Payment Services Act (Singapore)— What is regulated?

Darshita
FinTech & Law
Published in
2 min readJan 9, 2020

The Payment Services Act 2019 (No. 2 of 2019) (the “PS Act”) came into force on 28 January 2020, repealing the Payment Systems (Oversight) Act (the “PS(O)A”) and the Money-changing and Remittance Businesses Act (the “MCRBA”). All businesses that carry out one or more regulated payment activities under the PS Act will require a payment service provider licence.

Regulated Payment Activities

The types of payment services that will be regulated under the PS Act are:

Types of payment service provider licences

There are three main payment service provider licences:

(i) Major payment institution licence (“MPI Licence”);

(ii) Standard payment standard institution licence (“SPI Licence”); and

(iii) Money-changing licence.

The MPI Licence and SPI Licence are distinguished from each other based on the average monthly transaction value or the average daily e- money issued for the regulated payment service being conducted. A MPI Licence is required for businesses where:

(i) the average monthly transaction value exceeds S$3 million for one regulated payment service or S$6 million for two or more regulated payment services;

(ii) the average daily e-money issued exceeds S$5 million for an e-money issuance service; or

(iii) the average daily e-money stored in a payment account and/or issued exceeds S$5 million for an e-money account issuance service.

The criteria to obtain and to operate under a MPI Licence is of a higher standard than that of the SPI Licenceand may include additional obligations on the MPI Licence holder to safeguard customers’ monies, maintain a security deposit with MAS and to meet certain compliance requirements.

The opinions expressed in this article are my own and do not represent the opinions of my employer. This article does not constitute legal advice or a legal opinion on any matter discussed and, accordingly, it should not be relied upon. It should not be regarded as a comprehensive statement of the law and practice in this area. If you require any advice or information, please speak to a suitably qualified lawyer in your jurisdiction. The author does not accept or assume any responsibility or liability in respect of this article.

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