This page clarifies the difference between (1) the licensing authority function and (2) registered agents or private service providers. It sets minimum disclosure expectations and practical checks to avoid role confusion in public claims and client communications.
A licensing authority maintains scope definitions, administers licensing decisions, and supports public verification. A registered agent (or private service provider) assists applicants with preparation and submissions, but does not replace the authority function.
Public function
Private function
Use this table to keep public statements accurate. If you cannot defend a statement using register wording or verifiable outputs, do not publish it.
| Area | Authority (NLA function) | Agent / private provider | Typical failure pattern |
|---|---|---|---|
| Decision-making | Issues/records licensing decisions and status. | No authority to grant a license; supports preparation and submission. | Marketing implies the agent “approved” or “regulated” the firm. |
| Scope definition | Defines categories, activity headers, and minimum standards. | Explains categories; cannot redefine scope or invent permissions. | Scope drift: claims broader permissions than recorded scope. |
| Verification | Maintains register and verification outputs. | May link to verification; cannot substitute it. | Using screenshots/emails instead of a verification link. |
| Fees / invoicing | Publishes fee framework; receives official fees where applicable. | Charges service fees separately (if any), under its own terms. | Bundling fees so clients cannot distinguish official vs private fees. |
| Ongoing obligations | Sets obligations via standards/circulars; may apply administrative actions. | Can help compliance operations but does not “supervise” on behalf of Authority. | Agent described as “supervisor” or “regulator” in public claims. |
If a licensee uses a private agent/provider, public materials should be clear. A simple minimum standard is:
Most public confusion comes from wording. The following patterns must be avoided in websites, pitch decks, onboarding text, and adverts.
Reality: Agents are private providers. They can support submissions but cannot replace licensing decisions or verification outputs.
Reality: Payments to a service provider do not equal a license status. Status must be verifiable via register outputs.
Assume your client, bank, PSP, or counterparty will verify you like a compliance team. These checks are simple—but strict.
| Check | What they look for | Typical failure pattern |
|---|---|---|
| Verification link | A direct link to verify status, with consistent license number and entity name. | Only screenshots or PDFs, no verifiable interface. |
| Register wording | Activity headers match what you claim publicly (no extra permissions). | Public claims exceed the register scope (scope drift). |
| Role clarity | Authority vs agent roles are distinct; no “proxy regulator” framing. | Agent presented as the authority or supervisor. |
| Contact signals | Official contact references align with authority pages; agent contacts are labelled as private. | Agent phone/email used as “regulator contact” without labeling. |
Neves Licensing Authority – Disciplina • Unitas • Labor