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Regulatory sandbox
A regulatory sandbox is a platform that allows participants, through consultations with the National Bank of Slovakia (NBS), to align financial innovations with regulatory requirements and practically test them in the Slovak financial market. Consultations within the sandbox are long-term and focused on the comprehensive setup of financial innovation in compliance with relevant legal regulations. After regulatory aspects are addressed, financial innovation is tested on real clients within the sandbox. However, regulatory requirements cannot be waived in the regulatory sandbox.
The regulatory sandbox has been open since January 1, 2022.
Who can participate in the regulatory sandbox, and what criteria must be met?
Eligible participants in the regulatory sandbox:
- a supervised entity
- a foreign supervised entity
- an applicant for authorization
- a service provider
- a future supervised entity
Criteria for entry into the regulatory sandbox:
- the applicant’s readiness to participate in the sandbox and the financial innovation’s readiness for testing
- the necessity of testing
- innovativeness
- positive impact on clients in the Slovak financial market and no significant negative impact on financial stability in Slovakia
The NBS assesses compliance with all criteria based on its Methodology for Evaluating Entry Criteria for the Regulatory Sandbox.
The NBS allows an applicant to enter the regulatory sandbox if:
- they have a clean criminal record
- the subject of consultation concerns the application of generally binding legal regulations within the NBS’s jurisdiction
- the applicant meets all entry criteria for the sandbox
How does the regulatory sandbox work?
Participation in the regulatory sandbox consists of the following phases:
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Preparation Phase
- Allows consultations with the NBS to help set up financial innovation in compliance with generally binding legal regulations within the NBS’s jurisdiction.
- Defines the course of the testing phase in the form of a testing plan.
- Lasts a maximum of 6 months (can be reasonably extended by the NBS if necessary).
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Testing Phase
- Allows the implementation of the tested financial innovation in the Slovak financial market according to the testing plan.
- The participant continuously informs the NBS about the progress of testing in line with the testing plan.
- The testing period must not exceed 6 months (it may be extended by the NBS for a maximum of another 6 months if necessary).
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Completion of participation in the regulatory sandbox
- Within one month after the end of testing, the participant submits a final report to the NBS.
- Within one month of receiving the final report, the NBS organizes a final meeting with the participant to discuss the final report and their participation in the regulatory sandbox.
- The NBS may replace the final meeting with a written statement on the final report.
- Participation in the regulatory sandbox ends on the day of the final meeting or the day the NBS delivers its written statement on the final report.
- Participation in the sandbox may also be terminated early by either the participant or the NBS.
Application process for the regulatory sandbox
- The applicant submits a completed application to the NBS either in physical format (.docx) or electronically.
- The NBS confirms receipt of the application, assesses the formal and substantive requirements, and, if necessary, requests the applicant to correct any deficiencies or supplement the application.
- The NBS organizes an informational meeting to obtain more detailed information about the applicant and the application.
- Within two months from the date of receiving a complete application, the NBS informs the applicant whether they will be allowed to enter the regulatory sandbox. (This two-month deadline does not apply to entities interested in cross-border testing.)
Participants in the testing phase of the regulatory sandbox
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Crowdberry Investment Platform j. s. a.
On November 22, 2023, Crowdberry Investment Platform j. s. a. (hereinafter referred to as “the participant”) entered the regulatory sandbox. The participant provides crowdfunding services under the Crowdfunding Regulation, facilitating investments in small and medium-sized enterprises (SMEs) in Slovakia and the Czech Republic.
On December 15, 2024, after successfully completing the preparation phase of the regulatory sandbox, the participant entered the next phase, which involves testing an “electronic bulletin board” under Article 25 of the Crowdfunding Regulation.
The participant’s electronic bulletin board allows clients to advertise their interest in buying and selling transferable securities that were initially offered on its crowdfunding platform. This may provide existing investors with a degree of liquidity when selling securities without the participant operating a multilateral system under MiFID II.
The aim of the tested innovation is to digitize the process of advertising interest in selling or purchasing an investment, automate investor connections as much as possible, and ensure the execution of orders for the transfer and acquisition of relevant securities.
Frequently Asked Questions (FAQ)
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How can I submit an application for the regulatory sandbox
You can submit an application to the NBS:
- By filling out an electronic form.
- After submission, the NBS will confirm receipt of the form.
Or
- By sending a completed application (.docx)
- Electronically via email to sandbox@nbs.sk
Or
- By sending it in physical form to:
- National Bank of Slovakia
Department of Financial Technologies and Innovations
Imricha Karvaša 1
813 25 Bratislava
- By filling out an electronic form.
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What is the difference between the innovation hub and the regulatory sandbox?
The innovation hub and regulatory sandbox are two tools that allow interested parties to engage in dialogue with the NBS about applying regulation to financial innovation.
The innovation hub primarily serves to answer specific questions regarding regulatory applications for financial innovation. Once these questions are addressed, the interaction in the innovation hub ends.
The regulatory sandbox enables repeated consultations on the setup of financial innovation and its subsequent real-world testing in the financial market under the supervision of the NBS.
Collaboration within the innovation hub is usually one-time, whereas collaboration within the regulatory sandbox lasts several months.
Therefore, the number of interactions through the Innovation Hub is significantly higher than the number of participants in the Regulatory Sandbox.
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Why apply for the regulatory sandbox?
Participation in the regulatory sandbox allows the participant to consult with the NBS on compliance of financial innovation with regulation. Based on consultations with NBS experts, the participant can appropriately configure financial innovation and then test it on real clients in the Slovak financial market in accordance with the testing plan.
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When can an application be submitted?
An application for the regulatory sandbox can be submitted at any time during the year.
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How is participation in the regulatory sandbox concluded?
Participation in the regulatory sandbox can be terminated properly or prematurely.
Premature Termination of Participation
- The participant may withdraw from the sandbox at any time at their own initiative but must inform the NBS in advance.
- The NBS may also terminate participation if the participant fails to follow the NBS’s instructions.
Proper Termination of Participation
- Within one month after completing testing, the participant submits a final report summarizing the testing process.
- Within one month after receiving the final report, the NBS organizes a final meeting to discuss the report and the participant’s sandbox experience.
- The NBS may replace the final meeting with a written statement on the final report.
- Participation in the sandbox ends on the day of the final meeting or when the NBS issues its written statement.
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Under what conditions can cross-border testing be conducted in multiple regulatory sandboxes?
The first step in cross-border testing is filling out a form on the EU Digital Finance Platform, specifying the type of cross-border testing and which supervisory authorities should be involved.
Applicants must apply separately to the NBS regulatory sandbox and all other regulatory sandboxes where they wish to test.
After expressing interest in cross-border testing, the NBS will coordinate with other relevant supervisory authorities to establish the next steps.
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What information about participants does the NBS publish?
The NBS publishes the participant’s business name, entry date, testing start date, testing interruption date, completion date, and a short description of the tested financial innovation.
With the participant’s consent, the NBS may disclose additional details about their participation in the regulatory sandbox.