Regulations for all Payment Services Providers

Does the calculation of the SPI threshold for e-money issuance include e-money that has already been spent?

According to MAS (FAQs)

last revised 31 March 2021

49.1 In computing whether an entity holds a daily average e-money float that exceeds the threshold of $5 million, the value of the e-money that has been spent by the payment service user is excluded. The total annual value of the e-money float is to be divided by the total number of days in a calendar year, and not only for the days when there was e-money issuance.