Sandbox Name
Launch Date
Governing Commission, Law & Regulatory Guidelines
Sandbox Environment
ADGM Digital Sandbox
ADGM RegLab
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Abu Dhabi Global Market (ADGM)
Sandbox Environment
FinTech firms that provide innovative digital financial products and services that can benefit the industry in the region are eligible to participate in the RegLab and ADGM Sandbox.
The ADGM Sandbox allows FinTechs to run tests digitally on the platform, adopt and orchestrate the best ones that meet their business needs, offer their innovative solutions to international market players and tap cross-border market access and opportunities to grow and scale their business.
Under the RegLab framework, participants enjoy a in a controlled environment, after which participants with viable business models will be transferred to the full authorization and supervisory regime upon successful demonstration of compliance with the authorization criteria. Firms who are not ready after the 2-year period will exit the RegLab framework.
SEPT 2018
MAY 2016
Abu Dhabi
CBB REGULARTORY SANDBOX
Sandbox name
Governing Commission, Law & Regulatory Guidelines
Luanch Date
• Central Bank of Bahrain(CBB)
• Framework
Eligible Companies
Start-ups and well established businesses
NOV. 2016
United
Arab
Emirates
DFSA's Innovation Testing License
Sandbox name
Governing Commission, Law & Regulatory Guidelines
Luanch Date
Dubai Financial Services Authority(DFSA) Dubai International Financial Center Authority(DIFCA)
UAE Federal Laws
Eligible Companies
Firms must invole innovation and the use of FinTech(activity that would amount to a Financial Service)
MAY. 2016
Dubai
Australia
Indonesia
Malaysia
Taiwan
South Korea
Thailand
Russia
Singapore
Dubai
United Arab Emirates
Abu Dhabi
Sierra Leone
Switzerland
Denmark
Netherlands
U.K.
U.S.
Canada
Hong Kong
Brunei
599 Lexington Avenue, New York, New York 10022-6069 United States of America
Contact Us
ShearmanFinTech@shearman.com
+1 212 848 4000
View the Full Report
DFSA Innovation Testing License
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Dubai Financial Services Authority (DFSA)
• Dubai International Financial Center Authority (DIFCA)
• UAE Federal Laws
Sandbox Environment
FinTech firms that have products or services that involve innovation and the use of FinTech are eligible. In making this determination, the DFSA will consider if the firm uses new, emerging or existing technology in an innovative and beneficial way. Products must also involve a “Financial Service” within the scope of the DFSA’s regulatory regime.
Products must also be ready (or soon be ready) to start testing with customers or industry.
Selected firms receive will receive an Innovation Testing Licence (ITL).
MAY 2017
Dubai
CBB REGULARTORY SANDBOX
Sandbox name
Governing Commission, Law & Regulatory Guidelines
Luanch Date
• Central Bank of Bahrain(CBB)
• Framework
Eligible Companies
Start-ups and well established businesses
NOV. 2016
United
Arab
Emirates
Abu Dhabi REGULARTORY SANDBOX
Sandbox name
Governing Commission, Law & Regulatory Guidelines
Luanch Date
Abu Dhabi Global Market(ADGM)
ADGM's three independent authorites:
• the Registartion Authority
• the Financial Services Regulatory Authority
• ADGM COurts
Common Law
Eligible Companies
Firmdeploying innovative technology in the financial services sector(FinTech participants)
Loacal and international FInTech start-ups and Small-Medium Enterpreise(SME)
sector entities have been admitted thus far
NOV. 2016
Abu Dhabi
(Click to view more info)
(Click to view more info)
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DFSA's Innovation Testing License
Sandbox name
(Click to view more info)
Governing Commission, Law & Regulatory Guidelines
Luanch Date
Dubai Financial Services Authority(DFSA) Dubai International Financial Center Authority(DIFCA)
UAE Federal Laws
Eligible Companies
Firms must invole innovation and the use of FinTech(activity that would amount to a Financial Service)
MAY. 2016
Dubai
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• UAE Securities Commodities Authority (SCA)
Sandbox Environment
Requirements for participation in the sandbox include innovative technology, measurable benefit to consumers and/or industry growth, a business plan ready to be tested, certain compliance criteria and defined test scenarios, among other requirements.
The SCA FinTech Regulatory Sandbox testing runs for where the business model is tested in a real and safe environment to ensure compliance with consumer safeguards agreed between the SCA and the applicant.
Sept 2018
United
Arab
Emirates
Abu Dhabi REGULARTORY SANDBOX
Sandbox name
Governing Commission, Law & Regulatory Guidelines
Luanch Date
Abu Dhabi Global Market(ADGM)
ADGM's three independent authorites:
• the Registartion Authority
• the Financial Services Regulatory Authority
• ADGM COurts
Common Law
Eligible Companies
Firmdeploying innovative technology in the financial services sector(FinTech participants)
Loacal and international FInTech start-ups and Small-Medium Enterpreise(SME)
sector entities have been admitted thus far
NOV. 2016
Abu Dhabi
AMBD Regulatory Sandbox
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• The Monetary Authority of Brunei Darussalam (AMBD)
• Legislations & Regulations
• Regulatory Guidelines
Sandbox Environment
FinTech firms that have a working solution (i.e., solutions that are ready to be deployed to the market) are eligible.
If your company has not reached this stage yet, you are encouraged to engage the FinTech Office to clarify any questions that you may have concerning applying for a sandbox.
Eligible firms include those that offer innovative “financial services,” meaning regulated activities under any of the following: (i) Banking order, 2006; (ii) Islamic Banking Order, 2008; (iii) Insurance Order, 2006; (iv) Takaful Order, 2008; (v) Securities Market Order, 2013; (vi) Payment and Settlement System Order, 2015; (vii) Money Changing and Remittance Business Act; (viii) Moneylenders Act; (ix) Pawnbroker Order, 2002.
The sandbox allows FinTech firms to experiment with new products and services, as well as business models. Additionally, it allows the execution of software or programs for evaluation, monitoring, or testing in a controlled environment and a relaxed regulatory space for a limited period of time.
The FinTech firm must perform its own research and due diligence on the proposed financial service prototype in its testing environment, given the adequate technical knowledge, and must take into account the evolving landscape of the financial sector.
Companies must be past the “proof-of-concept” phase and demonstrate the intention and ability to deploy their product or solution on a broader scale after exiting the sandbox.
FEB 2017
(Click to view more info)
brunei
CSA Regulatory Sandbox
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Canada Securities Administrators (CSA)
Sandbox Environment
The sandbox is open to business models that are innovative from a Canadian market perspective, including FinTech firms. This includes products, services and applications that are useful throughout the Canadian market.
Under the sandbox, firms may obtain exemptive relief from securities laws requirements, under a more expedited process than a standard application.
CSA staff determines limits and conditions that will apply to the firm in the Regulatory Sandbox (conditions are tailored to each company)
FEB 2017
(Click to view more info)
canada
FSA FT Lab
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Danish Financial Supervisory Authority (FSA) (Finanstilsynet)
Sandbox Environment
The FT Lab is open to FinTech firms that:
(1) already have a license within the financial legislation, but wish to test a new technology and/or business model;
(2) do not have the required license within the financial legislation to provide the desired activity; or
(3) are uncertain whether the activity requires a license within the financial legislation.
The purpose is to provide companies with an efficient process to clarify whether their activity requires a license.
Limitations may include, among other things, allowed number of customers and the scope of business. Companies participating in
FT Lab are subject to current legislation at all times, and companies depending on the specific agreement between the FSA and the company.
FEB 2018
(Click to view more info)
denmark
HKMA FinTech Supervisory Sandbox (FSS)
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Hong Kong Monetary Authority (HKMA)
• Guidelines
Sandbox Environment
Eligible firms include banks with FinTech and other technology initiatives to be launched in Hong Kong. Banks must also have certain safeguards in place related to the parameters of the pilot trial, customer protection measures, risk management controls and readiness and monitoring.
Examples of types of products that have been admitted into the FSS include biometric authentication, soft token, chatbot and distributed ledger technologies, among other technologies (e.g., API, notification service via social media platforms, RegTech).
The FSS is a pilot trial for initiatives involving actual banking services without the need to achieve full compliance with the HKMA’s usual supervisory requirements during the trial period. The FSS also includes a FinTech Supervisory Chatroom to provide feedback to banks and tech firms at an early stage of their projects.
SEPT 2016 (Initial launch)
2017 (Subsequent launch)
(Click to view more info)
Hong Kong
SFC Regulatory SandboX
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Securities and Futures Commission (SFC)
• Securities and Finance Ordinance (SFO)
Sandbox Environment
Available to FinTech firms that intend to provide a regulated product or service under the SFO. The firm must use innovative technologies and demonstrate a commitment to carrying on regulated activities through the use of FinTech.
The SFC may impose licensing conditions on qualified firms, which may include limiting the types of clients which the firm may serve or the maximum exposure of each client, so as to limit the scope and boundary of the firm’s business in regulated activities.
Licensing conditions may in some cases require the firm to put in place appropriate compensation schemes for investors, or to submit to periodic supervisory audits by the SFC. Qualified firms may be placed under closer monitoring and supervision by the SFC when they operate in the Sandbox.
SEPT 2017
(Click to view more info)
IA InsurTech Sandbox
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Insurance Authority (IA)
Sandbox Environment
The sandbox is available to InsurTech firms and other technology initiatives intended to be launched in Hong Kong by authorized insurers.
The InsurTech Sandbox is a regulatory sandbox for the insurance industry, with determinations of eligibility made on a case-by-case basis. When applying for admission into the sandbox, firms must define timing and duration, size and type of insurance business, technology involved, and expected outcome and success criteria of the trial. Further, firms must outline their risk management controls, customer protection policies, resources and readiness, exit strategy and other relevant considerations.
SEPT 2017
(Click to view more info)
Bank Indonesia Regulatory Sandbox
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
Sandbox Environment
Eligible FinTech firms must operate within the payments space or provide other related services, have innovative elements, provide utility for customers and/or the economy, be non-exclusive, provide widely-adopted solutions and implement risk identification and mitigation measures, along with other criteria considered important by BI. Firms that wish to enter the regulatory sandbox must also register with BI.
DEC 2017
(Click to view more info)
indonesia
MAS FINTECH REGULATORY SANDBOX
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Monetary Authority of Singapore (MAS)
Sandbox Environment
Any firm that is looking to apply technology in an innovative way to provide new financial services that are or are likely to be regulated by MAS (e.g. banks, securities/futures intermediaries, insurers, asset managers, and FinTech firms).
Companies receive a decision regarding their product’s suitability within 21 working days of applying for the sandbox.
The sandbox allows for service amendments during testing. Usual regulatory standards may be relaxed, on a case-by-case basis (e.g., asset maintenance, board composition, cash balances, credit rating, financial soundness, solvency & capital requirements, management experience, MAS guidelines, technology risk and management outsourcing).
In August 2019, the MAS launched Sandbox Express, which provides firms with a faster option to test innovative products and services in the market. Sandbox Express shortens the approval process for entry into the Sandbox for activities where the risks are low and well-understood by the markets (e.g., insurance brokers, recognised market operators and remittance businesses). Each vertical will have pre-defined boundaries, regulatory reliefs and expectations.
Firms can remain in Sandbox Express for up to 9 months.
NOV 2016
(Click to view more info)
SINGAPORE
Financial Regulatory Sandbox
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Financial Services Commission (FSC)
Sandbox Environment
Sandbox participants may test new services for a maximum of 2 years.
APRIL 2019
(Click to view more info)
south
korea
FINMA REGULATORY SANDBOX
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Swiss Financial Market Supervisory Authority (FINMA)
• Banking Ordinance (BO; SR 952.02)
Sandbox Environment
Banks and FinTech firms with innovative business models are eligible.
Participants may test and develop business models without blocking capital and incurring full licensing costs. Eligible participants are exempt from banking licensing requirements, and instead may operate under a FinTech license, or in a license-free innovation area (the sandbox). The requirements for obtaining a FinTech license are less restrictive than a traditional banking license.
In the sandbox, public deposits may be accepted without a license, up to a CHF 1 million limit, the funds may be invested and may bear interest (this was updated–previously this was not allowed–and will enter into force on 01 April 2019), even if such deposits come from more than 20 depositors. The participant may not engage in interest margin-based activities.
AUG 2017
(Click to view more info)
Switzerland
Financial Supervision Sandbox
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Financial Supervisory Commission
• Financial Technology Innovation and Experiment Act
Sandbox Environment
The sandbox is open to FinTech firms that offer innovative products and solutions. Factors to be considered for admittance into the sandbox include whether the testing will involve regulated financial services firms, if the product is innovative, the product or service’s potential to increase efficiency, potential risks, consumer protection measures and other matters deemed relevant.
FinTech firms will be granted relief from certain regulations during their time in the sandbox. This does not include regulations related to money laundering or terrorism financing.
JAN 2018
(Click to view more info)
Taiwan
FinTech Hub of Thailand (F13)
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Securities and Exchange Commission, Thailand
• Bank of Thailand
Sandbox Environment
Eligible firms include financial institutions that are licensed in Thailand (also, group companies that conduct financial business), non-financial institutions under the supervision of the Bank of Thailand (e.g., non-deposit taking businesses, like consumer finance), FinTech firms and other technology firms.
FinTech initiatives proposed by applicants must relate to: (1) lending payments; (2) fund transfers; and/or (3) other financial transactions that have similar characteristics to loans, payments and fund transfers.
Under the sandbox, participating firms are not fully subject to licensing/supervision requirements that are normally applicable. The cost of participation is free, including infrastructure and data that is supplied by F13’s partners.
DEC 2016
(Click to view more info)
THailand
BNM FINTECH REGULATORY SANDBOX
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Bank Negara Malaysia (BNM)
• Financial Sector Development Department
• Financial Technology Enabler Group (FTEG)
Sandbox Environment
FinTech firms, including those without a presence in Malaysia, may apply. Applicants must demonstrate that the product, service or solution is truly innovative, useful, functional and compatible with applicable laws and regulations. Applicants must also have the resources necessary for testing, a realistic exit strategy and credible management. Firms that collaborate with financial institutions and have the potential to create jobs in Malaysia will be looked upon favorably by the BNM.
Examples of products that have been approved include, among other things, remittance services, e-payment, InsurTech and financial advisory services.
Companies may participate in the sandbox for
OCT 2016
(FIRST PARTICPANTS LICENSED IN MAY 2017)
(Click to view more info)
Malaysia
AFM & DNB REGULATORY SANDBOX
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Authority for the Financial Markets (AFM)
• De Nederlandsche Bank (DNB)
Sandbox Environment
The sandbox is available to all FinTech firms wanting to roll out an innovative financial concept.
“Innovative Products” related to the financial sector are eligible.
JAN 2017
(Click to view more info)
Netherlands
RUSSIA'S REGULATORY SANDBOX
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Central Bank of Russia
Sandbox Environment
FinTech firms that provide innovative financial services, products and technologies are eligible for participation in the sandbox.
If testing is successful, the service or technology may be approved and regulators will develop draft action plans necessary for the introduction of such service or technology.
APR 2018
(Click to view more info)
Russia
BSL Sandbox Program
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Bank of Sierra Leone (BSL)
• Section 48, Banking Act 2011 and Section 49, OFS Act 2001.
Sandbox Environment
FinTech firms that are registered within Sierra Leone with at least 10% ownership by a citizen of Sierra Leone are eligible to participate in the sandbox. Licensed institutions may also apply to test new products and services that do not fit within existing regulatory frameworks. Applicants must demonstrate the potential for the product or service to advance financial inclusion, legal diligence, sufficient maturity of the product or service, sufficient resources, a clear exit strategy and credible management.
The BSL will modify regulatory requirements and develop testing requirements for products within the sandbox on a case-by-case basis.
APRIL 2018
(Click to view more info)
SIERRA
LEONE
FCA Regulatory Sandbox
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Financial Conduct Authority (FCA)
Sandbox Environment
The sandbox is open to authorized firms, unauthorized firms that require authorization and technology businesses. The sandbox seeks to provide firms with:
• the ability to test products and services in a controlled environment;
• reduced time-to-market at potentially lower cost;
• support in identifying appropriate consumer protection safeguards to build into new products and services; and
• better access to finance.
Eligibility criteria include whether the product or service is intended for the U.K. financial services market, novelty of the product or service, consumer benefits, necessity of participation in the sandbox and readiness for testing.
For sandbox participants, the FCA may be able to offer individual guidance, waivers or modifications to existing rules, no enforcement action letters or informal steers on potential regulatory implications of a new product or service.
JUNE 2016
(Click to view more info)
UK
Arizona’s FinTech Sandbox
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Arizona Attorney General's Office
• AZ – H.B. 2434
• Amended by AZ – H.B. 2177
Sandbox Environment
FinTech firms may participate regardless of whether they are licensed in Arizona. Eligible FinTech firms include those that offer innovative services related to credit extension (i.e. peer-to-peer lending or online marketplace lending), money transmission and investment management. Certain blockchain or cryptocurrency products may also be eligible.
The sandbox allows for the Attorney General’s Office to enter into agreements that allow Arizona sandbox participants to operate in other jurisdictions that establish similar programs.
The sandbox program ends July 1, 2028.
MAY 2018
(Click to view more info)
U.S.
SCA FinTech Regulatory Sandbox
Bahrain
CBB REGULATORY SANDBOX
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Central Bank of Bahrain (CBB)
Sandbox Environment
FinTech firms are eligible to participate.
The sandbox is open to existing solutions that have already been technically tested in a lab environment, as well as ideas yet to be developed and tested.
Companies are granted licenses to engage in the sandbox after an application process that verifies its security systems, policies, processes and controls to protect customers.
JUNE 2017
(Click to view more info)
Bahrain
Bermuda
Bermuda Insurance Regulatory Sandbox
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Bermuda Monetary Authority (BMA)
• Insurance Amendment Act, 2018; Insurance Act 1978
Sandbox Environment
InsurTech firms, insurance firms or affiliates of existing insurance firms are eligible. Proposed products or services should also be new or use existing technology in novel ways.
Firms will develop proof-of-concepts based upon parameters set by the BMA. The proof-of concept phase will typically be Upon completion of the proof-of-concept phase, the BMA will then decide whether it will offer the product or solution outside of the sandbox. If the product or service is approved, the BMA will award the firm a license in accordance with the company’s business model and existing insurance licenses.
July 2018
(Click to view more info)
Bermuda
Laboratory of Financial and Technological Innovations (LIFT)
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Banco Central do Brasil (supported by Fenasbac)
Sandbox Environment
Technology providers, academics and FinTech firms with solutions that align with the managing committee’s themes are eligible.
Themes for eligible projects will be provided by the managing committee on a rotating basis. The first themes included increased financial citizenship, more modernized legislation, a more efficient financial system and cheaper credit.
MAY 2018
(Click to view more info)
Brazil
MNB Innovation Hub
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Central Bank of Hungary (Magyar Nemzeti Bank)
Sandbox Environment
Available to FinTech firms, so long as the intention is to apply the innovation to Hungary.
The sandbox offers exemptions from certain regulations to facilitate the testing of new products or services (e.g., remote customer identification, debt cap rules, payment rules, total cost ratio rules, internal education systems rules, rules on handling client complaints, rules on classifying and assessing partners).
DEC 2018
(Click to view more info)
hungary
FSA FinTech Proof of Concept Hub
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Financial Services Agency (FSA)
Sandbox Environment
Eligible firms include FinTech firms, banks and other financial services firms. One example, accepted into the PoC Hub in November 2017, is a study group that aimed to build an advanced “Know-Your-Customer” platform using blockchain technology.
PoC Hub applicants must describe how the product or service would improve efficiency and production, and outline its planned tests within the PoC hub, how the product or service is innovative and planned consumer protection measures, among other things.
A team made up of members of the FSA will be assigned to support each project. The PoC Hub does not exempt participants from existing laws and regulations.
SEPT 2017
(Click to view more info)
Japan
Jordan’s Fintech Regulatory Sandbox
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Central Bank of Jordan
Sandbox Environment
FinTech firms within Jordan, and outside of Jordan working in collaboration with entrepreneurs in Jordan, are eligible to participate.
The FinTech Sandbox mainly targets innovative financial solutions that include money transfers, and enhancing security, efficiency and competition in providing such services.
There is a to innovate the solution. If successful, the owner can exit the FinTech Sandbox and proceed to the local market, subject to necessary approvals from the Central Bank of Jordan if needed.
APR 2018
(Click to view more info)
jordan
AFSA FinTech Regulatory Sandbox
Sandbox Nname
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Astana Financial Services Authority (AFSA)
Sandbox Environment
FinTech firms looking to apply FinTech to financial services in Kazakhstan are eligible.
JAN 2018
(Click to view more info)
Kazakhstan
Bank of Lithuania Regulatory Sandbox
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Central Bank of Lithuania
Sandbox Environment
FinTech firms with financial services, products or business models that are new to Lithuania’s market are eligible for the sandbox. Firms will be selected on various criteria, including genuine innovation, consumer benefit, need for testing in a live environment, product readiness and desire to provide financial services within Lithuania.
There is a If the Bank of Lithuania approves the product, the applicant may then decide whether to continue providing the service and obtain a license (if necessary).
OCT 2018
(Click to view more info)
Lithuania
MGA Sandbox Framework
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Malta Gaming Authority (MGA)
Sandbox Environment
FinTech firms with products or services related to digital assets and DLT, with a particular focus on the gaming industry, are eligible.
An approval to participate in the sandbox framework is conditional on the applicant holding the relevant license issued by the MGA, without prejudice to any other regulatory requirements stemming from other applicable legislation, including but not limited to the VFA Act and regulations issued thereunder.
An applicant may apply for its testnet to be included within the sandbox framework, on the condition that the live environment goes live by such time as the MGA may allow, which can be no more than 3 months after the approval is issued.
The Malta Gaming Authority will be accepting applications for the use of DLT Assets, directly or through third party service providers, by its respective licensees. subject to an extension if deemed fit by the MGA.
JAN 2019
(Click to view more info)
Malta
Regulatory Sandbox License
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Economic Development Board of Mauritius
Sandbox Environment
Both FinTech and non-FinTech firms are eligible. The sandbox is open to any innovative project for which there is no existing legal framework or adequate provisions.
however, firms must commence operation of business within 3 months of issuance of the license.
OCT 2016
(Click to view more info)
Mauritius
Incubator Sandbox
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Bank of Mozambique
• Mozambique Financial Sector Deepening (FSDMoz)
Sandbox Environment
FinTech firms, particularly with a focus on financial sector development and expanding financial inclusion for marginalized populations, or those not currently served by formal financial institutions, are eligible.
As an example of one testing period, three alternative payment systems were tested over a 6-month period.
MAY 2018
(Click to view more info)
Mozambique
Financial Industry Sandbox
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Central Bank of Nigeria (CBN)
Sandbox Environment
FinTech firms focused on innovating in the financial sector in Nigeria are eligible. CBN has partnered with the Bill and Melinda Gates Foundation to create a regulatory framework. One of the main focuses is on financial inclusion, so that innovative solutions can be developed to expand access to financial services for Nigeria’s population. The sandbox aims to provide an environment for FinTech firms to innovate freely and securely to test concepts.
MAR 2018
(Click to view more info)
Nigeria
Regulatory Sandbox
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Bangko Sentral ng Pilipinas (BSP)
• Philippine Securities and Exchange Commission (SEC)
Sandbox Environment
FinTech firms that engage in delivering products or services not otherwise regulated are eligible. Virtual currencies are an area of interest to the regulators.
The environment is a quasi-regulatory sandbox regime where a controlled environment is created for testing new FinTech. The FinTech firm operates under the supervision and monitoring of the BSP or the Philippine SEC (or both). Both timing and criteria for acceptance are largely assessed by regulators on
APR 2018
(Click to view more info)
Philippines
KNF Regulatory Sandbox
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Komisji Nadzoru Finansowego (KNF)
Sandbox Environment
Eligible entities include FinTech firms with untested innovative financial products based on information technologies, along with entities that provide innovative solutions to financial institutions and wish to conduct further testing to develop new products and services. Eligible entities must also have a registered office within Poland.
Criteria for inclusion within the sandbox include offering KNF-supervised products and/or services; innovative (or at least different) solutions; justifiable need to participate in the sandbox; and readiness for testing.
OCT 2018
(Click to view more info)
Poland
SAMA Regulatory Sandbox
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Saudi Arabian Monetary Authority (SAMA)
Sandbox Environment
The sandbox is open to innovators proposing non-regulated technology and/or proposing new digital business models. Applicants may fall into four categories, including: (i) SAMA-licensed innovators that wish to test solutions under existing regulatory frameworks; (ii) SAMA-licensed innovators that wish to test solutions that do not fit under existing regulatory frameworks; (iii) non-licensed Saudi FinTech firms; and (iv) non-licensed international FinTech firms.
Applicants must demonstrate that the product is genuinely innovative, provides consumer benefits and is ready for testing. Applicants must also provide an exit plan to deploy the solution if it is approved.
The sandbox allows for a
JAN 2018
(Click to view more info)
Saudi
Arabia
Financial Technology Sandbox
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Wyoming Banking Commissioner or Secretary of State
• Wyoming HB0057
Sandbox Environment
To be eligible, the FinTech firm must be a domestic corporation or other organized domestic entity with a physical presence, other than that of a registered office or agent, in Wyoming.
Only innovative financial products or services which cannot be made available under existing law are eligible for the financial technology sandbox.
FEB 2019
(the law takes effect
on Jan 1, 2020)
(Click to view more info)
Brazil
Hungary
Japan
Jordan
Kazakhstan
Lithuania
Malta
Mauritius
Mozambique
Nigeria
Philippines
Poland
Saudi Arabia
• Bank Indonesia (BI) (Central Bank)
• Reg. No. 19/12/PBI 2017 of the Organization of Financial Technologies
Additional U.S. Regulatory Sandboxes
Additional U.S. Regulatory Sandboxes
OJK Regulatory Sandbox
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Otoritas Jasa Keuangan (OJK)
• OJK Regulation No. 13/POJK.02/2018 (on Digital Financial Innovation in the Financial Services Sector
Sandbox Environment
Eligible firms include FinTech firms and other firms that operate in the financial services space and engage in FinTech related activities (i.e. crowdfunding, settlement, peer-to-peer lending, AI, InsurTech, among other things).
AUG 2018
(Click to view more info)
Additional Indonesia Regulatory Sandboxes
Additional Indonesia Regulatory Sandboxes
Additional Hong Kong Regulatory Sandboxes
Additional Hong Kong Regulatory Sandboxes
Additional Hong Kong Regulatory Sandboxes
Additional Hong Kong Regulatory Sandboxes
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Eligible Products
More information and FAQs
Live testing within a controlled experimental environment.
6-month testing period, which can be extended in exceptional cases.
Live and virtual testing within a controlled experimental environment.
Testing may last for a period between 3 and 9 months, which can be extended for a period of up to 12 months, subject to KNF approval.
Live testing within a controlled experimental environment.
Live testing within a controlled experimental environment.
Live testing within a controlled experimental environment.
The length of the testing period varies.
Live testing within a controlled experimental environment.
There is no specified time period for the sandbox;
Live testing within a controlled environment.
Live testing within a controlled experimental environment.
Live testing within a controlled experimental environment.
The length of the testing period will be decided on a case-by-case basis.
Live testing within a controlled experimental environment.
Testing within a controlled environment.
Live testing of products or services on real customers.
Live testing within a controlled environment.
.
Live testing within a controlled environment.
Live, but limited environment of select users.
The duration of the sandbox is 9 months with a maximum extension of 3 months.
Live testing under controlled conditions.
Testing within the sandbox is intended for a limited duration, which has typically been for between 3-6 months.
Live testing within a controlled environment.
The initial testing period will not exceed 12 months unless it has been determined that additional testing is needed.
Live testing within a controlled environment.
Live testing within a controlled environment.
Duration is on a case-by-case basis.
Live testing within a controlled environment.
Live, but limited environment of volunteered customers.
The scope and duration of participation in the sandbox will be determined on a case-by-case basis.
Live experiments in confined spaces.
The duration is limited to 1 year, but can be extended up to 3 years.
Live testing within a controlled environment.
Live testing with regulatory exemptions.
Live testing within a well-defined space and duration.
Live testing with actual, but controlled group of market participants.
Live testing within a controlled experimental environment.
between 6 and 12 months.
Live testing with actual, but controlled group of market participants.
Live testing with actual, but controlled group of market participants.
(limits have ranged from 12-24 months).
Live testing of products or services on real customers.
may expect to test for up to 6 months
Controlled environment for firm to develop and test FinTech ideas.
Live testing with limited customers.
Live testing with limited customers.
Live, real market data for a trial term.
Live environment supervised by Bank Indonesia.
The trial period will last for a period of 6 months, which can be extended one time for a maximum of 6 months, if necessary.
Live testing within a controlled environment.
The testing period will last for a maximum period of 1 year, which can be extended for 6 months, if necessary.
The testing period is decided on a case-by-case basis.
9-month maximum experimentation stage
6-month testing period with a possibility of extension of up to 12 months.
a testing period of no more than 12 months.
This phase is planned to last for a period of 10 months,
a case-by-case basis.
The initial testing period will not exceed 12 months unless it has been determined that additional testing is needed.
Live testing within a controlled experimental environment.
6-12 months,
Live testing with limited market access.
Sandbox participants will have 24 months after approval date to test their innovative financial product or service (possible extension of up to 1 year upon request to the Attorney General’s office).
Live testing under controlled conditions.
Testing will last for up to 2 years with the possibility of a 1-year extension.
2-year period to develop, test and launch their products and services
Additional U.S. Regulatory Sandboxes
Regulatory Sandbox Program
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Utah Department of Commerce
• UT – H.B. 378
Sandbox Environment
As part of the application process, applicants must, among other things, establish a physical location in Utah from which testing will be developed and performed, demonstrate sufficient resources for sandbox participation and submit a report detailing how the product or service will be tested that includes statements on matters such as consumer protection, market benefits and novelty.
Products and services tested within the sandbox environment may only be offered to Utah residents. On a case-by-case basis, the Department of Commerce may cap the number of consumers that may use the product or service, the maximum amount of individual loans provided or the maximum amount of a single transaction for an individual consumer.
Sandbox participants are also required to provide proper disclosures to consumers before offering the product or service.
Sandbox participants will be granted 24 months following the day on which the application was approved to test the product or service. The Department of Commerce may grant an extension of no more than 6 months following the conclusion of the testing period.
Live testing under controlled conditions.
july 2019
(Click to view more info)
Additional U.S. Regulatory Sandboxes
Additional U.S. Regulatory Sandboxes
Barbados Regulatory Sandbox
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Central Bank of Barbados (CBB)
• Financial Services Commission (FSC)
Sandbox Environment
The sandbox is open to FinTech firms with a product or service:(1) where there is ambiguity as to the appropriate regulatory regime for the product or service (i.e. deposit-taking or the provision of investments or payment services between third parties);(2) that uses unproven technologies whose failure could pose risks to consumers or financial stability; (3) where there have been adequate and appropriate assessments to demonstrate the usefulness and functionality of the product or service and to understand the appropriate risks; and (4) where the firm has demonstrated possession of the necessary resources (i.e. financial and human) to participate in the sandbox and has demonstrated the ability to mitigate and reasonably control potential consumer risks and losses from activity that may occur while participating in the sandbox.
Terms and conditions of participation in the sandbox will be determined by a Regulatory Review Panel (RRP) in consultation with the applicant.
Within 30 working days following the completion of the testing period, the RRP will draft a report that, among other things, will recommend whether or not the product or service should be licensed.
The RRP may require an extension of a participant’s testing period if it determines that there is insufficient information to make a determination. Participants may also request an extension using the same notification requirement.
The length of the testing period will be decided on a case-by-case basis.
Live testing within a controlled environment.
October 2018
(Click to view more info)
BARBADOS
Barbados
Kenya
CMA Regulatory Sandbox
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Capital Markets Authority (CMA)
• Regulatory Sandbox Policy Guidance Note
Sandbox Environment
The sandbox is open to FinTech firms (including firms that already operate under a license issued by the CMA) that (i) are incorporated in Kenya or licensed by a securities market regulator in an equivalent jurisdiction; and (ii) intend to offer an innovative product, service or solution in Kenya following successful completion of the testing period.
As part of the application process, applicants must submit to the CMA a testing plan that outlines key objectives, testing metrics/performance indicators, testing methodologies, scope and testing parameters, the proposed testing period, feedback mechanisms, safeguards and remediation measures.
Throughout the testing period, sandbox participants will be required to submit periodic reports to the CMA assessing its progress. Participants are also required to submit a safeguard and supervision plan and commit to implementing such plan for the duration of the testing period.
The length of the testing period will be decided on a case-by-case basis.
Limited scale, live testing.
MARCH 2019
(Click to view more info)
Kenya
Kuwait
CBK Regulatory Sandbox
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Central Bank of Kuwait (CBK)
Sandbox Environment
The sandbox is open to both firms and individuals striving to provide innovative FinTech products or services that are based on, or relevant to the electronic payment of funds either by using new technologies or using existing technologies in an innovative way.
Applications will be assessed based on the following eligibility criteria: (i) whether the product or service is innovative and will be deployed in the local market; (ii) value proposition for both consumers and markets; (iii) readiness to test, which requires the applicant to provide a complete testing plan, customer protection plan and assessment report of emerging risks; and (iv) the applicant’s deployment plan.
The sandbox process is broken down into three stages, which include: (i) an evaluation stage; (ii) the experimentation stage; and (iii) an accreditation stage. During the accreditation stage, the CBK may grant either final approval, grant initial approval or reject the product or service.
The maximum duration to complete all stages of the sandbox is 1 year,
Live testing within a controlled environment.
November 2018
(Click to view more info)
KUWAIT
with the possibility of an extension based on CBK discretion.
ICO Sandbox
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Information Commissioner’s Office (ICO)
Sandbox Environment
The sandbox is intended for firms that use personal data to develop innovative products and services that provide a demonstrated public benefit. The ICO will consider applications from startups, SMEs and large organizations across the private, public and voluntary sectors. Such entities must be subject to U.K. data protection laws.
Applications will be assessed based on whether the product or service is innovative and can provide a potential demonstrable benefit to the public (including both the amount of people benefiting and the extent to which they benefit). The ICO will also consider: (i) whether the product or service addresses key areas of challenges to innovation; (ii) whether the entity has been involved in any recent data protection incidents; (iii) if the ICO can meet the resources and capabilities required to collaborate with the entity; and (iv) the viability of the organization’s proposed sandbox plan.
Sandbox participants will receive a statement of “comfort from enforcement,” which will state that any inadvertent violation of the U.K.’s data protection legislation as a result of the product or service will not immediately lead to regulatory action during the time in the sandbox. The ICO will also provide informal advice to sandbox participants as part of each participant’s bespoke sandbox plan.
For the beta phase, the first round of participants may participate in the sandbox for a period of no longer than 15 months.
Live or simulated testing under controlled conditions.
March 2019
(beta phase)
(Click to view more info)
Additional U.K. Regulatory Sandboxes
Additional U.K. Regulatory Sandboxes
FinTech firms or financial institutions may apply for participation in the regulatory sandbox. Such entities must offer financial services that are different from existing services in content, method and form.
Applications will be reviewed by a committee established by the FSC. As part of the application process, applicants are required to submit plans for consumer protection and risk management while taking part in the sandbox. The committee approved 9 firms to participate in the first round of testing in April 2019.
Sandbox participants may test new services for a maximum of 2 years.
Insurance Innovation Sandbox
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Kentucky Department of Insurance
• KY – H.B. 386
Sandbox Environment
The Insurance Innovation Sandbox allows for beta testing of innovative insurance products or services under limited no-action letters.
Applicants must describe the risks and benefits of the product or service, the current statutory or regulatory issues that prevent the innovation from being utilized, how the innovation functions and if the innovation involves the issuance of an insurance policy, among other things. Applicants must also include a statement by an officer certifying that there are no substantially similar products or services to the innovation available in Kentucky and a statement that the applicant has at least $25,000 available to ensure financial stability.
Participants in the Insurance Innovation Sandbox must utilize the innovation within Kentucky and agree to monthly reporting obligations and certain consumer protection measures. The Commissioner of the Department of Insurance may impose limits on the financial exposure that may be assumed by an application or its clients during the beta test, the number of customers an applicant may accept and the volume of transactions the application or its clients may complete during the beta test.
The sandbox program ends December 31, 2025.
The test period will be for 1 year. Upon request, the time period may be extended for a period of no more than 1 year.
Live testing under controlled conditions.
juNE 2019
(Click to view more info)
Additional U.S. Regulatory Sandboxes
Additional U.S. Regulatory Sandboxes
Insurance Regulatory Sandbox
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Vermont Department of Financial Regulation
• VT – S.131
Sandbox Environment
As part of the application process, applicants must, among other things, establish a physical location in Utah from which testing will be developed and performed, demonstrate sufficient resources for sandbox participation and submit a report detailing how the product or service will be tested that includes statements on matters such as consumer protection, market benefits and novelty.
Products and services tested within the sandbox environment may only be offered to Utah residents. On a case-by-case basis, the Department of Commerce may cap the number of consumers that may use the product or service, the maximum amount of individual loans provided or the maximum amount of a single transaction for an individual consumer.
Sandbox participants are also required to provide proper disclosures to consumers before offering the product or service.
Sandbox participants will be granted 24 months following the day on which the application was approved to test the product or service. The Department of Commerce may grant an extension of no more than 6 months following the conclusion of the testing period.
Live testing under controlled conditions.
February 2019
(effective January 2020)
(Click to view more info)
Additional U.S. Regulatory Sandboxes
Additional U.S. Regulatory Sandboxes
India
IRDAI Regulatory Sandbox
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Insurance Regulatory and Development Authority of India (IRDAI)
Sandbox Environment
Applicants should seek to promote or implement innovations in insurance related to insurance solicitation or distribution, insurance products, underwriting, policy and claims servicing or any other category recognized by IRDAI.
Applicants must also demonstrate that the innovation is beneficial to insurance in India, is in the interest of policyholders, is conducive for the orderly growth of the insurance industry in India, would promote an increase in insurance penetration in India and meets any other requirements specified by IRDAI.
During the test phase, participants must ensure that the integrity of the system is maintained at all times, confidentiality of policyholder data is maintained and that adequate internal mechanisms are put in place for reviewing, monitoring and evaluating controls, systems, procedures and safeguards.
The testing period will last for a period of 6 months, which can be extended by no more than 6 months, if deemed necessary.
Live testing of new products or services in a relaxed regulatory environment.
AUGUST 2019
(Click to view more info)
RBI Regulatory Sandbox
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Reserve Bank of India (RBI)
Sandbox Environment
Applicants must demonstrate that there is an absence of regulations governing the product or service, that there is a need to ease regulations for enabling the proposed innovation and that the proposed innovation demonstrates the potential to ease delivery of financial services in a significant way.
Applicants are also required to be incorporated and registered in India or a bank licensed to operate in India, have a minimum net worth of Rs. 25 lakh, show that the product or service is ready for deployment in the broader market and demonstrate arrangements to comply with existing laws and regulations, among other things.
The RBI will consider products and services related to retail payments, money transfer services, marketplace lending, digital KYC, financial advisory services, wealth management services, digital identification services, smart contracts, financial inclusion products, cybersecurity products, mobile technology applications, data analytics, API services, applications under blockchain technologies and AI and ML applications.
The RBI will not consider products or services related to digital assets and initial coin offerings.
Sandbox cohorts will typically be completed within 6 months, although they may run for varying time periods. Participants may request extensions if deemed necessary.
Live testing of new products or services in a controlled regulatory environment.
August 2019
(Click to view more info)
Additional India Regulatory Sandboxes
INDia
Additional India Regulatory Sandboxes
FinTech firms that meet the following conditions: (1) have no more than 100 retail clients (unlimited wholesale clients); (2) plan to test for no more than 24 months; (3) have total customer exposure of no more than AUD5 million; (4) have adequate compensation arrangements (such as professional indemnity insurance); (5) have dispute resolution processes in place; and (6) meet disclosure and conduct requirements.
• Deposit products with a maximum AUD10,000 balance
• Payment products, if ADI-issued and with a max AUD10,000 balance
• General insurance, for personal property and home contents and with a max of AUD50,000 insured
• Liquid investments for listed Australian securities or simple schemes and with a max AUD10,000 exposure
• Consumer credit contracts with certain features, and a loan size between AUD2,001 and AUD25,000
The sandbox framework provides three options for testing a new product or service without a license: 1) relying on existing statutory exemptions or flexibility in the law (i.e., acting on behalf of an existing licensee); (2) relying on ASIC’s ‘fintech licensing exemption’ for testing of certain specified products and services; and (3) for other services, relying on individual relief from ASIC.
Digital Currency Innovation Lab
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Hawaii Department of Commerce and Consumer Affairs (DCCA)
• Hawaii Division of Financial Institutions (DFI)
• Hawaii Technology Development Corporation (HTDC)
Sandbox Environment
Any company looking to engage in digital currency transactions in Hawaii can apply for admission into the program. Applicants must demonstrate that they have the necessary capital, personnel, financial and technical expertise to provide their services, and upon admission must also provide DFI with necessary data following DFI’s stipulated timeline.
Participants in the Digital Currency Innovation Lab may conduct digital currency transactions without enforcement for what DFI would consider unlicensed activity. However, participants are still subject to other federal and state laws.
There is no limit to the number of customers or value of digital currency transactions during the participation period.
Live transactions in a relaxed regulatory environment.
March 2020
(Click to view more info)
Additional U.S. Regulatory Sandboxes
Additional U.S. Regulatory Sandboxes
Sri Lanka
Egypt
Jamaica
FinTech Regulatory Sandbox of the Central Bank of Sri Lanka
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Central Bank of Sri Lanka (CBSL)
Sandbox Environment
Eligibility will be assessed based upon whether the product is innovative, has been thoroughly tested and provides clearly identifiable benefits to customers. The Sandbox is open to both local and foreign applicants, but all Sandbox applicants other than a CBSL licensed financial institution must partner with a CBSL licensed financial institution in order to be considered for entry into the Sandbox.
Applicants are also required to identify and divulge any potential risks to financial institutions, their customers and the financial system stability of Sri Lanka. They also must state the dispute resolution mechanisms and customer protection safeguards and countermeasures put in place for the avoidance or mitigation of such risks.
Live testing of products or services on real customers.
MARCH 2020
(Click to view more info)
SRI LANKA
Bank of Jamaica FinTech Regulatory Sandbox
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Bank of Jamaica
Sandbox Environment
Live testing within a controlled environment.
(Click to view more info)
JAMAICA
March 2020
Regulated entities, including deposit taking institutions (DTIs), cambios, remittance service providers and securities dealers authorized by the Financial Services Commission of Jamaica (FSC), along with FinTech companies in partnership with a DTI, will be eligible to participate in the Sandbox. Applicants must demonstrate that they meet a number of requirements related to (i) innovation; (ii) consumer, country and regional benefit; (iii) need for participation in the Sandbox; and (iv) testing readiness.
Participants must comply with a number of safeguards including those related to client limits, exposure limits, consumer protection, dispute resolution, risk management controls and readiness and monitoring.
Sandbox Name
Governing Commission, Law & Regulatory Guidelines
Launch Date
• Central Bank of Egypt (CBE)
Sandbox Environment
The Regulatory Sandbox employs a cohort-based model, open to any commercially registered FinTech company and any other licensed financial institutions, including banks. Applicants will be qualified to enter the Regulatory Sandbox under the condition that the innovative product, service or solution is (i) within the scope of FinTech services; (ii) genuinely innovative with clear potential to improve accessibility and efficiency in the provision of financial services; (iii) beneficial to customers either directly, or via heightened market competition; (iv) in real need of the Regulatory Sandbox; (v) ready for experimentation under the Regulatory Sandbox with a realistic and well-developed business plan; and (vi) supportive of financial inclusion in Egypt.
The maximum and minimum number of customers and transaction value and volume must be approved upon application, and participants will be required to source customers themselves for testing in the Regulatory Sandbox. Participants must also put in place appropriate customer safeguards and protection measures during participation in the Regulatory Sandbox.
Live testing within a controlled experimental environment.
JUNE 2019
(Click to view more info)
CBE Regulatory Sandbox
EGYPT
The Sandbox testing period will last a maximum of 9 months, although participants have the option of requesting an extension during that stage.
The sandbox allows FinTech firms to test services for up to 24 months with up to 100 retail clients, as long as total customer exposure doesn’t exceed AUD5 million.
Upon approval, applicants will participate in the Regulatory Sandbox for a fixed duration. Generally, the duration of this process is 6 months, and can be extended to be up to 12 months based on the testing process requirements.
The testing period shall not exceed 24 months from a participant’s start date, with the possibility of an extension if deemed necessary to respond to specific issues or risks identified during initial testing.
Upon acceptance into the program, participants will be given 24 months to engage in digital currency transactions.
