Innovation Pathways eligibility criteria

Check whether your firm meets our eligibility criteria before applying for support, and find out what we look for when assessing your proposal.

Innovation Pathways aims to help firms understand FCA rules and our regulatory regime. We can support firms of any size, whether you're a current financial services provider, an existing firm newly entering the financial services sector, or a start-up that is yet to launch.

If you want to apply for our support, you must meet our 5 eligibility criteria:

in scope
genuine innovation
consumer benefit
readiness
need for support

Below, we explain what these criteria mean and what we look for when assessing whether your firm’s proposal meets them. Unfortunately, we can’t support everyone who applies, so please help us by providing as much information as possible about how you meet our criteria.

Eligibility criteria.
How we decide if criteria is met.
Examples of proposals that may meet each criteria.

If you think you meet these criteria, find out how to apply[2].

Eligibility criteria

The application form includes space for you to explain how your proposition meets our eligibility criteria. The table below includes information on each of the criteria:

Criteria	Key questions	Positive indicators	Negative indicators
In scope	Are you doing something that is within our remit? Will your customers be in the UK?	Your proposal is intended for the UK market and customers. The relevant activity is regulated by us or may be used by firms we regulate.	Your innovation doesn’t appear to be intended for use in the UK.
Genuine innovation	Are you doing something that’s ground-breaking or significantly different? This could be something completely new, or it could be a new market or a new version of an existing model.	Desk research produces few or no comparable examples of innovation in the market. Your proposal is a novel way of providing an existing service – for example, a digitised version of an older model. You are offering a model we wish to encourage, such as automated advice for lower-income consumers.	There are numerous examples of similar offerings already on the market. Your proposal appears to be only superficially different from existing services.
Consumer benefit	How does your proposal help consumers (either individuals or businesses)? How is it an improvement on existing services? How will you protect consumers from any risks your model poses?	Your business will provide services cheaper, quicker, more securely, higher quality or more reliably. You’ve thought about your target market, identified risks and have thought about how to protect consumers Your proposal will promote competition – for example, by making it easier to enter the market, or making it easier to comply with our rules. Your business model promotes diversity and inclusion - for example, targeting underserved or unserved consumers	Your proposal has a potential detrimental impact on consumers, markets or the financial system. Your proposal is more expensive than existing services, is slower, and has no corresponding benefits that make up for this. Your proposal looks designed to circumvent FCA rules.
Readiness	Have you thought about how your proposition works with our rules? Have you carried out any background research into the regulations that might apply to your business? Can you explain how your business will work? Do you have a clearly defined issue we can help you resolve?	Your business can be clearly and coherently described, including how it works, how it makes money, and what your market will be. You have made a good faith effort to research and understand how our rules apply to your model. You have a specific issue you are seeking our help with.	Your proposal is not clearly defined. You have made no effort to undertake background research or understand our rules.
Need for innovation support	Do you have a genuine need for regulatory support through the Innovation Pathways?	The innovative nature of your business means that it may be unclear how our rules apply to your firm – for example, whether you need to be authorised or what kind of authorisation is needed. Your business has no alternative means of engaging with the FCA Your innovation does not easily fit the existing regulatory framework Your question is one that your existing FCA Supervisor (if you have one) can’t answer.	You have a vague or broad question (for example ‘please help me identify all the rules I need to comply with’). You are asking us to endorse or to promote your business. Your queries would be more suitable for a compliance consultant – for example, ‘can you help me draft my compliance manual’.

You can also access the full eligibility criteria[3] (PDF).

How we decide if criteria is met

How we decide whether something is in scope

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.

How we decide whether something is genuinely innovative

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.

How we decide whether something has consumer benefit

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.

What does readiness mean?

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].

How to demonstrate a need for Innovation Pathways support

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.

Examples of proposals that may meet each criteria

In scope Genuine innovation Consumer benefit Readiness Need for innovation support

In scope

Small tech company seeking to launch a payments service using Open Banking and aimed at UK customers.
US tech company wanting to expand into the UK and Europe with its share trading app.
Company seeking to provide KYC / AML technology to FCA-regulated firms.

Genuine innovation

Automated advice platform seeking guidance on the advice boundary.
Payments solution making use of stablecoins.
Debt advisor making use of open banking data to assess a consumer’s financial position.
Technology company developing a distributed ledger to speed up share settlement & execution.

Consumer benefit

Savings platform aimed at unbanked or underbanked consumers.
Technology solution using social media and banking data to detect vulnerable consumers.
Platform for low-cost, high-speed cross-border remittance.

Readiness

A firm has reviewed what regulated activities might apply to their business, and has given a view of whether or not they apply.
A firm has targeted questions (for example, whether their guidance platform strays into regulated advice).

Need for innovation support

Clear questions as to whether an innovative model needs to be authorised.
A firm whose model makes it unclear what kind of authorisation is required.

24/07/2026 : Editorial amendment formatting, right hand menu updates

05/01/2026 : Editorial amendment Update to right hand navigation menu

28/10/2025 : Technical update: no content changed

10/02/2023 : Editorial amendment page updated as part of website refresh

First published: 27/03/2022 Last updated: 24/07/2026 See all updates