The same guidance states that providers without an application must cease operating by December 1, 2026. This is a transition framework, not an invitation for a new entrant to launch while waiting for a license.
Establish the provider's transition position
An existing provider and a new business have different starting points. The project brief should identify the operating history, brand, applicant and any auction right involved. Do not assume a right can be transferred or used for another brand without evidence supporting that arrangement.
Winning an auction does not establish final approval. The business still needs to satisfy the application and operating requirements applicable to it.
Prepare evidence without promoting an unlicensed launch
For an eligible applicant, align the submitted business model with the deployed platform, customer-funds arrangements, controls and proposed catalog. Distinguish final requirements from consultation material when assigning development work.
Keep marketing plans conditional on the applicable permission and transition rules. A software delivery date cannot establish the date on which advertising or customer activity is allowed.
Discuss your actual transition position with SuperBluOrange. We can scope the relevant readiness work once eligibility is established, rather than quote a new market launch around an auction that has already concluded.
Last source review: October 17, 2026. Recheck applicable rules before committing.