CMA FinTech Experimental Permit

What the permit is

The Financial Technology Experimental Permit is granted under the CMA's FinTech Experimental Permit Instructions, issued by Board Resolution 1-4-2018 and updated by Resolution 2-9-2021. The Lab opened in 2018 and took its first batch of applications in February that year.

Anyone may apply, including a firm that is not a capital market institution, provided the product it wants to test relates to securities activities. A CMI that already holds the authorisation the product needs does not need a permit. A product that is mature and can comply with the full rules is expected to apply for a capital market institution licence instead.

Eligibility: what the CMA tests

• The product involves a securities activity.
• It is genuinely innovative.
• It brings benefits to the market, to compliance or to clients.
• It is developed far enough to be tested with real clients.
• The applicant has adequate resources, is fit and proper and acts with integrity.
• The applicant has done its own regulatory due diligence.
• There is a client exit strategy if the test ends.

How an application runs

1. Submit the application

   Applications go in on the CMA's "FINTECH application" form by email to the FinTech Lab. They are accepted all year but assessed in announced batches; the eighth review had a cut-off of 31 December 2024.

2. Eligibility and conditions

   The CMA confirms eligibility and sets additional requirements for your test: client numbers and types, transaction sizes, suitability, protection of client assets, data, promotions, capital if any, and reporting.

3. Permit granted

   The CMA issues the permit with those conditions attached.

4. Commencement-of-business requirements

   Within the period the CMA sets, you establish a Saudi commercial entity, adopt conflict-of-interest policies, comply with the AML and counter-terrorist financing laws, test information security, and put key agreements and outsourcing governance in place.

5. Approval to start

   The CMA must approve before you begin operating with clients.

Rules while you hold a permit

• Suspensions of the test may not total more than three months.
• No gifts or incentives to clients.
• No loss-sharing arrangements with clients.
• Owners may not exit the business during the permit period.
• The permit conditions on client numbers, transaction sizes and reporting apply for the whole test.

Duration, extensions and moving to a full licence

A permit lasts up to two years from commencement of business. An extension request must be filed at least three months before expiry, and the CMA grants extensions only in exceptional cases. At expiry the firm either runs its client exit strategy or obtains a full licence.

Debt-instrument crowdfunding shows how the move works. The model was tested in the Lab from the second quarter of 2021 and became a licensed activity in September 2025. Existing permit holders may continue until their permits expire and must then hold an Arranging licence, and the CMA now accepts new Lab applications for that model only where there is an innovative element to test. Robo-advisory, also tested in the Lab, became a regulated service in March 2026. See crowdfunding and robo-advisory.

Plan the licence file during the test. The CMI licence needs capital, a permitted legal form for some activities, registered persons who have passed the CMA exams, and the Annex 3.1 documents, none of which you want to start in the last six months of a permit.

How many permits: the numbers count different things

The first three figures are cumulative permit totals since 2018. The 45 is a count of companies currently listed. A cumulative total keeps permits that have since ended, been cancelled or been replaced by a full licence, so the two series should not be compared as if they measured the same thing.

What firms test in the Lab

The live list covers debt instruments, fund distribution, robo-advisory, social trading, artificial intelligence in advisory, and a model the CMA calls "Stock Ownership Transfer". Earlier permits, listed in 2021, covered equity crowdfunding, robo-advisory, debt instruments, social trading and a platform using distributed ledger technology to arrange and offer securities and provide custody.

The CMA's list does not describe the technology behind the Stock Ownership Transfer model, and the CMA has issued no rules on tokenisation. A Lab permit is a test permission for a named product. It does not create a digital-asset licence.

Recent permit decisions

The April 2026 draft update is not adopted

On 26 April 2026 the CMA consulted on new FinTech Experimental Permit Instructions (CMA_N_4030, consultation closed 27 May 2026). The FinTech Lab page still links only the 2021 Instructions, and we found no approval announcement, so the 2021 text governs applications today.

The draft would move from batches to year-round submission and assessment, widen the scope to technology-based products related to securities business or the capital market, let the CMA charge a fee, impose a three-month wait before reapplying after a rejection (with all earlier observations addressed), and add governance and business-continuity requirements. The two-year validity is unchanged in the draft.

Common questions