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Licensing

Technology Due Diligence for Broker Licence Applications: What MAS, the FCA and CIRO Look For

Quick answer

When you apply for a licence in Singapore, the UK or Canada, regulators look closely at the technology you outsource: your trading platform, CRM, hosting, liquidity bridge and payment providers. You will need to show due diligence on each vendor, contracts with service levels and audit rights, security and resilience controls, data location and protection, incident reporting and exit plans. A good technology provider supplies system descriptions, architecture diagrams, security and continuity documents and contract terms that make these answers straightforward.

Key takeaways
  • Regulators treat critical technology vendors as outsourcing that you must oversee.
  • MAS has technology risk and outsourcing guidelines; the FCA has outsourcing and operational resilience rules; CIRO and provincial regulators expect dealers to supervise outsourced services.
  • Contracts need service levels, audit and access rights, incident notification and exit plans.
  • Know where client data is stored and how it is protected and exported.
  • Ask your provider for system documentation early in your application.
Our Solution

Looking for documented brokerage technology? Platform, CRM, hosting and liquidity with documentation for your licence application.

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Many licence applications are delayed not by capital or people, but by technology questions. Regulators want to know that your systems are secure, resilient and under your control, even when a vendor runs them. This guide explains what MAS, the FCA and CIRO typically look for, and how to prepare.

Why regulators care about your vendors

A broker relies on vendors for its trading platform, CRM, hosting, liquidity bridge, market data and payments. If one fails, clients may be unable to trade or withdraw. Regulators therefore treat material technology services as outsourcing and expect you to stay responsible for them.

What each regulator focuses on

RegulatorKey expectations
MAS (Singapore)Technology Risk Management Guidelines, cyber hygiene requirements and outsourcing guidelines: governance, access control, recovery objectives and vendor oversight
FCA (UK)Outsourcing rules, operational resilience (important business services and impact tolerances) and incident reporting
CIRO and provincial regulators (Canada)Dealers remain responsible for outsourced activities, with due diligence, written agreements and ongoing supervision

Other regulators, such as CySEC, the FSCA and the FSC Mauritius, ask similar questions in less detail. See our Singapore, UK and Canada guides.

The due diligence checklist

AreaWhat to confirm
Vendor profileOwnership, experience, financial stability and references
Service descriptionExactly what the vendor runs, and what you run
SecurityEncryption, multi-factor authentication, access management, penetration tests and vulnerability management
ResilienceHosting locations, redundancy, backups, recovery time and recovery point objectives, tested disaster recovery
DataWhere data is stored, data protection compliance, ownership and full export
IncidentsHow quickly the vendor tells you about incidents and breaches
Sub-contractorsWhich other providers the vendor relies on
Audit and accessYour right, and the regulator's, to audit and access information
ExitNotice periods, transition support and data return

For security controls in more depth, read forex broker cybersecurity.

Documents your technology provider should give you

  1. A system description of the platform, CRM, bridge and integrations.
  2. Architecture and data-flow diagrams.
  3. Hosting, backup and disaster recovery descriptions.
  4. Security policies and a summary of recent testing.
  5. Service level agreement and support model.
  6. Incident management and notification process.
  7. Data protection terms and data location.
  8. Exit and migration plan.

Common mistakes

  • Choosing vendors before thinking about regulatory requirements.
  • Contracts without audit rights or exit terms.
  • No clear answer on where client data is stored.
  • Untested disaster recovery.
  • Relying on a single platform or payment provider.

How we help

We supply technology documentation for licence applications: system descriptions, architecture diagrams, hosting and continuity information and contract terms covering service levels, data and exit. We provide technology, not legal or compliance advice. See our turnkey brokerage, hosting and company formation pages.

General information reviewed November 2026, not legal, tax or investment advice. Rules change; confirm your model with qualified local counsel. MetaTrader is a trademark of MetaQuotes Ltd.

Frequently asked questions

Because critical systems such as your trading platform, CRM and hosting affect clients directly. Regulators treat them as outsourcing that you must oversee.

MAS expects licensees to follow its Technology Risk Management Guidelines, cyber hygiene requirements and outsourcing guidelines, including vendor due diligence and tested recovery plans.

Firms remain responsible for outsourced services, must manage outsourcing risk and must stay within impact tolerances for important business services under operational resilience rules.

Service levels, security obligations, incident notification, audit and access rights, data terms and an exit plan.

Yes. We supply system descriptions, architecture diagrams, hosting and continuity information and contract terms.

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