Authorised vs Prohibited Activities — Guidance | NLA
Guidance & Standards / Authorised vs Prohibited Activities

Authorised vs prohibited activities

licenses are scope-based. “Authorised” means the activity is explicitly covered by the license category and recorded activity header(s). “Prohibited” means the activity is outside scope, misdescribed, or presented in a misleading way. This page helps applicants and license holders prevent invalid claims and avoid operational drift.

Scope boundaries Truthful license claims Activity headers Verification-first
Important: If there is any doubt about scope, do not market it as authorised. Use the verification interface and obtain scope confirmation through your Registered Agent before making public claims.

Quick definitions

authorised • prohibited

Authorised activity

An activity is “authorised” when all three conditions are met:

  • The activity is within the stated scope of the license category.
  • The activity header (permission group) is recorded on the license.
  • Public claims match the license wording and verification output.
Scope-aligned Recorded Verifiable

Prohibited activity (for licensing purposes)

An activity is “prohibited” when it is outside scope or presented in a misleading manner, including:

  • Claiming a broader license category than issued.
  • Offering services that require additional activity headers or a different license family.
  • Using “regulated/approved” language that implies powers not granted.
  • Presenting “partner” permissions as if they were your own license scope.
Out-of-scope Misdescribed Non-verifiable

What “activity headers” mean in practice

permissions

Activity headers are top-level permission groups recorded on a license. They limit what can be marketed, contracted, and operationally delivered. If an activity is not covered by the recorded header(s), it should not be offered or implied.

Example activity Typically authorised under Common prohibited claim pattern
Broker dealing / execution Capital Markets & Dealing (with correct model) Claiming “banking” or “custody” permissions when only dealing scope exists.
Payment routing / gateway PSP / Payments (as issued) Holding client balances or issuing stored value while describing it as “payments only”.
Stored-value wallet EMI / Stored Value (as issued) Describing stored value as “deposits” or “bank accounts” without the relevant license scope.
Managed pools / MAM Fund Management / Managed Pools Calling pooled management “signals only” while actually controlling execution and allocations.
Custody / trustee roles Custodian & Trustee (as issued) Using “custody” language for normal platform balances without custody controls or mandate.
Common confusion: “We work with a partner who is licensed”

Partnering does not automatically extend your scope. If you market an activity as yours, your own license must cover it. If a partner provides the licensed service, your wording must be explicit: you are an introducing/technology/service provider, and the licensed counterparty is identified clearly.

  • Do not display partner license numbers as if they were yours.
  • Do not imply you hold permissions that sit with the partner.
  • Ensure contracts, T&Cs and onboarding flows mirror the true operating model.

How to make accurate license claims

marketing • websites • documents

Accurate claims are short, verifiable, and scope-limited. The aim is clarity: third parties should be able to verify the claim and understand what it covers without assumptions.

Use this structure

  • license category name (exact wording used by NLA)
  • Operating model (if relevant, e.g., principal/agency)
  • Scope statement (1–2 lines; no extra claims)
  • Verification link (always)

Avoid these patterns

  • “Fully regulated / officially approved” statements that go beyond licensing scope.
  • Using seals/crests next to claims that cannot be verified.
  • “Licensed for all financial services” or “global license” language.
  • Claiming “banking” where only payments, dealing or advisory scope exists.
No scope inflation No implied powers
What to do if your website content is outdated

If your public content does not match your verified scope, treat it as a priority remediation. Update the website, sales decks and onboarding flows before continuing marketing campaigns. Your Registered Agent can help align the claim to license wording and activity headers.

If you’re unsure: the safe decision rule

practical
Safe rule: If a third party cannot verify it and understand it in under 60 seconds, don’t market it as authorised. Use scope-confirmation via your Registered Agent and update claims only after alignment.