The Financial Markets Authority (FMA), in an update on 27 November 2025, provided further details on the single licence initiative that is proposed under the Financial Markets Conduct Amendment Bill (Bill). The update provides clarity on what is planned under the single licence regime and the intended transition process.

The Bill is currently still at the select committee stage, with submissions open on an amendment paper until 4 December 2025. Links to the Bill and the FMA update are available here and here.

Who needs to read it? Why?

The FMA has indicated in its update that this will be a relatively straightforward change. All holders of market service licences granted by the FMA under part 6 of the Financial Markets Conduct Act 2013 (FMCA) should however read this and be aware of potential changes under the Bill and find reassurance in the FMA’s commitment to a low impact transition. 

What does it cover?

Currently, firms offering multiple market services must hold separate licences for each service they provide. There are currently several types of market services under the FMCA which require a licence. Each licensing regime has its own requirements and application guidance even though many address similar issues. This overlap creates unnecessary duplication, as firms offering multiple market services must currently navigate separate licencing regimes with similar requirements and guidance. Under the Bill, the FMA will issue one licence for firms providing multiple market services under the FMCA.

The FMA in its update stated that the following is planned: 

• One licence application for multiple services
• A single annual regulatory return
• Consistent standard conditions for all market services
• One process for reporting changes to directors and senior managers.

The update also emphasised that the impact for firms with a single licence will be minimal. For multi-service firms, the transition will be “as seamless as possible”, with existing licences automatically combined into a single licence without requiring reapplication. This will reduce internal administration costs, as firms will only need to report on a single licence. 

The FMA has also confirmed that implementation will be gradual:

“Changes won’t happen immediately or all at once. We’ll keep licensees informed, consult on proposed conditions and allow time to adapt before implementation." 

This proposed amendment applies only to firms licensed under the FMCA for market services. Licensed supervisors will not be directly affected by these licensing regime changes, though they may need to adjust monitoring processes to ensure compliance across all authorised services under a single licence.

Our view

We have been involved in shaping the conversation around financial services reform from the outset. An earlier article by Lloyd Kavanagh, Financial Services – the case for reform, discussed the need for a more streamlined licensing regime, an approach now reflected in the Bill. 

We consider this a welcome development in the financial services regulatory space. This change will lead to greater licensing efficiency, reducing compliance complexity for firms operating across multiple market service classes. We anticipate that multi-service firms, in particular, will benefit from lower administrative burdens. 

What next?

The Bill is currently at the select committee stage, with submissions closing on the amendment paper on 4 December 2025.

If you have any questions in relation to the Bill or considering how these changes (if implemented) may affect your firm or business, please contact one of our experts.

This article was co-authored by Olivia Maher, a solicitor, and Vincent Thomas, a Summer Clerk in our Finanical Services team.