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Any business that carries on a payment service in Singapore needs a licence from the Monetary Authority of Singapore (MAS) under the Payment Services Act 2019 (the PS Act), unless an exemption applies. Parliament passed the Act on 14 January 2019, and it brought money-changing, remittance, e-money, merchant acquiring and digital payment tokens under one law with three licence classes.
The licence follows the activity, not the label a firm gives itself. The MAS licence class then depends on which services the firm provides and how much value passes through them each month.
Singapore-based firms that serve only customers outside Singapore need to read the digital token rules carefully. From 30 June 2025, MAS regulates these businesses as digital token service providers under the Financial Services and Markets Act 2022 and has stated that it will generally not issue a licence for that model. A firm serving Singapore customers under a PS Act licence may also serve customers overseas.
The PS Act sets three licence classes. The money-changing licence covers one narrow activity. The standard payment institution (SPI) and major payment institution (MPI) licences cover the same seven payment services, and the difference between them is scale: once a firm's volumes pass set thresholds, it must hold an MPI licence.
| Licence | Who it suits | Key terms |
|---|---|---|
| Money-changing licence | Businesses that only buy and sell foreign currency notes | S$500 application fee; S$1,500 annual fee; local ownership and experience rules |
| Standard payment institution | Firms providing any of the seven services within the volume thresholds | S$100,000 base capital; no security deposit; S$5,000 minimum annual fee |
| Major payment institution | Firms above any threshold, and those planning to scale quickly | S$250,000 base capital; security deposit of S$100,000 or S$200,000; safeguarding of customer money |
Under section 6(5) of the PS Act, a firm may hold an SPI licence while its average monthly transactions stay within:
Account issuance and money-changing are left out of the monthly transaction counts. A firm that expects to pass any of these figures within its business plan period should apply for the MPI licence from the outset rather than convert later. The detail of each class is on our pages for the Singapore standard payment institution licence and the Singapore major payment institution licence.
The money-changing licence allows only the purchase and sale of foreign currency notes. MAS sets ownership conditions for it: a sole proprietor must be a Singapore citizen, and a Singapore-owned company must be more than 50% beneficially owned and controlled by citizens. Applicants, partners and directors need at least one year of relevant full-time experience. Firms providing any other payment service hold an SPI or MPI licence instead, which may also include money-changing.
Each SPI or MPI licence lists the services the firm may provide. Applicants select every service their model touches, and MAS reviews each against the business plan and a legal opinion that analyses the proposed model service by service.
| Payment service | Typical business |
|---|---|
| Account issuance | Issuing and operating payment accounts, such as e-wallets and multi-currency accounts |
| Domestic money transfer | Accepting and moving money between payers and payees in Singapore |
| Cross-border money transfer | Remittance and international payouts, including facilitation where no money touches Singapore |
| Merchant acquisition | Contracting with merchants to accept and process card and wallet payments |
| E-money issuance | Issuing stored value that customers use to pay merchants or other people |
| Digital payment token service | Dealing in, exchanging, transferring or holding in custody digital payment tokens |
| Money-changing | Buying and selling foreign currency notes |
The April 2024 amendments widened two services. Digital payment token services now include custody of tokens and the facilitation of token transfers and exchange, even where the provider never comes into possession of the money or tokens. Cross-border money transfer now includes facilitation between other countries, even where money is not accepted or received in Singapore. Firms with platform or marketplace models should test both definitions before choosing their services.
MAS sets financial requirements in its Guidelines on Licensing for Payment Service Providers (PS-G01, last revised 8 October 2025) and in the PS Act.
An SPI applicant needs base capital of at least S$100,000 and an MPI applicant at least S$250,000. Base capital is paid-up ordinary share capital, plus qualifying irredeemable non-cumulative preference shares and retained profit or loss, less interim losses and declared dividends. MAS expects a buffer above the minimum and states that base capital should ideally cover six to twelve months of operating expenses, so the business plan and forecasts set the real figure.
Before it starts business, an MPI must lodge security with MAS:
The security may be a cash deposit with MAS or a bank guarantee in the prescribed format. SPIs and money-changers lodge no security.
Under section 23 of the PS Act, an MPI that provides domestic money transfer, cross-border money transfer or merchant acquisition must safeguard relevant money no later than the next business day after receiving it. For e-money issuance, safeguarding applies from the moment the money is received. The Act permits three methods, each with a safeguarding institution: an undertaking to be fully liable to the customer, a guarantee for the amount, or a trust account.
Digital payment token providers have their own customer asset rules. Since October 2024, they must keep customer assets separate, hold them in trust for customers, keep proper books and records, and maintain controls over the integrity and security of those assets.
MAS licenses firms that are run from Singapore. The MAS licence criteria and the licensing guidelines set out what that means in practice.
The board of a Singapore company must include either:
MAS defines an executive director as a person involved in day-to-day operations and executive decisions, and expects that person to be resident in Singapore. Nominee directors, such as investors, legal advisers or corporate secretaries, do not count.
MAS also weighs the commitment of any holding company to the Singapore operation and may ask majority shareholders or the parent for a letter of responsibility or undertaking. The template is provided if the application is approved.
MAS assesses a complete, firm-specific application filed online through its eLicensing portal, in English or with certified translations. The MAS application checklist lists the core documents:
Firms offering online financial services must run a penetration test, remediate all high-risk findings and have the remediation independently validated. This can be completed after filing but must be done before MAS grants the licence. Internet-facing systems are then tested at least once a year or after major changes.
Applicants set out independent audit arrangements proportionate to the business. Once licensed, section 37 of the PS Act requires an annual audit of accounts, transactions and compliance at the firm's own expense, with the auditor reporting to MAS on Form 4.
Digital payment token (DPT) applicants follow the same SPI or MPI route, with further steps that MAS applies to crypto businesses:
MAS also applies retail conduct measures, which took effect in phases from mid-2024. DPT providers must assess a retail customer's risk awareness before giving access, may not offer incentives to trade, may not provide financing, margin or leverage, and may not accept locally issued credit card payments. Further rules cover conflicts of interest, token listing policies, complaints and the availability of critical systems.
Firms licensed under the PS Act to serve Singapore customers may also serve customers overseas. A Singapore entity that serves only overseas customers falls under the digital token service provider regime in the Financial Services and Markets Act 2022, where MAS has said it sets a high bar and will generally not issue a licence.
Singapore regulates stablecoins in two layers. A stablecoin that is not MAS-regulated is treated as a digital payment token, so dealing in it, exchanging it or holding it in custody is a DPT service under an SPI or MPI licence. A single-currency stablecoin issued in Singapore and pegged to the Singapore dollar or a G10 currency falls within the MAS single-currency stablecoin (MAS-SCS) framework.
On 15 August 2023 MAS finalised its stablecoin framework, with these core requirements for issuers:
Only issuers that meet every requirement may describe their tokens as "MAS-regulated stablecoins". Misusing the label can lead to financial penalties, imprisonment for individuals and listing on the MAS Investor Alert List.
On 1 September 2026 MAS published its consultation on amendments to the PS Act to put the framework into law (consultation P015-2026). The consultation closed on 16 October 2026. It covers:
MAS has not announced a commencement date. Issuers preparing now build the reserve, custody and redemption arrangements to the 2023 framework and track the final legislation. Our stablecoin licensing page sets out how Singapore sits alongside the United States, European Union, United Kingdom and Hong Kong regimes.
MAS charges a non-refundable application fee and an annual licence fee. The application fee is the higher of a minimum or the sum of the fees for each service applied for.
| Fee | Standard payment institution | Major payment institution |
|---|---|---|
| Minimum application fee | S$1,000 | S$1,500 |
| Account issuance | S$0 | S$0 |
| Domestic money transfer | S$1,000 | S$1,500 |
| Cross-border money transfer | S$1,000 | S$1,500 |
| Merchant acquisition | S$1,000 | S$1,500 |
| E-money issuance | S$1,000 | S$1,500 |
| Digital payment token | S$1,000 | S$1,500 |
| Money-changing | S$500 | S$500 |
| Annual licence fee | S$5,000 or the sum of service fees, whichever is higher | Per service, under the Payment Services Regulations 2019 |
A stand-alone money-changing licence costs S$500 to apply for and S$1,500 a year. Professional costs sit on top: the legal opinion, the external auditor's assessment for DPT applicants, the penetration test and the annual audit.
The PS Act sets no decision period. MAS states on its Form 1 application page that there is a significant wait before an officer is available to review an application and that the current estimated waiting period is more than a year.
| Stage | What happens | Timing points |
|---|---|---|
| Preparation | Entity, office, board, capital, business plan, legal opinion and AML/CFT pack | ACRA profile dated within 30 days of filing; DPT auditor report within 3 months |
| Filing | Form 1 and attachments through the MAS eLicensing portal, with the fee | Searchable, English-language documents |
| Waiting period | Queue until a case officer is assigned | MAS estimate: more than a year |
| Review | MAS questions, penetration test validation, in-principle approval for DPT firms | An application may be put on hold for up to six months, not extendable |
| Licence | E-licence issued by email and listing in the MAS Financial Institutions Directory | MPI security lodged before business starts |
The waiting period is set by application volume; the review that follows moves at the pace of the applicant's answers. A complete pack and technology evidence prepared in advance keep that review short.
Banking runs in parallel with the licence application, because a licensed firm cannot trade without it. A Singapore payment institution typically needs four arrangements:
DPT providers also need trust arrangements for customer tokens and fiat money, and custody that meets the segregation rules. Banks carry out their own due diligence on payment and DPT clients, so the same governance, AML/CFT and ownership material prepared for MAS forms the core of each bank onboarding pack. Our banking access service arranges operating, safeguarding and settlement accounts alongside the licence.
The licence is issued by email and the firm appears in the MAS Financial Institutions Directory. Obligations then continue for the life of the licence:
Adding a service, such as DPT services for an existing licensee, is a variation filed on Form 2, with the external auditor's report where DPT services are added.
Three questions settle the licence choice for most firms.
For regional groups, the decision sits within a wider Asia Pacific plan: Singapore for the hub, with licences in Hong Kong, Australia and other markets where customers sit. With a waiting period of more than a year, the strongest plans file early, with the full board, office and capital in place, and arrange banking during the wait so that trading starts on the day the e-licence arrives.
Both cover the same seven payment services. An SPI must stay within S$3 million of monthly transactions for one service, S$6 million across two or more and S$5 million of daily e-money float. An MPI has no such limits but needs S$250,000 base capital, a security deposit and safeguarding of customer money.
There is no statutory decision period. MAS states that the current estimated waiting period before an officer reviews an application is more than a year, and the review follows after that.
Base capital of S$100,000 for an SPI and S$250,000 for an MPI, plus a buffer. MAS states base capital should ideally cover six to twelve months of operating expenses. An MPI also lodges security of S$100,000 or S$200,000.
Yes. The board must include an executive director who is a Singapore citizen or permanent resident, or an executive director on an Employment Pass together with a non-executive director who is a citizen or permanent resident.
Yes. Digital payment token services are one of the seven payment services under an SPI or MPI licence. Applicants also file an external auditor's assessment of AML/CFT and consumer protection, signed within three months before applying.
MAS finalised its single-currency stablecoin framework in August 2023 and consulted from 1 September to 16 October 2026 on PS Act amendments to license issuers of stablecoins pegged to the Singapore dollar or a G10 currency. No commencement date has been announced.
S$1,000 or the sum of per-service fees for an SPI, and S$1,500 or the sum of per-service fees for an MPI, whichever is higher. The fee is non-refundable. A money-changing licence costs S$500 to apply for.
Buckingham Capital Consulting obtains payment, e-money, digital payment token and stablecoin licences, including MAS standard and major payment institution licences, and arranges the banking and technology that licensed firms need.
Speak to an expert: WhatsApp +44 7563 115980, Telegram @buckinghamcapital or [email protected].
This article is general information, not legal advice. Requirements change, and the regulator’s own publications take precedence.