Why the PSA 2019 Matters for APAC Fintechs
Singapore's Payment Services Act 2019 (PSA) came fully into force in January 2020. It replaced the old Payment Systems (Oversight) Act and the Money-Changing and Remittance Businesses Act, and significantly expanded the range of payment activities that require MAS licensing. If you process payments in Singapore — even as an intermediary — you likely need a PSA licence.
The Three Licence Tiers
| Licence Type | What it covers | Key thresholds |
|---|---|---|
| Money-Changing Licence (MCL) | Exchange of physical currency notes only | No transaction volume limit |
| Standard Payment Institution (SPI) | Any PSA payment service below major thresholds | <SGD 3M/month transaction volume OR <SGD 5M e-money outstanding |
| Major Payment Institution (MPI) | Any PSA payment service above the thresholds above | ≥SGD 3M/month OR ≥SGD 5M e-money outstanding |
The 7 Regulated Payment Services
- Account issuance service — issuing a payment account (e.g., e-wallet, prepaid card)
- Domestic money transfer service — transferring money within Singapore between accounts
- Cross-border money transfer service — sending or receiving money across borders (traditional remittance)
- Merchant acquisition service — enabling merchants to accept card or PayNow payments
- E-money issuance service — issuing electronic money stored on a device or account
- Digital payment token (DPT) service — buying, selling, or facilitating exchange of cryptocurrencies
- Money-changing service — exchanging physical currency notes
Which Licence for Common Fintech Business Models
B2B Payment Platform (cross-border, SGD 1–5M/month)
Service type: Cross-border money transfer. Below SGD 3M/month threshold → Standard Payment Institution licence. If you expect to grow past this, apply for MPI now — upgrading mid-business is operationally disruptive.
E-wallet / Neobank
Services: Account issuance + domestic money transfer + possibly e-money issuance. If e-money float will exceed SGD 5M → Major Payment Institution. Below SGD 5M float → SPI. Note: MPI holders must comply with MAS Notice 626 CDD, while SPI holders comply with lighter Notice 3001.
Crypto Exchange (DPT Service Provider)
Must hold MPI licence for DPT services. Additionally subject to MAS PSN01 (AML/CFT) and PSN02 (Travel Rule) regardless of transaction volume.
Marketplace / Platform that Collects Payments
If your platform collects money from buyers and holds it before paying sellers, you are likely conducting a domestic money transfer or merchant acquisition service. Take legal advice — many marketplace operators were surprised to require a PSA licence.
Key AML/CFT Obligations by Licence Type
| Obligation | SPI | MPI |
|---|---|---|
| CDD on customers | MAS Notice 3001 (lighter) | MAS Notice 626 (full bank standard) |
| Ongoing transaction monitoring | Required | Required |
| Travel Rule (DPT) | Required if DPT | Required if DPT |
| Suspicious Transaction Report | Required | Required |
| Annual audit | Not required below S$5M revenue | Required |
Key Takeaways
- Most Singapore fintechs processing payments need either SPI or MPI — determine which by calculating your monthly transaction volume and e-money float
- If you offer DPT services, MPI is mandatory regardless of volume
- SPI carries lighter CDD obligations; MPI requires full MAS Notice 626 compliance
- Apply for the licence tier you expect to reach in 18–24 months, not just today's volume — upgrading is operationally costly
- Collect payments via a marketplace or B2B platform? Get legal advice on whether you are an unlicensed payment service provider