Ongoing Obligations of Licensees
This page summarises ongoing expectations for license holders operating under the Neves authorisation framework, including recordkeeping, disclosures, operational controls, and timely notification of material changes.
Overview
License holders are expected to operate in a manner consistent with their recorded license scope, maintain clear and fair communications, and keep relevant internal records that support continuity, accountability, and verification.
1) Core obligations (summary)
The obligations below represent baseline expectations. Additional requirements may apply based on license type and specific conditions recorded in the license file.
Ensure registered details remain correct and promptly notify changes (ownership, directors, address, trading names, key contacts).
Do not represent activities outside the recorded license permissions and conditions. Avoid broad or misleading claims.
Maintain policies, client communications, operational logs, incident records, and key contracts sufficient to support verification and continuity.
Ensure systems, vendors, and workflows remain stable, documented, and reasonably resilient (including basic business continuity planning).
Marketing and client communications should be clear, not misleading, and consistent with recorded license scope.
Where agents are used, maintain written appointment terms, defined responsibilities, and oversight arrangements.
2) What changes should be notified
Licensees should notify the Authority of material changes, including (not limited to):
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Ownership & control changes
Shareholders, ultimate beneficial ownership, control agreements, or changes to key controlling persons.
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Leadership / key persons changes
Directors, senior managers, compliance/operations leads, authorised representatives, key contacts.
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Business model changes
New products, new client onboarding flows, significant client segments, major distribution channels, material outsourcing.
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Branding & public claims
New domains, trading names, marketing claims, use of license references, or changes to customer-facing disclosures.
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Operational incidents
Material outages, data incidents, integrity issues, or events that could materially affect customers or service continuity.
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Agent appointment changes
New agent appointments, termination of agents, or changes in agent scope of responsibility.
3) Recordkeeping & retention (baseline)
Licensees should keep organised records for reasonable periods to support continuity and verification. Examples include:
- Governance records: board/management decisions, delegations, policy index
- Customer communications: disclosures, complaints, notices, key customer interactions
- Vendor and outsourcing records: contracts, SLAs, due diligence notes
- Operational logs: incidents, system changes, continuity testing, escalation records
- Training records: staff onboarding and periodic training on key policies
4) Notify a material change
Use the template below to notify a change for administrative recording.
Disclaimer
This page outlines baseline ongoing expectations within the Authority’s licensing framework. It does not constitute legal advice and does not represent statutory regulation. The Authority may update expectations through circulars and notices.