Overview
Payment Services Act 2019 & MPI vs SPI
Singapore's Payment Services Act (PSA), enacted in January 2020, consolidated the Payments and Settlement Systems Act and the Money-Changing and Remittance Businesses Act into a single, comprehensive framework. The PSA introduced two licence tiers: Standard Payment Institution (SPI) for lower-volume operations, and Major Payment Institution (MPI) for firms exceeding the volume thresholds or needing the full regulatory imprimatur.
The PSA regulates seven payment service categories: account issuance services, domestic money transfer services, cross-border money transfer services, merchant acquisition services, e-money issuance services, digital payment token (DPT) services, and money-changing services. Firms can apply for a licence covering one or multiple service categories.
The MPI licence applies when a firm's monthly transaction volume exceeds S$3 million for any single service type, or S$6 million across all services combined. For e-money specifically, the MPI threshold applies when average daily outstanding e-money exceeds S$5 million. All crypto exchange and DPT custodial services require MPI (or SPI) with DPT permissions regardless of volume.
MAS is internationally regarded as one of the world's most thorough but fair regulators. Its supervisory approach is risk-based, and its published guidance is detailed. Singapore is also notable for bilateral payment system linkages: the UPI-PayNow linkage with India allows instant cross-border transfers between Singapore and India, and similar linkages exist with Thailand (PromptPay), Malaysia (DuitNow), and other ASEAN countries.
Capital & Safeguarding
Capital Requirements & Safeguarding Rules
Base Capital (Transfer)
S$1,000,000
Domestic or cross-border transfer MPI
Base Capital (E-money only)
S$250,000
E-money issuance service only
Safeguarding Threshold
S$5,000,000
Daily avg e-money — trust account required
DPT Service Capital
S$250,000
Additional for digital payment token services
SPI vs MPI
SPI vs MPI: Which Licence Fits?
| Feature | Standard PI (SPI) | Major PI (MPI) |
|---|---|---|
| Monthly volume cap | S$3M/service; S$6M total | No cap |
| Min base capital | S$100,000 | S$250K–S$1M |
| Safeguarding | Not required (below threshold) | Required above S$5M daily avg |
| DPT services | Available (lower threshold) | Available (full scope) |
| Best for | Startups, MVP | Scale operators |
Process
Step-by-Step MAS MPI Application
1
Incorporate Singapore Entity
Register a Singapore private limited company (Pte Ltd) with ACRA. Appoint at least one Singapore-resident director. The company must be incorporated before MAS application can be filed.
1–2 weeks2
Determine Licence Scope
Identify which PSA service categories you need (e.g., e-money issuance + domestic transfer + DPT). MAS application is category-specific. Capital requirements are additive for multiple service types.
Week 1–33
Prepare Application Documents
Prepare the MAS application form plus supporting documents: business plan, financial projections, AML/CFT policies (MAS AML Notice for PSPs), IT security documentation, governance framework, and personal declarations for directors and 10%+ shareholders.
8–16 weeks4
Submit MAS Application Online
File through MAS's Licence Application Repository and Information (LARI) system. Pay application fee (S$1,000 for SPI; higher for MPI). MAS acknowledges and assigns case officer.
Month 3–45
MAS Review & Queries
MAS conducts detailed review including fit-and-proper assessment of shareholders/directors, business model viability, technology risk assessment, and AML/CFT programme evaluation. May request additional documents or management meetings.
Months 4–106
Licence Grant & Operational Launch
MAS grants licence for specified payment services. Establish safeguarding arrangements (trust account with MAS-approved bank). Implement ongoing MAS reporting obligations. Launch services in Singapore.
Month 6–12◆ KEY REQUIREMENTS
Singapore EMI Essentials
SGD 500,000
Minimum Capital Requirement
4–6 Months
Processing Timeline
SGD 2,500
Annual Licence Fee
17%
Corporate Income Tax Rate
Monetary Authority of Singapore
Regulator (MAS)
ASEAN Gateway Status
Key Strategic Benefit
◆ APPLICATION ROADMAP
Licensing Timeline for 2026
1
Week 1–2
Eligibility & Pre-Submission Review
Confirm SPI/EMI classification under PSA 2019, prepare corporate structure, verify beneficial ownership, and engage MAS-approved compliance advisors.
2
Week 3–8
Document Compilation & AML/CFT Framework
Compile financial statements, business plan, risk management policies, anti-money laundering controls, and customer due diligence procedures per MAS Notice 757.
3
Week 9–10
Formal Application Submission
Submit completed Form PSA-PI-001 to MAS with all supporting documentation, proof of SGD 500,000 capital, and IT security audit reports.
4
Month 2–4
MAS Assessment & Clarifications
MAS conducts due diligence, requests additional documentation, reviews governance structure, and assesses operational resilience under PSA Schedule 2.
5
Month 5–6
Licence Issuance & Compliance Commencement
Receive Standard Payment Institution Licence, pay annual SGD 2,500 fee, and commence regulated payment services under MAS supervision.
FAQ
Frequently Asked Questions
An SPI operates below volume thresholds (S$3M/month per service, S$6M combined) with lower capital requirements. An MPI operates above these thresholds with higher capital (S$1M for transfer services) and safeguarding requirements. All DPT services require a PSA licence regardless of volume.
An MPI licence can cover: account issuance, domestic money transfer, cross-border money transfer, merchant acquisition, e-money issuance, digital payment token (DPT/crypto) services, and money-changing. Firms apply for the specific service categories they need.
Base capital: S$1M for domestic or cross-border transfer; S$250K for e-money issuance or DPT services only. Safeguarding in a trust account is required when average daily outstanding e-money exceeds S$5M.
Yes. MAS includes Digital Payment Token (DPT) services as a regulated activity under the PSA. Firms providing crypto exchange, transfer, or custody require MPI or SPI with DPT permissions. MAS scrutiny of DPT licence applications is particularly thorough.
Initial application fees to MAS are approximately S$2,500–S$5,000, plus professional advisory costs (typically S$30,000–S$80,000 depending on complexity). Total licensing timeline is 8–16 weeks from submission to in-principle approval, followed by 4–8 weeks for final approval after meeting all conditions. Total out-of-pocket costs usually range from S$50,000–S$150,000 including legal, compliance, and setup expenses.
MAS requires at least one director and a local representative/compliance officer physically based in Singapore. You must also maintain a registered office in Singapore with documented governance structures. Remote operation from Switzerland is not permitted for the principal management function, though back-office operations can be managed offshore if properly segregated and supervised.
You must establish a relationship with a local Singapore bank for operational accounts and maintain a separate trust account (with a bank or capital markets services licence holder) for customer fund safeguarding. Major banks (DBS, OCBC, UOB) typically require compliance documentation, business plans, and proof of MAS approval or in-principle approval before opening accounts. Plan 4–8 weeks for banking onboarding after regulatory approval.
Standard corporate income tax is 17% on profits derived from Singapore-sourced activities, with exemptions available for the first S$75,000 of profit (100% exemption) and the next S$75,000 (50% exemption) for newly incorporated companies in their first three years. MPI licence holders may also benefit from Pioneer Certificate status if engaged in technology-driven financial services, potentially reducing tax to 5–10% for 5–10 years depending on the approved activity.
MAS conducts on-site supervisory visits typically within the first 12 months post-approval and annually thereafter, focusing on AML/CFT controls, transaction monitoring, customer due diligence, and safeguarding arrangements. You must prepare for regulatory reports (quarterly transaction reports, annual audited financial statements, compliance certifications) and ad-hoc data requests. Non-compliance can result in fines (up to S$1M) or licence suspension.
No; once you breach MPI thresholds (S$3M/month per service or S$6M combined), you must maintain MPI status and cannot revert to SPI. However, if volumes decline and remain below thresholds for 12 consecutive months, you may apply to MAS for voluntary conversion to SPI status, which involves reduced capital and compliance requirements. Downgrading requires formal MAS approval and takes 4–6 weeks.
MAS does not maintain a formal blacklist, but you must conduct country-risk assessments and ensure compliance with international AML/CFT standards (FATF recommendations). High-risk jurisdictions (sanctioned countries, FATF grey-list nations) require enhanced due diligence and MAS pre-notification. Singapore's bilateral payment corridors (with India, Malaysia, Thailand, Philippines, Hong Kong) are actively promoted and carry lower compliance friction.
Singapore offers English common law, political stability, deep banking infrastructure, 17% corporate tax, and bilateral payment linkages with India (UPI-PayNow), Thailand, Malaysia, and other ASEAN countries. MAS is an internationally respected regulator.