The Financial Markets Authority (FMA) released a consultation on the standard licence conditions for market services licences. The FMA’s submission form is available here and its consultation paper is available here.
The consultation closes on 11 December 2026.
The proposal aims to consolidate all the standard conditions into a single document for ease of access. The changes cover all licensed market services, making the standard conditions more navigable for licensees operating multiple market services.
Who needs to read it? Why?
The changes affect all market services licensees – with consumer credit providers facing a new set of standards for the first time. Therefore, it is important that all licensees (and all those authorised under a licence) read the consultation paper and submit their views on how the proposed changes impact their business.
What does it cover?
Currently, the FMA imposes a separate set of standard conditions on each type of licensed market service, creating overlap and complexity, particularly for licensees that hold two or more market services licences. The FMA is proposing to consolidate all standard conditions into a single document and align them across licensed market services, with some conditions continuing to apply only to specific services.
A notable feature of the proposal is the imposition of six new standard conditions (business continuity and technology systems, internal complaints process, ongoing requirements, outsourcing, record keeping, and regulatory returns) on creditors under consumer credit contracts, who became subject to FMA licensing and supervision from 1 July 2026.
The FMA is also proposing to revoke five existing standard conditions: compliance, governance arrangements, notification of material changes, professional indemnity insurance for independent trustees, and skills and expertise. Compliance and governance arrangements will both be replaced by the existing ongoing requirements condition, while reliance for notification of material changes will instead be placed on reporting obligations under the FMC Act, FMC Regulations and regulatory returns. These changes are intended to reduce duplication and compliance burden without materially affecting the FMA's ability to monitor licensees.
Once finalised, the new standard conditions will replace all existing standard conditions, with the FMA proposing a six-month implementation period following formal notice, to give licensees time to update their policies, processes, systems and controls.
What next?
We welcome the FMA's efforts to harmonise the standard conditions across licensed market services, which should reduce duplication and make compliance more straightforward for licensees holding multiple licences.
That said, given the breadth of licensees affected and the specific questions the FMA has posed on each condition, licensees operating under any market services licence – and particularly consumer credit providers facing new conditions for the first time – should review the proposals closely and consider making a submission.
If you have any questions about the upcoming changes to the standard licence conditions and how they might affect your business, please contact one of our experts.
To learn more on the FMA's consultation and proposed changes, our Banking and Finance team have delved into the detail - read their update here.
This article was co-authored by Sarah Waller, a Solicitor in our Financial Services team.
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