The Cyril Shroff Centre for AI, Law & Regulation prepared detailed comments on the Draft IFSCA FinTech Sandbox Framework and made its submission to the International Financial Service Centres Authority (IFSCA).  The Centre’s key suggestions were for the framework to define “innovation” objectively, avoid vague terminologies and adopt impact-based, technology-neutral definitions that align with international practice.

It also recommended to IFSCA that the eligibility criteria should not exclude independent innovators or early-stage teams, and the prescribed list of eligible activities should be replaced by a functional test tied to IFSCA’s remit. Other recommendations included replacing rigid requirements, such as mandatory testing partners and a single extension limit, with a more flexible risk-based approach.  The submission to IFSCA emphasised that monitoring should rely on standardized reporting templates and, where necessary, independent verification. The work reflects Centre’s continued commitment to contribute and engage with public institutions through cutting edge research and build a dialogue between policymakers and academic institutions so that regulatory frameworks maybe continually evolved in line with public interest.