MAS Payment Services Act licensing — MPI and SPI — Documents required and templates
MAS Payment Services Act licensing sorts payment businesses into two main licence classes: the Standard Payment Institution (SPI) for smaller-scale operators and the Major Payment Institution (MPI) for firms above the transaction thresholds. This guide explains which class you fall into, the documents MAS expects, the capital you must hold, and the templates that keep an application on track under the Payment Services Act 2019.
Raffles Corporate Services works with a panel of corporate and employment law firms; this article is general information, not legal advice.
What the Payment Services Act covers
The Payment Services Act 2019 regulates seven activities: account issuance, domestic money transfer, cross-border money transfer, merchant acquisition, e-money issuance, digital payment token (DPT) services, and money-changing. A single licence can cover multiple activities, and the class of licence — SPI or MPI — depends on the scale at which you carry them on.
SPI versus MPI — where the line sits
You need an MPI licence, rather than an SPI, once monthly transactions for any single payment service reach S$3 million or more, or S$6 million across two or more services, or where the daily outstanding e-money float reaches S$5 million or more. Below those thresholds an SPI licence is appropriate. Money-changing has its own dedicated licence. Section 6 of the Payment Services Act 2019 establishes that a person must not provide a payment service unless licensed or exempt.
Eligibility and base capital
An applicant must be a Singapore-incorporated company (or a foreign company registered here) with a permanent place of business, at least one executive director resident in Singapore, and a fit-and-proper management team. Base capital is at least S$100,000 for an SPI and at least S$250,000 for an MPI, rising to S$500,000 for an MPI providing DPT services or cross-border money transfer. MPIs must additionally safeguard customer money through a bank guarantee, trust account or equivalent, and appoint a permanent compliance arrangement.
Documents required
Assemble the Form 1 application via the MAS portal, the business plan and financial projections, the corporate structure and shareholder chart, fit-and-proper declarations for directors, shareholders and the CEO, the anti-money-laundering and countering-the-financing-of-terrorism (AML/CFT) policy, the technology risk and cyber-hygiene documentation, evidence of base capital, and the safeguarding arrangement for an MPI. Standing templates worth preparing in advance are the AML/CFT manual, the risk assessment matrix, and the outsourcing register.
Cost and timeline benchmarks
Application fees are S$1,000 for an SPI and S$1,500 for an MPI, per payment service applied for. Professional and setup fees commonly range from S$25,000 to S$80,000 depending on the number of activities and whether DPT is involved. MAS review timelines typically run four to six months for an SPI and six to nine months or longer for an MPI, particularly where DPT services attract enhanced scrutiny. Budget ongoing annual compliance, audit and safeguarding costs from S$80,000 upwards.
Common mistakes and gotchas
The classic error is applying for an SPI while planning volumes that will breach the MPI thresholds within months, forcing a re-application. Others under-build the AML/CFT programme, which is the single most scrutinised area, or overlook that DPT services carry both higher base capital and stricter conduct rules. Robust AML/CFT sits at the centre of every payments licence — our checklist on MAS AML/CFT for licensed entities is the natural companion. If your payments business will also run a fund or investment strategy, review whether a Variable Capital Company suits your redomiciliation plans in our note on VCC inward and outward redomiciliation, and if you are bringing in an overseas director, read the essentials of nominee director services for foreigners.
FAQs
What is the base capital for an MPI? At least S$250,000, or S$500,000 where the MPI provides DPT services or cross-border money transfer.
What triggers the move from SPI to MPI? Monthly transactions of S$3 million for a single service, S$6 million across services, or a daily e-money float of S$5 million.
How much are the application fees? S$1,000 for an SPI and S$1,500 for an MPI, charged per payment service.
How long does an MPI licence take? Commonly six to nine months, longer for DPT-inclusive applications.
Where are the rules set out? Licensing guidance is published by the Monetary Authority of Singapore, and the Payment Services Act 2019 is available on Singapore Statutes Online.
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.