Regulations for E-wallets
Is the topping up of e-wallets a regulated activity?
It is if the e-wallet operator providing the top-up service is also regarded as providing an account issuance service.
According to MAS (FAQs)
last revised on 31 Mar 2021
"18.1 ...where the service provider (Business X) accepts money from a customer for the purpose of sending the money to an e-wallet operator, so that the e-wallet operator can top up the customer’s payment account. Business X does not provide an account issuance service because it does not operate the payment account and top up the payment account. Instead, it only hands over the money to the e-wallet operator.
18.2 Business X would however be providing an account issuance service in a situation where Business X (rather than the e-wallet operator) operates the payment account and tops up the payment account. In that situation, Business X will need to hold a licence to provide an account issuance service, unless it is exempted."