Singapore Major Payment Institution Licence: MAS Requirements, Capital and Safeguarding
MAS Major Payment Institution licence: SGD 250,000 base capital, security deposit, section 23 safeguarding, local director rules, DPT obligations and the application process.
Written and reviewed by the Regulatory Counsel team. Last reviewed: 28 August 2026.
The short answer
A Major Payment Institution licence is the Payment Services Act licence class for firms whose volumes exceed, or are intended to exceed, the Standard Payment Institution thresholds: SGD 3 million average monthly transactions for any one payment service, SGD 6 million across two or more, or SGD 5 million of daily outstanding e-money.
An MPI holds base capital of SGD 250,000, lodges security with MAS of SGD 100,000 or SGD 200,000 depending on transaction volume before commencing business, and must safeguard relevant money under section 23 of the Act using an undertaking or guarantee from a safeguarding institution, a trust account, or a combination of the two.
The local substance requirements are the same as for an SPI: a Singapore-incorporated company, a permanent place of business, qualifying executive directors, a resident chief executive and a compliance officer at management level. The supervisory expectation is materially higher, because the licence carries no volume ceiling.
MAS does not publish a fixed processing period. Timelines are driven by the quality of the application and the number of MAS query rounds.
Key facts at a glance
| Regulator | Monetary Authority of Singapore |
|---|---|
| Permission type | Licence under the Payment Services Act 2019, Major Payment Institution class |
| Who needs it | Firms exceeding, or intending to exceed, SGD 3 million monthly for one service, SGD 6 million across two or more, or SGD 5 million daily outstanding e-money |
| Local entity required? | Yes. An ACRA-registered company with a permanent place of business in Singapore |
| Local management required? | Yes. At least one executive director who is a Singapore citizen or permanent resident, or an employment pass holding executive director plus a citizen or permanent resident director |
| Base capital | SGD 250,000 |
| Security to MAS | SGD 100,000 where average monthly transaction value does not exceed SGD 6 million for any one payment service, otherwise SGD 200,000. Lodged before commencing business |
| Safeguarding | Required under section 23 for relevant money, by undertaking or guarantee from a safeguarding institution, trust account, or a combination |
| Fees | Application and annual licence fees set per payment service in the Schedule to the Payment Services Regulations 2019 |
| Timeline | No MAS-published processing period |
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What is the Singapore Major Payment Institution Licence?
A Major Payment Institution licence is the Monetary Authority of Singapore licence class under the Payment Services Act 2019 for firms operating above the Standard Payment Institution thresholds. It carries base capital of SGD 250,000, a security deposit lodged with MAS, and the section 23 obligation to safeguard relevant money.
Who Needs Singapore Major Payment Institution Licence?
Firms whose Singapore payment activity exceeds, or is intended to exceed, the SPI thresholds.
- - Cross-border remittance businesses at scale
- - E-money issuers with daily outstanding float above SGD 5 million
- - Merchant acquirers and payment gateways processing above the thresholds
- - Digital payment token service providers with substantial Singapore-facing volume
- - Account issuance providers operating consumer or business wallets at scale
The MPI licence is often described as a premium version of the SPI licence. It is not optional positioning: once the thresholds are exceeded or intended, the MPI class is the only lawful one. Equally, an MPI licence does not authorise every payment service. The licence is granted for the services applied for, and adding a service requires a variation.
When the MPI licence is required
The trigger is volume, not business model. A firm must hold an MPI licence where its average monthly transactions exceed SGD 3 million for any one payment service, or SGD 6 million across two or more payment services, or where daily outstanding e-money exceeds SGD 5 million.
The test also captures intention. A firm whose forecasts show it crossing a threshold should apply as an MPI at the outset rather than obtaining an SPI licence and reapplying, because the second application arrives at the point of maximum commercial pressure.
- - Account issuance service, including e-wallets and non-bank credit card issuance
- - Domestic money transfer service, including payment gateway and payment kiosk services
- - Cross-border money transfer service, covering inbound and outbound remittance
- - Merchant acquisition service
- - E-money issuance service
- - Digital payment token service
- - Money-changing service
Capital and security
Base capital and security are distinct. Base capital is a permanent balance sheet requirement measured under the Act. Security is a separate lodged amount that sits outside working capital entirely.
- - Base capital of SGD 250,000, maintained continuously with a working buffer
- - Security lodged with MAS of SGD 100,000 where average monthly transaction value across a calendar year does not exceed SGD 6 million for any one payment service, and SGD 200,000 in all other cases
- - Security provided as a cash deposit with MAS or a bank guarantee in the form MAS prescribes
- - Security must be in place before business commences, not at the point volumes rise
Safeguarding relevant money under section 23
An MPI that receives relevant money must safeguard it. The permitted methods are an undertaking or guarantee from a safeguarding institution, deposit into a trust account maintained with a safeguarding institution for the benefit of customers, or a combination of methods across different amounts.
Where an undertaking or bank guarantee is used, MAS expects a legal opinion confirming that the arrangement satisfies section 23. Customers must be told which method applies to their money before it is first placed under that method.
Safeguarding is an operational discipline, not a document. Reconciliation frequency, the treatment of in-flight funds and the handling of receipts across corridors are where supervisory findings arise.
Digital payment token services as an MPI
Digital payment token service is a regulated payment service in its own right, and most substantial crypto businesses serving Singapore customers hold an MPI licence for it.
The additional layer is significant: MAS Notice PSN02 for anti-money laundering purposes, the consumer protection safeguards in Guidelines PS-G03 covering risk disclosure, customer assessment and restrictions on lending or staking retail customer assets, and the user protection requirements effective 4 October 2024 requiring segregation of customer assets into a statutory trust with supporting books, records and controls.
Governance, conduct and technology obligations
- - Fit and proper assessment of the applicant, directors, chief executive, shareholders and relevant employees under FSG-G01
- - A compliance officer at management level, with group support permitted only where Singapore oversight is demonstrable
- - Anti-money laundering framework under MAS Notice PSN01, or PSN02 for digital payment token services
- - Conduct obligations under MAS Notice PSN07, including transaction records, receipts, transmission timelines and disclosure of rates and fees
- - Cyber hygiene under MAS Notice PSN06, and technology risk management proportionate to the platform
- - Reporting of suspicious activities and fraud incidents under PSN03 and periodic returns under PSN04
Ongoing obligations after licensing
- - Maintenance of base capital and of the lodged security at the correct tier as volumes change
- - Section 23 safeguarding, including reconciliations and customer disclosure
- - Annual audit under the Payment Services Act and payment of the annual licence fee
- - Periodic regulatory returns, suspicious activity reporting and incident reporting
- - Notification of changes in directors, chief executive, shareholders, compliance officer and place of business
- - Variation applications before launching a payment service outside the licensed scope
Singapore SPI vs MPI: what actually differs
Both are licences under the same Payment Services Act. The distinction is transaction volume and e-money float, and the obligations that follow from them.
| Criterion | Standard Payment Institution | Major Payment Institution |
|---|---|---|
| Volume ceiling | Below SGD 3 million average monthly transactions for any one payment service, and below SGD 6 million across two or more | No ceiling. Required once any threshold is exceeded or is intended to be exceeded |
| E-money float | Below SGD 5 million daily outstanding e-money | No ceiling |
| Base capital | SGD 100,000 | SGD 250,000 |
| Security to MAS | Not required | SGD 100,000 or SGD 200,000 by transaction volume, lodged before commencing business |
| Safeguarding of relevant money | Not applicable in the same statutory form | Required under section 23 of the Payment Services Act |
| Typical use | Launch stage, a single corridor, or a contained domestic model | Scaling volumes, e-money float, or institutional and enterprise distribution |
The thresholds are tested on intention as well as actual volume. A firm that plans to exceed them applies for an MPI licence rather than upgrading later.
Singapore MPI compared with a UK EMI
Firms building an Asia and UK footprint frequently run these two permissions in parallel. They are not equivalents.
| Criterion | Singapore MPI | UK EMI |
|---|---|---|
| Regulator | Monetary Authority of Singapore | Financial Conduct Authority |
| Framework | Payment Services Act 2019 | Electronic Money Regulations 2011 with the Payment Services Regulations 2017 |
| Capital | Base capital SGD 250,000 plus lodged security | Initial capital EUR 350,000 plus own funds under Method D |
| Customer money | Section 23 safeguarding by undertaking, guarantee or trust account | Safeguarding by segregation, insurance or comparable guarantee, with CASS 15 from 7 May 2026 |
| Crypto | Digital payment token service is a licensable payment service | Cryptoasset activity requires separate registration under the Money Laundering Regulations |
| Territorial reach | Singapore | United Kingdom, with no EEA passporting |
Key Requirements
Base capital
SGD 250,000, maintained on an ongoing basis with a buffer above the minimum.
Security
SGD 100,000 where average monthly transaction value across a calendar year does not exceed SGD 6 million for any one payment service, otherwise SGD 200,000, lodged as a cash deposit with MAS or a bank guarantee in the prescribed form before commencing business.
Safeguarding
Relevant money safeguarded under section 23 by an undertaking or guarantee from a safeguarding institution, a trust account with a safeguarding institution, or a combination, with a legal opinion where an undertaking or guarantee is used.
Local substance
ACRA-registered company, permanent place of business in Singapore, qualifying executive directors, resident chief executive and a compliance officer at management level.
Financial crime framework
Anti-money laundering and counter financing of terrorism arrangements meeting MAS Notice PSN01, or PSN02 for digital payment token services, with customer due diligence, monitoring, screening and reporting.
Reporting and audit
Periodic returns under PSN04, suspicious activity and fraud incident reporting under PSN03, and the annual audit required by the Payment Services Act.
What a Singapore MPI licence costs
The distinction that matters for budgeting is between fees, which are modest, and locked capital. Base capital plus security means at least SGD 350,000 of the balance sheet is committed before a single transaction is processed.
- - MAS application fee and annual licence fee: set per payment service in the Schedule to the Payment Services Regulations 2019. Confirm current figures against the live Schedule
- - Base capital: SGD 250,000, maintained continuously
- - Security to MAS: SGD 100,000 or SGD 200,000 by transaction volume, lodged as cash or a prescribed bank guarantee before commencing business
- - Safeguarding: bank guarantee or trust account costs, plus the legal opinion where an undertaking or guarantee is used
- - Third-party costs: audit, anti-money laundering and screening systems, technology risk review, and local company administration
- - Regulatory Counsel: fixed fee agreed on scoping
The Application Process
Threshold and perimeter assessment
Confirm the MPI class against forecast volumes and map each payment service to be licensed.
Entity, management and compliance officer
Incorporate, appoint qualifying executive directors and the chief executive, and identify the compliance officer who will be employed before commencement.
Safeguarding and banking
Negotiate the section 23 arrangement with a safeguarding institution and obtain the supporting legal opinion where an undertaking or guarantee is used.
Application pack
Business plan, financial projections, governance, anti-money laundering framework, conduct policies, technology risk and cyber hygiene documentation.
Submission and query management
File through the MAS portal and manage the assessment. Query quality and turnaround determine elapsed time more than any other factor.
Security lodgement and commencement
Lodge the security at the correct tier, satisfy any conditions of approval and confirm operational readiness before providing regulated services.
MAS does not publish a determination period. Build the plan around preparation milestones and the safeguarding arrangement rather than an assumed approval date.
How long an MPI licence takes
MAS does not publish an indicative processing period for payment services applications. Timeframes circulating on advisory websites are not MAS commitments and should not be relied on for launch planning.
The elements that can be planned are the entity and management build, the compliance framework, the safeguarding arrangement with a bank, and the security lodgement. Of these, obtaining the safeguarding arrangement and the banking relationship is frequently the long pole, and it should be started in parallel with the application rather than after approval.
- - Perimeter and threshold assessment, and confirmation of the MPI class
- - Entity, directors, chief executive and compliance officer in place
- - Application pack, anti-money laundering framework and technology documentation prepared
- - Safeguarding arrangement negotiated and legal opinion obtained where required
- - MAS query rounds, which drive the remaining variability
- - Security lodged and pre-commencement conditions completed
Why Applications Fail - and How We Prevent It
Security lodged late
Security must be in place before business commences. Firms that treat it as a post-approval administrative step delay their own launch.
Safeguarding arrangement assumed
Section 23 requires a real arrangement with a safeguarding institution. Applications that describe an intention rather than an agreement attract sustained queries.
Scope creep after licensing
The licence covers the payment services applied for. Launching an adjacent service without a variation is a breach and is visible in the returns.
Retail crypto safeguards retrofitted
For digital payment token services, PS-G03 and the statutory trust requirements shape the product itself. Building the product first and the safeguards afterwards produces rework and supervisory attention.
Practitioner notes
- - Start the safeguarding institution conversation early. An application that cannot evidence a workable section 23 arrangement stalls regardless of how good the rest of the pack is
- - Track the security tier against actual volumes, because moving from SGD 100,000 to SGD 200,000 is a funding event
- - For digital payment token services, build to PS-G03 and the statutory trust requirement from day one rather than retrofitting retail safeguards
- - A compliance function supported from an overseas group is acceptable only where Singapore oversight is real and evidenced
- - Keep the licensed scope aligned with the roadmap. Launching an unlicensed payment service is a breach, not a variation opportunity
How Regulatory Counsel Can Help
Application management
Threshold analysis, perimeter scoping, the full MAS pack and management of the query rounds through to approval.
Safeguarding and capital design
Section 23 arrangement design, legal opinion coordination, security tiering and base capital planning.
Ongoing compliance
PSN04 returns, audit readiness, safeguarding reconciliation discipline and variation applications as the product set grows.
Regulatory Counsel advises firms on Major Payment Institution licensing and on the safeguarding, financial crime and reporting framework that has to operate afterwards. We do not claim a Singapore office or local staff. The value is regulatory depth on the Payment Services Act and its notices, and continuity between the application and the supervised business.
Related Licences
Singapore Standard Payment Institution Licence
The threshold-limited class, with SGD 100,000 base capital and no security requirement.
Hong Kong MSO Licence
The Hong Kong remittance and money changing permission.
UK Electronic Money Institution Licence
The comparable UK permission for stored value models.
Frequently Asked Questions
MAS sets application and annual licence fees per payment service in the Schedule to the Payment Services Regulations 2019, and those figures should be confirmed against the live Schedule. The financially significant commitments are base capital of SGD 250,000 and security of SGD 100,000 or SGD 200,000 lodged with MAS before commencing business.
MAS does not publish a processing period. The predictable phases are preparation, the safeguarding arrangement and the security lodgement. The unpredictable phase is the MAS query cycle, which is shortened by a complete and internally consistent application.
An SPI must remain below SGD 3 million average monthly transactions for a single payment service, SGD 6 million across two or more, and SGD 5 million of daily outstanding e-money. An MPI has no ceiling but holds SGD 250,000 base capital, lodges security with MAS and safeguards relevant money under section 23.
Yes. At least one executive director must be a Singapore citizen or permanent resident, or an employment pass holding executive director must be paired with a citizen or permanent resident director. Executive directors and the chief executive are expected to be resident and involved in day-to-day management.
A major payment institution holding relevant money must safeguard it under section 23, using an undertaking or guarantee from a safeguarding institution, a trust account with a safeguarding institution, or a combination. Digital payment token service providers separately segregate customer assets into a statutory trust.
Yes, subject to fit and proper assessment of shareholders and controllers. The requirement is a Singapore-incorporated company with a permanent place of business and genuine local management, not local ownership, except in the separate money-changing licence class.
Only if digital payment token service is one of the licensed payment services. Where it is, additional obligations apply under MAS Notice PSN02, Guidelines PS-G03 and the customer asset segregation requirements effective 4 October 2024.
The security amount moves from SGD 100,000 to SGD 200,000 where average monthly transaction value across a calendar year exceeds SGD 6 million for any one payment service. That should be forecast and funded in advance rather than discovered during supervision.
Primary sources
The requirements, fees and timeframes on this page are taken from the following primary regulatory and legislative sources. Rules change, and firms should confirm the current position before relying on any figure.
- MAS Guidelines on Licensing for Payment Service Providers (PS-G01)
- Payment Services Act 2019 (Singapore Statutes Online)
- Payment Services Regulations 2019, including the fee Schedule
- MAS Guidelines on Fit and Proper Criteria (FSG-G01)
Last reviewed by the Regulatory Counsel team on 28 August 2026.