MAS Payment Services Act licensing — MPI and SPI — Eligibility and requirements checklist
MAS Payment Services Act licensing governs anyone providing regulated payment services in Singapore, from digital wallets to cross-border remittance. The Payment Services Act 2019 sets two main licence tiers, the Standard Payment Institution (SPI) and the Major Payment Institution (MPI), separated by transaction and float thresholds.
Raffles Corporate Services works with a panel of corporate and employment law firms; this article is general information, not legal advice.
What MAS Payment Services Act licensing covers
The Payment Services Act 2019 regulates seven payment services, including account issuance, domestic money transfer, cross-border money transfer, merchant acquisition, e-money issuance, digital payment token services and money-changing. Section 5 of the Payment Services Act 2019 defines these activities, and section 6 establishes that a person carrying on a business of providing any of them must hold a licence unless exempt.
Firms self-assess which of the seven services they perform, then map those services to a licence class. A single licence can authorise multiple services, which keeps growing fintechs from holding several separate approvals.
SPI versus MPI: the thresholds that decide your class
The distinction between a Standard Payment Institution and a Major Payment Institution is quantitative. An SPI is available where monthly transaction volumes stay below S$3 million for any single payment service and below S$6 million across two or more services, and where average daily e-money float stays below S$5 million.
Cross those ceilings and you must hold an MPI licence, which has no upper transaction limit but imposes safeguarding of customer money, higher capital and fuller compliance. Money-changing carries its own dedicated licence class. Managers building fund-adjacent payment rails should also review how a regulated manager sits alongside a Singapore vehicle in our note on the VCC Act 2018 — Section 50 director residency requirements — Timeline and processing benchmarks.
Eligibility and ongoing obligations
Applicants must be a Singapore-incorporated company (or a registered foreign company) with a permanent place of business, at least one executive director resident in Singapore, and a fit-and-proper board and shareholder base. Base capital is S$100,000 for an SPI and S$250,000 for an MPI, and MPIs must additionally safeguard customer funds through an undertaking, guarantee or trust arrangement.
All licensees must maintain anti-money-laundering and countering-the-financing-of-terrorism controls, appoint a compliance officer, and file periodic and transaction reports to MAS. These obligations flow from the Payment Services Act 2019 and its subsidiary regulations and notices.
Cost and timeline benchmarks
MAS charges tiered application fees per payment service, typically S$1,000 to S$1,500 each. The larger costs are professional: legal, compliance build and AML systems commonly run S$40,000 to S$120,000 for an MPI, less for a straightforward SPI.
Timelines are longer than many founders expect. Allow around 4 months for an SPI and 6 months or more for an MPI from complete submission, extended where safeguarding arrangements, group ownership or novel token services require deeper review. Foreign founders should also budget time to incorporate; see Nominee director services — foreigner essentials — Eligibility and requirements checklist.
Step-by-step application process
Map your services to the seven regulated activities. Choose SPI or MPI against the thresholds. Incorporate and appoint a resident executive director. Build AML/CFT policies and a compliance function. Submit the application through the MAS portal with business plan, financial projections and fit-and-proper declarations. Arrange safeguarding for an MPI. Respond to queries and, on approval, commence within any conditions MAS imposes.
For the timeline-first view of the same licensing pathway, see the MAS Payment Services Act licensing — MPI and SPI — Timeline and processing benchmarks.
Common mistakes
The classic error is assuming an SPI will suffice, then breaching the thresholds within months and scrambling for an MPI. Model your volumes honestly and apply for the tier you will actually need. A second error is weak AML systems; MAS scrutinises transaction monitoring closely for payments firms.
Confirm the current rules directly with the Monetary Authority of Singapore at mas.gov.sg and the statute at sso.agc.gov.sg before relying on any summary.
FAQs
What is the difference between an SPI and an MPI?
An SPI operates below set monthly transaction and float thresholds and holds S$100,000 base capital. An MPI has no transaction ceiling, must safeguard customer funds and holds S$250,000 base capital.
Do I need a separate licence for each payment service?
No. A single Payment Services Act licence can authorise multiple regulated services, subject to meeting the requirements for each.
How long does MPI licensing take?
Plan for 6 months or more from a complete submission, longer where safeguarding or group structures require additional review.
Is a Singapore company required?
Yes. Applicants must be a Singapore-incorporated company or registered foreign company with a permanent place of business and a resident executive director.
Related guides
- VCC Act 2018 — Section 50 director residency requirements — Timeline and processing benchmarks
- Nominee director services — foreigner essentials — Eligibility and requirements checklist
- MAS Payment Services Act licensing — MPI and SPI — Timeline and processing benchmarks
Need help with this? Call, SMS or WhatsApp +65 8501 7133, or email [email protected]. Raffles Corporate Services works with a panel of corporate and employment law firms; this article is general information, not legal advice.