What is the difference between FSPR registration and a Financial Advice Provider (FAP) licence?

FSPR registration records that a business or individual provides financial services and is listed on New Zealand's Financial Service Providers Register. It is not a licence and does not constitute regulatory approval or endorsement. A Financial Advice Provider (FAP) licence is a regulatory authorisation issued by the Financial Markets Authority (FMA). It is required where a business provides regulated financial advice to retail clients in New Zealand.

Who needs a Financial Advice Provider (FAP) licence?

A business generally requires a Financial Advice Provider (FAP) licence if it provides regulated financial advice to retail clients in New Zealand. Examples include independent financial advisory firms, wealth management businesses, investment advisory companies, insurance and mortgage advice businesses, fintech platforms providing regulated financial advice, and businesses employing or engaging financial advisers.

Do individual financial advisers need their own Financial Advice Provider (FAP) licence?

Not necessarily. In New Zealand, the Financial Advice Provider (FAP) licence is generally held by the business providing regulated financial advice, not by each individual adviser. Most financial advisers are employed or engaged by a licensed FAP and provide advice under that FAP's licence. A sole adviser business may hold its own FAP licence.

What are the ongoing compliance obligations after obtaining FSPR registration or a FAP licence?

After registration or licensing, businesses must continue to meet their ongoing regulatory obligations. These may include maintaining accurate information on the FSPR, filing annual confirmations, meeting the conditions of a FAP licence, submitting FAP regulatory returns where required, maintaining membership in an approved dispute resolution scheme for retail service providers, complying with AML/CFT obligations where applicable, and maintaining governance, compliance, and risk management frameworks.

Can an overseas company register as a Financial Service Provider (FSPR) in New Zealand?

Yes, an overseas company may register as a financial service provider in New Zealand if it meets the relevant FSPR requirements. For overseas providers, the FSPR guidance requires the business to confirm that it expects to provide financial services to persons in New Zealand above the minimum annual business threshold: 10 New Zealand resident financial services clients and NZD 10,000 of financial services transactions with New Zealand resident clients.

Can an FSP provide financial advice without a FAP licence?

Generally, no. A business providing regulated financial advice to retail clients must either hold a Financial Advice Provider (FAP) licence or operate under a licensed FAP, unless an exemption applies.

What are the director requirements for a Financial Advice Provider (FAP) licence in New Zealand?

Directors of a Financial Advice Provider (FAP) are expected to support effective governance, risk management, and compliance. During the FAP licence application process, the Financial Markets Authority (FMA) assesses whether the applicant has suitable governance arrangements, effective systems and controls, and whether its directors and senior managers are fit and proper persons.

FSP Registration in New Zealand

Quick facts

Regulator / authority

FMA (Financial Markets Authority)

Coverage

Financial advice
money remittance
foreign exchange
payment services
broking and client money/property services

Best for

Financial advisers, brokerages, discretionary investment managers, fintechs, financial institutions, derivatives issuers, and crowdfunding or peer-to-peer lending platforms establishing a compliant presence in New Zealand.

Local presence

Required (New Zealand legal entity)

Substance level

Low (FSPR registration) to Medium–High (FMA licensing) — fit and proper directors and senior managers; governance and compliance framework; documented policies and procedures; risk management systems; competent personnel; and compliance with applicable FMA licence conditions.

Banking friendliness

Medium

Who this is for

Best fit

Provide financial advice or financial services to New Zealand retail or wholesale clients as a regular part of the business
Operate a Discretionary Investment Management Service (DIMS) for retail or wholesale clients
Operate as a registered bank, licensed insurer, or licensed non-bank deposit taker subject to the CoFI regime

Issue derivatives or operate a crowdfunding or peer-to-peer lending platform
Establish a compliant and publicly searchable presence on the Financial Service Providers Register (FSPR)
Combine FSPR registration with the appropriate FMA licence for regulated financial services

What you can do (scope)

FSPR registration — provide financial services that do not require a separate FMA licence, subject to applicable registration, disclosure, and dispute resolution obligations
Financial Advice Provider (FAP) licence — provide regulated financial advice to retail clients
Discretionary Investment Management Service (DIMS) licence — provide discretionary investment management services and make investment decisions on behalf of clients under a discretionary mandate
Financial institution licence (CoFI) — operate as a registered bank, licensed insurer, or licensed non-bank deposit taker providing relevant services to New Zealand consumers
Derivatives issuer, crowdfunding service, and peer-to-peer lending service licences — provide the licensed market service authorised under the Financial Markets Conduct Act 2013

Requirements overview

Company & presence

New Zealand-incorporated entity or registered overseas company meeting the FSPR registration criteria; FSPR registration required before providing financial services in or from New Zealand.

Key persons / governance

Fit and proper directors and senior managers (where applicable); competent advisers and key personnel; appropriate governance and compliance arrangements; and licence-specific governance requirements (e.g. a Fair Conduct Programme for Financial Institution licensees and compliance with the Code of Professional Conduct for Financial Advice Services for FAPs).

Capital / safeguarding / bonds

No universal minimum capital requirement. Financial soundness, capital, liquidity, insurance, and other prudential requirements vary depending on the applicable FMA licence and its licence conditions.

AML/CTF baseline expectations

AML/CFT compliance under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (where applicable); reporting entity registration; customer due diligence (CDD); ongoing monitoring; suspicious activity reporting; record-keeping; and supervision by the DIA, FMA, or RBNZ, depending on the business activity.

Reporting / audits

Annual FSPR confirmation; applicable FMA regulatory returns and levy payments; ongoing AML/CFT compliance; and independent AML/CFT audits at the intervals required by the relevant AML/CFT supervisor.

Process (end-to-end steps)

Step 1: Eligibility & scope assessment

Determine the applicable financial services and regulatory requirements; identify whether FSPR registration alone is sufficient or an FMA licence is also required; determine the appropriate FMA licence type (e.g. FAP, DIMS, Financial Institution, Derivatives Issuer, Crowdfunding, or Peer-to-Peer Lending); and confirm the proposed business model and regulatory scope.

Step 2: Entity setup

Incorporate or confirm the New Zealand legal entity; establish the required New Zealand business presence; confirm eligibility for FSPR registration; and prepare the corporate governance structure.

Step 3: FSPR registration

Prepare the FSPR registration application; register the entity through the Financial Service Providers Register (FSPR); complete the required identity and criminal history checks; pay the applicable registration fees; and receive the FSPR registration confirmation.

Step 4: FMA licence application (where required)

Prepare the licence application and supporting documentation; develop the required governance and compliance framework; prepare Fit and Proper and licence-specific documentation; submit the application to the Financial Markets Authority (FMA); and pay the applicable licensing fee.

Step 5: FMA review & regulatory assessment

Undergo regulatory review by the FMA; respond to regulatory queries and requests for additional information; provide supplementary documentation and clarifications where required; meet the prescribed regulatory deadlines; and receive the licensing decision.

Step 6: Go-live & ongoing compliance

Activate the FSPR registration and applicable FMA licence; implement the AML/CFT compliance programme (where applicable); comply with applicable licence conditions and regulatory obligations; complete annual confirmations, regulatory returns, and levy payments; and maintain ongoing governance and compliance arrangements.

Step 1: Eligibility & scope assessment

Determine the applicable financial services and regulatory requirements; identify whether FSPR registration alone is sufficient or an FMA licence is also required; determine the appropriate FMA licence type (e.g. FAP, DIMS, Financial Institution, Derivatives Issuer, Crowdfunding, or Peer-to-Peer Lending); and confirm the proposed business model and regulatory scope.

Step 2: Entity setup

Incorporate or confirm the New Zealand legal entity; establish the required New Zealand business presence; confirm eligibility for FSPR registration; and prepare the corporate governance structure.

Step 3: FSPR registration

Prepare the FSPR registration application; register the entity through the Financial Service Providers Register (FSPR); complete the required identity and criminal history checks; pay the applicable registration fees; and receive the FSPR registration confirmation.

Step 4: FMA licence application (where required)

Prepare the licence application and supporting documentation; develop the required governance and compliance framework; prepare Fit and Proper and licence-specific documentation; submit the application to the Financial Markets Authority (FMA); and pay the applicable licensing fee.

Step 5: FMA review & regulatory assessment

Undergo regulatory review by the FMA; respond to regulatory queries and requests for additional information; provide supplementary documentation and clarifications where required; meet the prescribed regulatory deadlines; and receive the licensing decision.

Step 6: Go-live & ongoing compliance

Activate the FSPR registration and applicable FMA licence; implement the AML/CFT compliance programme (where applicable); comply with applicable licence conditions and regulatory obligations; complete annual confirmations, regulatory returns, and levy payments; and maintain ongoing governance and compliance arrangements.

What's included in our support

Regulatory scope assessment and FSPR/FMA licence mapping
Preparation of the FSPR registration and applicable FMA licence application
Fit and Proper preparation for directors, senior managers, and other key personnel
Development of governance, compliance, AML/CFT, and risk management frameworks
Preparation of business plans, policies, procedures, and licence-specific supporting documentation
FSPR registration and FMA application submission support
Regulatory query management and liaison with the Companies Office and the FMA

FAQ

FSP registration is the process of registering a business or individual on New Zealand's Financial Service Providers Register (FSPR) before providing financial services where registration is required by law. The FSPR is maintained by the Companies Office and records individuals, businesses, and organisations that offer financial services in New Zealand.

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FSP Registration & FAP Licensing - New Zealand

Quick facts

Who this is for

What you can do (scope)

Requirements overview

Company & presence

Key persons / governance

Capital / safeguarding / bonds

AML/CTF baseline expectations

Reporting / audits

Process (end-to-end steps)

Step 1: Eligibility & scope assessment

Step 2: Entity setup

Step 3: FSPR registration

Step 4: FMA licence application (where required)

Step 5: FMA review & regulatory assessment

Step 6: Go-live & ongoing compliance

Step 1: Eligibility & scope assessment

Step 2: Entity setup

Step 3: FSPR registration

Step 4: FMA licence application (where required)

Step 5: FMA review & regulatory assessment

Step 6: Go-live & ongoing compliance

What's included in our support

FAQ

Ready to get started?