Those startups involved in the financial services industry should be careful to ensure that they meet the SEIS and EIS qualifying criteria and to submit an advance assurance application to HMRC that clearly argues the extent to which the startup is not disqualified from SEIS/EIS.
The application needs to outline how the company is developing a tech/software/platform business that is facilitating financial transactions by creating better procedures but is not actually producing/selling the underlying financial products itself.
The business should not be “bearing any financial risk” (as HMRC put it). At no time should the company be lending any capital itself – it needs to always be the underlying investors (users of the technology being developed) who are actually providing the lending capital.
The tech platform itself also has to be an independent provider of financial products.