Innovation Pathways eligibility criteria

For us to support a proposal, it needs to be within our remit. That means it must relate to our rules in some way. Not all financial services companies are regulated by us, so the problem or issue you come to us with needs to be something we have the power to help with. 

For example, we can help with working out whether a business model needs our authorisation or whether a particular rule applies to a business model we haven’t seen before.
 

We take a broad view of innovation. This means that a product doesn’t have to be completely unprecedented. Innovation is subjective and we weigh up a few things when making a judgment on whether something is innovative. For example, we look at how similar the proposal is to its competitors, or whether there are any existing products to compare it to.

If you’re considering applying for support from Innovation Pathways, you should set out the case for why your proposal is innovative and explain this clearly when drafting your request. You should consider whether there are other firms in your sector and who your direct competitors are (if any), and then explain why your business is significantly different.

To be eligible for Innovation Pathways support, you must demonstrate that your innovative business or service aims to benefit consumers. 

For example, that could be by making existing products or services cheaper, quicker, more secure, or more effective. It could be by making them accessible to previously underserved customers, or by providing something that isn’t currently available. 

You must be able to explain who will benefit and how. We also expect you to have considered the potential risk of harm and how this weighs up against the potential benefits.

When applying, you should provide as much evidence as you can, for example, by providing comparative prices or by explaining how underserved groups will benefit.

We include businesses themselves in our definition of ‘consumer’ and, as such, are happy to support B2B services that meet our eligibility criteria.

Readiness means having a proposal that is developed to the point where we can realistically help you with it. We would expect you to carry out background research and make a good faith attempt to understand your regulatory obligations before requesting our support. 

We want firms to come to us with defined questions and specific problems that they need our help with. While we would like to support every firm that demonstrates genuine innovation and consumer benefit, we’re a small team and we don’t have the resource to advise every firm we see on every step of the regulatory regime. 

We can provide the most value where you have identified regulatory ambiguity or uncertainty. Researching the regulatory landscape before requesting Innovation Pathways support should help you narrow or even resolve your questions. 

We have produced volumes of guides and introductions to regulation. You can help us to help you by reading our guidance and coming to us with questions that can’t be answered elsewhere.

Read our existing guidance[4].

To be eligible for Innovation Pathways support, you need to be able to explain why you need it. You might have limited resources, for example, or you might have a complex regulatory question. There might be an FCA rule that we need to clarify in response to a technological development that has created a regulatory grey area. It could be that your new business model doesn’t fit neatly into any existing regulatory category, or that our existing rules don’t cover a particular situation. 

Since we’re responsible for our rules, we may be able to provide greater certainty on where an innovative model sits. However, it’s important to remember that we aren’t a replacement for legal or compliance advice.

Firms at different stages of development may have different needs. For example, a large, established financial services firm wouldn’t need to be pointed towards relevant guidance, but a small start-up with lots of experience in technology but little direct exposure to financial services might.