New Zealand's Financial Service Providers Register is a public register maintained under the Financial Service Providers (Registration and Dispute Resolution) Act 2008 (the FSP Act). FSPR registration alone provides no licence, FMA assessment, or supervised status. The register publishes this warning on its website.
For certain financial services, a separate licence from the FMA or the Reserve Bank of New Zealand is required in addition to FSPR registration. A provider that performs a licensed service without the relevant licence lacks the required authorization. The FMA can also direct the Registrar to deregister providers whose presence on the register creates a false impression of New Zealand regulation. The most recent deregistration notice, published on August 19, 2026, covered 132 providers.
New Zealand therefore operates a two-step structure: registration with the Companies Office, followed by licensing where the service requires it. This distinction also separates the FSPR from payment licensing regimes in other jurisdictions that grant a specific operating authorization.
What Is the Financial Service Providers Register (FSPR)?
The FSPR is an online register of individuals, businesses, and organizations that provide financial services in New Zealand. The Registrar of Financial Service Providers, who sits within the Companies Office (part of the Ministry of Business, Innovation and Employment), maintains it. The FMA plays no role in administering the FSPR. This is a common error in third-party guides and matters because it blurs the line between registration and licensing.
The register records each provider's name, business address, registered financial services, and dispute resolution scheme membership. It was created under the FSP Act 2008 to provide transparency and give consumers access to dispute resolution. Registration includes criminal history and banned-director checks, but it does not assess the provider's business model, financial soundness, or compliance framework in the way a licensing process does.
Registration Is Not a Licence: What the FSPR Actually Means
The FSPR states on its website that registration carries no official approval or endorsement and says nothing about whether the provider is licensed or regulated in New Zealand.
A provider that presents its FSPR registration number as proof of licensed or supervised status risks action under sections 18A and 18B of the FSP Act. The FMA can direct the Registrar to deregister a provider when its registration creates a false or misleading appearance of New Zealand activity or regulation.
The Financial Service Providers (Registration) Regulations 2020 add a specific obligation. A registered provider that lacks an FMA licence, falls outside the financial adviser and certified creditor categories, and refers to its FSPR registration or New Zealand regulatory status in any public communication must include a prescribed warning statement on its website. The warning makes clear that registration and active regulation are separate things. A breach of this requirement is itself a ground for deregistration from the FSPR.
Who Must Register on the FSPR
The FSP Act 2008 (section 11) requires registration before a provider may lawfully offer financial services in New Zealand. Providing financial services without a current registration is an offense under section 11, carrying a fine of up to NZD 100,000 for an individual or NZD 300,000 for a body corporate (section 40).
Registration is triggered in three ways.
Threshold-based obligation. A person or entity that is ordinarily resident in New Zealand or has a place of business there, and provides financial services to persons in New Zealand above a minimum business threshold, must register. The threshold (set by the Financial Service Providers (Registration) Regulations 2020) is: 10 New Zealand-resident financial services clients and NZD 10,000 of financial services transactions in total with those clients, measured annually. In the first six months after registration, the provider must achieve at least half the threshold (five New Zealand-resident clients and NZD 5,000 in transactions).
AML/CFT reporting entities. A reporting entity under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 that provides financial services must register regardless of whether it meets the minimum business threshold.
Licensed providers. A person who is licensed to provide a financial service, or required by another enactment to hold a licence or registration for a specific financial service, must register.
Certain providers and activities are exempt under the Financial Service Providers (Exemptions) Regulations 2010, as amended in 2020. The most significant exemption covers overseas providers with no place of business in New Zealand that refrain from promoting their services to New Zealand clients (regulation 4A). Since March 15, 2021, a provider serving only offshore clients is barred from registering on the FSPR. Existing registrations that failed to meet the new conditions were removed.
Which Financial Services Also Require an FMA Licence
Registration sits with the Registrar at the Companies Office. Licensing sits with the FMA (or, for banks and insurers, with the Reserve Bank of New Zealand). These are separate processes administered by separate authorities.
The following categories of financial service require an FMA licence under the Financial Markets Conduct Act 2013, in addition to FSPR registration:
| Service | FMA licence type |
|---|---|
| Providing regulated financial advice to retail clients | Financial advice provider (FAP) |
| Making investment decisions on behalf of clients under a discretionary mandate | Discretionary Investment Management Service (DIMS) |
| Managing a managed investment scheme (including KiwiSaver) | Managed investment scheme (MIS) manager |
| Issuing derivatives to retail clients | Derivatives issuer |
| Operating a crowdfunding platform | Crowdfunding service provider |
| Operating a peer-to-peer lending platform | Peer-to-peer lending service provider |
| Acting as a financial institution under the Conduct of Financial Institutions (CoFI) regime | Financial institution licence |
If a provider's service falls into one of these categories, FSPR registration alone is insufficient. The provider must hold the relevant FMA licence before it can lawfully offer the service. A provider that applies to register for licensed services must already hold the applicable FMA or Reserve Bank authorization before the Registrar completes the registration.
Banks and insurers are licensed by the Reserve Bank under separate legislation and also register on the FSPR.
FSPR registration vs an FMA licence: side-by-side
| Feature | FSPR registration | FMA licence |
|---|---|---|
| Issued by | Registrar of Financial Service Providers (Companies Office, MBIE) | Financial Markets Authority |
| Legal basis | FSP Act 2008 | Financial Markets Conduct Act 2013 |
| What it confirms | The provider is listed on a public register | The provider has been assessed and authorized for a specific regulated service |
| Ongoing supervision | None by the Registrar or FMA solely by virtue of registration | FMA supervision, reporting obligations, licence conditions |
| Fitness assessment | Criminal history check on directors and controlling persons | Fit-and-proper assessment of directors and senior managers; evaluation of governance, compliance, capital, and risk management |
| Cost at entry (excl. GST) | NZD 300 application fee + NZD 600 FMA levy + NZD 11.30 per criminal history check | Set by licence type |
| Annual cost (excl. GST) | NZD 75 confirmation fee + FMA levy (NZD 660 for Class 7 providers; higher for licensed categories) | FMA levies by service class and size; regulatory returns; compliance infrastructure |
What Determines Whether an FSPR Application Succeeds
Registration is submitted online through the FSPR portal. The provider must already be incorporated in New Zealand or registered as an overseas company on the Companies Register.
The Registrar runs a criminal history check on each director and controlling person, and any person prohibited from being a director in New Zealand or Australia is barred from association with a registered provider.
Registration fees, in effect since July 1, 2022:
| Component | Excl. GST | Incl. GST |
|---|---|---|
| Application fee | NZD 300 | NZD 345 |
| Criminal history check (per person) | NZD 11.30 | NZD 13.00 |
| FMA levy | NZD 600 | NZD 690 |
The fees are the smallest part of the decision. Four things determine whether a registration survives.
The service categories selected in the application. The categories chosen at this stage decide whether the provider falls into a licensed category under the Financial Markets Conduct Act 2013 and which AML/CFT supervisor applies. A provider that selects a category it cannot lawfully perform without an FMA licence will not complete registration.
The substance of the New Zealand connection. The Registrar and the FMA look at who runs the business and where the clients are. A provider with offshore management, a passive New Zealand-resident director and no New Zealand clients meets the profile that sections 18A and 18B were enacted to address.
The match between the declared model and the actual one. Any gap between the registered service categories and what the business does surfaces at the first annual confirmation or the first threshold request from the Registrar.
Readiness for post-registration obligations before filing. DRS membership is due within 10 working days of registration, and the AML/CFT program, risk assessment and compliance officer are required from the point services begin, not from the first supervisor visit.
Anyone can file the application. What decides the outcome is whether the structure behind it holds up when the Registrar, the FMA or an AML/CFT supervisor examines it.
The FSP Act leaves the Registrar's review period open: there is no statutory deadline for processing a submitted application, and the Registrar can ask for further information at any point.
Equilex supports FSPR registration in New Zealand, including entity setup, application preparation, and post-registration compliance. Complete the contact form to discuss the requirements with a regulatory specialist and receive a reŠ°sponse within 24 hours.
Obligations After Registration: DRS, AML and Annual Confirmation
Post-registration obligations depend on the services provided and the clients served. The principal requirements cover dispute resolution, AML/CFT compliance, and annual confirmation.
Dispute resolution scheme. A provider that offers financial services to retail clients in New Zealand must join an approved consumer dispute resolution scheme (DRS). The provider must update the FSPR with its DRS membership details within 10 working days of registering (section 48 of the FSP Act). Providers dealing exclusively with wholesale clients are exempt from this obligation. Failure to join within the 10-working-day window is a ground for deregistration under section 18(1).
AML/CFT compliance. A provider that is a reporting entity under the AML/CFT Act 2009 must maintain a risk assessment, an AML/CFT program, a designated compliance officer, customer due diligence procedures, transaction monitoring, and suspicious activity reporting.
Three government agencies supervise AML/CFT compliance, depending on the provider's activities:
| Supervisor | Covers |
|---|---|
| Department of Internal Affairs (DIA) | Money or value transfer services, foreign exchange, means-of-payment issuance, financial guarantees, non-deposit-taking lenders, casinos, and all other reporting entities outside FMA and RBNZ supervision |
| Financial Markets Authority (FMA) | Derivatives issuers, brokers, custodians, FAPs, MIS managers, DIMS providers, crowdfunding and peer-to-peer lending platforms |
| Reserve Bank of New Zealand (RBNZ) | Banks, life insurers, non-bank deposit takers |
For a typical FSPR-registered provider offering money remittance, foreign exchange, or crypto exchange services, the DIA is the AML/CFT supervisor.
Annual confirmation. Every registered provider must confirm its details and services on the FSPR once per year, in a month assigned by the system (section 16 of the FSP Act). December and January are excluded from the assignment cycle. The annual confirmation fee is NZD 75 plus GST. An FMA levy is also payable, determined by the provider's service class under Schedule 2 of the Financial Markets Authority (Levies) Regulations 2012. The default levy for providers in Class 7 (those outside Classes 2 through 6H) is NZD 660 plus GST. Failure to file the annual confirmation is a ground for deregistration.
When the FMA Directs the Registrar to Deregister a Provider
Sections 18A and 18B of the FSP Act give the FMA the power to direct the Registrar to remove a provider from the register. The FMA may issue a direction where it is satisfied that a provider's registration:
(a) creates, or is likely to create, a false or misleading appearance that the provider provides financial services in New Zealand, or that it is regulated under New Zealand law; or
(b) otherwise damages the integrity or reputation of New Zealand's financial markets.
The Financial Advisers Disciplinary Committee (FADC) holds a parallel power to direct deregistration.
Procedure. The FMA issues a written notice of intention, setting out the grounds. The provider may make submissions in response. After considering any submission, the FMA decides whether to issue the direction. When a direction comes from the FMA or the FADC, the Registrar must act on it and the provider has no right of objection (section 18(1)(e)).
Case law. Court decisions have confirmed the FMA's power to act where an FSPR entry creates a misleading impression of New Zealand regulation. The key cases include:
Vivier & Company Limited: FMA directed deregistration on June 29, 2015, after finding that Vivier, a New Zealand-incorporated company, served clients entirely outside New Zealand (mostly in Europe) and maintained only a basic office in Auckland. The High Court allowed Vivier's appeal on procedural grounds (September 25, 2015, Justice Brewer). The FMA appealed, and the Court of Appeal restored the deregistration direction on May 13, 2016, finding in favor of the FMA.
Innovative Securities Limited: the High Court dismissed the company's appeal and it was deregistered from the FSPR in June 2017.
FXBTG Financial Limited: FMA directed deregistration in June 2019. The High Court dismissed FXBTG's appeal in November 2019. Justice Cooke described the case as "the classic situation the provisions were enacted to address," noting that FXBTG had one employee operating from a residential apartment in Mount Roskill and that all its clients were overseas.
Indicators of sham presence. The FMA's published materials identify several factors it considers when assessing whether a registration is misleading: directors and shareholders predominantly based overseas, a passive New Zealand-resident director with no operational role, a virtual or serviced office address, and an absence of New Zealand clients.
As of August 19, 2026, the most recent FSPR deregistration notice covered 132 providers. Registrar-led removals under section 18 operate separately from targeted FMA directions under sections 18A and 18B.
Crypto and Forex Businesses on the FSPR
FSPR registration alone does not license a crypto exchange or forex business and does not place it under FMA supervision.
A business that exchanges virtual assets or provides custodial wallet services in or from New Zealand is subject to obligations under the AML/CFT Act 2009. The DIA supervises AML/CFT compliance for these providers. FSPR registration confirms the provider is listed on the register; it says nothing about whether the FMA has assessed or approved the business.
A provider that offers derivatives, including contracts for difference on forex or cryptocurrency, to retail clients in New Zealand requires a derivatives issuer licence from the FMA. FSPR registration is separate from, and insufficient without, that licence.
Purchasing a ready-made company does not protect its FSPR registration. A structure with offshore principals, a nominal New Zealand address, no local clients, and a registration number marketed as evidence of regulation matches factors the FMA considers when assessing whether an entry is misleading. The FMA can direct deregistration after a change of ownership if the statutory grounds are met.
FSPR or an Overseas Alternative: How to Choose
FSPR registration applies to providers that meet the statutory connection and business-threshold tests or another registration trigger. The provider must also identify whether its services require an FMA or Reserve Bank licence and which DRS and AML/CFT obligations apply.
FSPR registration does not provide a cross-border licence. A provider seeking an authorization for overseas operations can assess MSB registration in the USA for US-facing payment and money transmission, SPI registration in Poland for a volume-capped Polish payment services structure, or an EMI authorization for passported electronic money issuance across the EEA.
A broader comparison of licensing jurisdictions, timelines, and costs is available in the best countries to get a payment licence in 2026 overview.
FAQ
Is FSPR registration a licence?
No. FSPR registration is an entry on a public register maintained by the Companies Office. It confers no licence, regulatory approval, or supervised status. Providers offering financial advice, DIMS, derivatives, crowdfunding, or peer-to-peer lending to retail clients need the relevant FMA licence in addition to FSPR registration.
Do I need FSPR registration if my clients are not in New Zealand?
An overseas provider with no place of business in New Zealand and no promotion to New Zealand clients is exempt under the Financial Service Providers (Exemptions) Amendment Regulations 2020. Since March 15, 2021, providers serving only offshore clients cannot register. An entry without a genuine New Zealand connection can be removed.
Can the FMA remove my company from the FSPR?
Yes. Under sections 18A and 18B of the FSP Act 2008, the FMA can direct the Registrar to deregister a provider whose registration creates a misleading impression about its presence in or regulation under New Zealand law. The Vivier and FXBTG decisions confirmed the FMA's power to address this misuse of the register.
Does a crypto exchange need an FMA licence in New Zealand?
Spot exchange of virtual assets does not itself require an FMA licence. A crypto exchange that is a reporting entity has AML/CFT obligations under the AML/CFT Act 2009, supervised by the DIA. Offering derivatives, such as contracts for difference on cryptocurrency, to retail clients requires a derivatives issuer licence from he FMA.
What must a registered FSP do every year?
File an annual confirmation in the assigned month (December and January excluded), pay the NZD 75 confirmation fee plus GST and the applicable FMA levy, maintain DRS membership if serving retail clients, and comply with all AML/CFT obligations. Failure to file the annual confirmation or to maintain DRS membership is a ground for deregistration.
