The Czech National Bank (CNB) is aware of the potential of innovation based on the application of digital technologies to streamline the functioning of all sectors of the financial market, enhance the provision of financial services and foster a stronger and more resilient real economy of the Czech Republic.
The CNB has therefore decided to establish a new specialised communication channel to receive FinTech-related enquiries from all financial market participants. The new channel is simply called the FinTech contact point.
The contact point aims to promote the introduction of innovative technologies on the Czech financial market through more active communication with incumbent institutions and potential new entrants. The CNB is not currently planning to establish an innovation hub or a regulatory sandbox.
The primary means to achieve this aim is to respond more flexibly to relevant FinTech-related enquiries. As when providing answers to professional queries, the CNB will try to help resolve unclear regulatory issues (including licensing and supervisory ones) so as to facilitate compliance with the duties imposed on enquirers by financial market regulations.
When sending in a query, enquirers should always state where specifically they see a relation between their activities and financial innovation. Most importantly, they should explain how the described technological solution, business model or other aspects differ from the products, services or processes provided or used on the domestic financial market at that time.
This information is necessary for the CNB to evaluate whether an enquiry is related to financial innovation and whether it will be answered via the contact point or dealt with as a professional query. The main feature that distinguishes “FinTech queries” from professional ones is the absence of a requirement for a legal assessment of the query as a condition for answering the query. However, the contact point is not intended to fully substitute for the efforts of market participants or their advisers. A query containing the enquirer’s own analysis and proposed solution will enable the CNB to better understand the subject of the query and provide a more specific reply.
Participants may use this contact form to send in FinTech-related queries.
Regular meetings with the FinTech community and the wider public and roundtables on specific FinTech-related topics are another means of communication associated with the contact point. These meetings are aimed at facilitating a dialogue on problems arising from the implementation of innovations and on the options for resolving them in practice. The CNB will provide information about these meetings on this website on an ongoing basis.
For clarity, we provide below answers to frequently asked questions about the purpose and operation of the contact point.
Financial innovation (aka financial technology or FinTech) can be defined as technology-enabled innovation in financial services that could lead to new business models, solutions, processes or products, and the related significant impact on the provision of financial services by individual institutions.
The contact point is used to establish and conduct communication between the CNB and incumbent institutions and potential new entrants in the FinTech area of the financial market.
The use of new technology in the financial area may give rise to a number of questions relating to regulation, licensing and supervisory aspects of the CNB’s activities. Using the contact point to answer these questions, the CNB will try to clarify and facilitate enquirers’ access to and operation on the financial market.
The contact point is intended for all companies (both new and existing) and also for individuals active in the FinTech area.
- The query should be submitted using the relevant form.
- The enquirer should provide a sufficiently specific and appropriate explanation of the solution’s relation to financial innovation (what it involves and how it differs from the solutions currently in use).
- The queries and descriptions of innovations submitted should be sufficiently specific for the CNB to be able to provide clear answers. A general description of an intended idea will not be sufficient.
- The relevant information includes the identity of the actual enquirer, i.e. the person to whom the answer will be addressed. Anonymous queries will not be answered. If an opinion is requested by a client’s representative (an attorney, auditor or other counsellor), the client for whom they are acting must be identified.
As soon as we receive your query, a team of CNB experts will assess whether the query relates to financial innovation. If it does, the experts will try to answer it as soon as possible depending on the capacity available and the complexity of the query. If the query does not relate to FinTech, it will be handled as a professional query. This will typically imply a need to supply a legal analysis and a proposed solution. If we arrive at this conclusion, we will notify the enquirer as soon as possible.
- Opinions of the CNB provided via the contact point do not substitute for authorisations or approvals granted in licensing proceedings and are not binding in any way. This is because, for example, the documents submitted for the purposes of an opinion may differ from those submitted in licensing proceedings. The CNB also reserves the right to change its opinions, especially if relevant legislation changes, the enquirer supplies an additional analysis, facts change, or further additional information is obtained.
- The contact point is not intended to provide information falling outside the CNB’s area of competence (for example about the tax regime applying to cryptoassets). Queries must relate to the interpretation of legal rules governing the financial market area falling within the CNB’s competences or the interpretation of supervisory practice.
- The contact point is not intended to substitute for the efforts of market participants or their legal and other advisers.