Payments licensing overview

Your business description

Centralised crypto exchange with decentralised settlement. Looking to issue our own utility token and apply for Payment Service licence.

What is a payment service provider licence?


MAS regulates the activities carried out in relation to cryptocurrencies. Under the Payment Services Act 2019, a payment service provider licence (PS licence) is required if a person or business engages in any of the regulated activities stipulated in the Payment Services Act 2019.

According to MAS (Pages)
last revised on 23 September 2021

Payment service providers and payment systems are both regulated under the Payment Services Act 2019 ("PS Act"). Payment service providers are licensed to provide specified payment services under the PS Act. Payment systems facilitate the transfer of funds between or among participants and may be designated under the PS Act for closer supervision.

What are examples of Payment Services that do not fall within the scope of the PSA?


a. Limited purpose e-money

b. Limited purpose digital payment tokens

c. Payment services conducted by licensed or exempt entities regulated under the Securities and Futures Act and the Financial Advisers Act.


Some examples of payment service providers exempt from the PSA include the follow:

  • Banks;
  • Merchant banks;
  • Finance companies;
  • Non-bank credit cards or charge card issuers

However, it is notable that these entities are regulated under the respective legislation and may have to comply with other requirements in the PSA that do not overlap with existing legislation applicable to them.

Which payment activities are regulated under the PSA and require a licence?


According to MAS (Pages)

last revised on 23 September 2021

MAS regulates seven payment services under the PS Act:

Activity Type Brief Description
Activity A: Account issuance service The service of issuing a payment account or any service relating to any operation required for operating a payment account, such as an e-wallet (including certain multi-purpose stored value cards) or a non-bank issued credit card.
Activity B: Domestic money transfer service Providing local funds transfer service in Singapore. This includes payment gateway services and payment kiosk services.
Activity C: Cross-border money transfer service Providing inbound or outbound remittance service in Singapore.
Activity D: Merchant acquisition service Providing merchant acquisition service in Singapore where the service provider processes payment transactions from the merchant and processes payment receipts on behalf of the merchant. Usually the service includes providing a point-of-sale terminal or online payment gateway.
Activity E: E-money issuance service Issuing e-money to allow the user to pay merchants or transfer to another individual.
Activity F: Digital payment token service Buying or selling digital payment tokens (“DPTs”) (commonly known as cryptocurrencies), or providing a platform to allow persons to exchange DPTs.
Activity G: Money-changing service Buying or selling foreign currency notes.

 

Save for the services listed in Part 2, First Schedule of the PSA, the following are seven (7) types of payment services regulated under the PSA:

  1. An account issuance service;
  2. A domestic money transfer service;
  3. A cross-border money transfer service;
  4. A merchant acquisition service;
  5. An e-money issuance service;
  6. A digital payment token service;
  7. A money-changing service.

 

PS licence: SPI vs MPI vs Money-changing


The three (3) types of licenses that payment service provides can hold to provide services under the PSA are:

(a) Money-Changing Licence;
(b) Standard Payment Institution Licence;
(c) Major Payment Institution Licence.

Payment service providers can conduct multiple payment services under one licence.

According to MAS (Pages)
last revised on 23 September 2021

Payment service providers can conduct multiple payment services under one licence. There are three types of licences that payment service providers can hold to provide the payment services above:

Money-Changing Licence 

  • Money-Changing licensees are only able to conduct money-changing services.

Standard Payment Institution Licence

  • Standard Payment Institutions are able to conduct multiple payment services below specified thresholds.

Major Payment Institution Licence

  • Major Payment Institutions are able to conduct multiple payment services without any limits on transaction volume or float.

See also: Standard vs Major Payment Institution Licence.