Inside this Topic Guide
The reliable and robust provision of payment services is essential to the functioning of the real economy. At their most basic, payment services are the means through which funds are transferred between consumers, businesses and financial institutions. In an increasingly digitalised world, electronic payments are becoming more prevalent whilst use of cash is on the decline. The rise of innovative payment services is being driven by technological advancements as well as by customer demand for more flexible and efficient ways of making payments. Payment systems, which are the financial market infrastructure underpinning the provision of payment services, have also become digitalised over the past few decades.
Provision of payment services is regulated in many advanced economies. As technology continues to develop and the payments landscape continues to evolve, policy makers are also considering how the regulatory framework for payment services may need to be updated to keep pace with innovation and other changes. Some areas of focus include financial exclusion risks for those unable to access digital payments easily, competition and anti-trust issues, operational resilience, cyber risks, anti-money laundering and the use of data in payments.
The payment services industry in Singapore is fast-growing, and new payment solutions are making digital payments quicker, cheaper and more convenient for consumers while also giving rise to new risks. The increasing complexity of payment service models mean that the lines between the various payment services are getting increasingly blurred. There are also concerns that payment service providers may facilitate money laundering or terrorist financing via the use of illicit cross-border transfers, anonymous cash-based payment transactions and the structuring of payment flows to avoid reporting thresholds. Fragmentation and technology risks have come to the fore with advancements in technology emphasising the need to address the lack of interoperability inherent in the existing payments landscape (which was largely cash and cheque-based) and the vulnerability of new forms of payment services to cyber-attacks and personal data leaks.
Recognising the need to address these developments, Singapore enacted the Payment Services Act 2019 ("PS Act"), which consolidated the preceding payments legislation into a single statute as well as expanded the scope of payment services regulation (e.g. by adding certain regulated services such as merchant acquisition services and digital payment token services). Extensive consultation was done and industry feedback was sought by the Monetary Authority of Singapore ("MAS") prior to the enactment of the PS Act, which came into force on 28 January 2020. The PS Act unifies and streamlines Singapore's payments regulatory regime into a single activity-based framework which provides a modular, risk-based approach to allow a single licence holder to potentially undertake multiple payments-related regulated activities.
The PS Act comprises two parallel regulatory frameworks: (1) a licensing regime; and (2) a designation regime. The former focuses on payment services provided to end-customers and merchants, and regulates seven key payment services. More details of the licensing regime is set out in the Payment Services in Singapore section below. The latter enables MAS to designate payment systems and regulate operators, settlement institutions and participants of such payment systems for financial stability, efficiency and/or competition reasons. More details on the designation regime is set out in the Payment Systems section below. Further details on the PS Act are also set out below.
This topic guide should be used as a tool to navigate the payment services regulatory regime in Singapore.
Payment Services in Singapore – Licensing Regime
Payment service providers may offer different combinations of these services, and each payment service is regulated commensurate to the risks that it poses.
(1) Account issuance service
Issuing, maintaining or operating a payment account in Singapore (e.g. e-wallet, debit card, credit card or bank account)
(2) Domestic money transfer service
Providing local money transfer services in Singapore (e.g. providing payment gateway services or payment kiosk services)
(3) Cross-border money transfer service
Providing inbound and/or outbound remittance services in Singapore
(4) Merchant acquisition service
Providing merchant acquisition services (i.e., where the service provider contracts with a merchant to accept and process payment transactions, which results in a transfer of money to the merchant)
(5) E-money issuance service
Issuing e-money in Singapore to allow a person to pay merchants (for goods and services) or transfer e-money to another person (e.g. peer-to-peer transactions)
(6) Digital payment token (DPT) service
Buying or selling DPTs, or providing a platform to allow persons to exchange DPTs in Singapore (e.g. cryptocurrency exchanges)
(7) Money-changing service
Buying or selling foreign currency notes in Singapore.
Three Classes of Licenses
The PS Act provides for the following three classes of licences and regulatory requirements differ according to the risks posed by the scope and scale of services a licensee is allowed to provide thereunder:
- Money-changing licence: A licensee can only provide money-changing services.
- Standard payment institution ("SPI"): An SPI may provide any combination of the seven payment services subject to certain threshold limits:
- the monthly average total value of all payment transactions accepted, processed or executed by the licensee over a calendar year must not exceed S$3 million (or its equivalent in a foreign currency) for one payment service, or S$6 million (or its equivalent in a foreign currency) for two or more payment services;
- where the licensee provides an e-money account issuance service, the sum of: (a) the daily average total value of all e-money stored in any payment account issued by the licensee to a person resident in Singapore over a calendar year; and (b) the daily average total value of all e-money issued in Singapore and stored in any payment account issued by the licensee to any person the licensee has not determined to be resident outside Singapore over a calendar year must not exceed S$5 million (or its equivalent in foreign currency); and
- where the licensee provides an e-money issuance service, the daily average total value of all specified e-money that is issued by the licensee must not exceed S$5 million (or its equivalent in foreign currency).
- Major payment institution ("MPI"): An MPI may provide any combination of the seven payment services. A person that crosses the thresholds above must obtain an MPI licence.
The PS Act seeks to mitigate risks in four key areas across relevant payment services:
- User Protection: MPIs are required to safeguard certain customer monies ("relevant money") against their own insolvency by using any of the following means:
- an undertaking from a safeguarding institution (e.g. a bank) to be fully liable to the customer for the relevant money;
- a guarantee given by a safeguarding institution for the amount of relevant money;
- depositing the relevant money in a trust account maintained with a safeguarding institution; or
- in such other manner as may be prescribed
(See Section 23 of the PS Act and Regulations 14-16 of the Payment Services Regulations 2019). Separately, see also Guidelines for E-Payments User Protection)
- Money laundering/terrorist-financing risks: Certain payment services attract heightened anti money-laundering and countering the financing of terrorism requirements.
(See Notice PSN01 Prevention of Money Laundering and Countering the Financing of Terrorism – Specified Payment Services, Notice PSN01A Prevention of Money Laundering and Countering the Financing of Terrorism - Persons Providing Account Issuances Services who are Exempted under the Payment Services (Exemption for Specified Period) Regulations 2019, Notice PSN01AA Prevention of Money Laundering and Countering the Financing of Terrorism - Persons Providing Account Issuances Services who are Exempted under the Payment Services (Exemption for Specified Period) Regulations 2019, Notice PSN02 Prevention of Money Laundering and Countering the Financing of Terrorism – Digital Payment Token Service, and Notice PSN10 Prevention of Money Laundering and Countering the Financing of Terrorism - Exempt Payment Service Providers.)
- Interoperability: MAS is given formal powers to ensure interoperability of payment solutions, in the interests of customers and market development. See below the Powers, Payment Investigation and Enforcement section of the topic guide.
- Technology risk: MAS is given powers to impose technology risk management requirements, including cyber risk management requirements, on all licensees. These requirements ensure that there is adequate risk governance and the implementation of adequate controls, particularly in areas such as user authentication, data loss protection and cyber-attack prevention and detection.
(See PSN05 Notice Technology Risk Management, PSN06 Notice on Cyber Hygiene, Guidelines on Risk Management Practices – Technology Risk, FAQs – Notice on Technology Risk Management, and FAQ – Notice on Cyber Hygiene.)
In accordance with the MAS' risk-focused licensing regime, the MAS has also set out in an infographic how these risks relate to each of the seven payment services:
*extracted from MAS Infographic on PS Act.
We also set out below the subsidiary legislation to the PS Act, and a non-exhaustive list of guidance and reference materials applicable to payment services in Singapore:
- Payment Services Regulations 2019
- Payment Services (Composition of Offences) Regulations 2019
- Payment Services (Exemption for Specified Period) Regulations 2019
- Payment Services (Saving and Transitional Provisions) Regulations 2019
- Payment Services (Singapore Dollar Cheque Clearing System and Inter-bank GIRO System) Regulations 2019
- PSN01 Notice Prevention of Money Laundering and Countering the Financing of Terrorism – Specified Payment Services
- PSN01A Notice Prevention of Money Laundering and Countering the Financing of Terrorism - Persons Providing Account Issuances Services who are Exempted under the Payment Services (Exemption for Specified Period) Regulations 2019
- PSN01AA Notice Prevention of Money Laundering and Countering the Financing of Terrorism - Persons Providing Account Issuances Services who are Exempted under the Payment Services (Exemption for Specified Period) Regulations 2019
- PSN02 Notice Prevention of Money Laundering and Countering the Financing of Terrorism – Digital Payment Token Service
- PSN03 Notice on Reporting on Suspicious Activities and Incidents of Fraud
- PSN04 Notice on Submission of Regulatory Returns
- PSN04A Notice on Submission of Statement of Transactions and Profit/Loss
- PSN05 Notice Technology Risk Management
- PSN06 Notice on Cyber Hygiene
- PSN07 Notice on Conduct
- PSN08 Notice on Disclosures and Communications
- PSN09 Notice on Specified Matters and Forms
- PSN10 Notice Prevention of Money Laundering and Countering the Financing of Terrorism - Exempt Payment Service Providers
- Guidelines on Licensing for Payment Service Providers [PS-G01]
- Guidelines for E-Payments User Protection
- Guide to the Essential Aspects of the Payment Services Act 2019
- FAQs – Payment Services Act 2019
- Infographic on the Payment Services Act 2019
Committee on Payments and Market Infrastructures (CPMI) and International Organisation of Securities Commissions (IOSCO)
- (31 May 2021) FSB consultation on quantitative targets for enhancing cross-border payments
- (26 May 2021) EPC Insight: Pushing the frontier of payments: towards a global payment area - an interview on the CPMI cross-border payment project at the BIS
- (20 January 2021) FSB 2021 work programme includes actions relating to cross-border payments | Press release
- (13 October 2020) FSB Stage 3 Report to the G20: Enhancing cross-border payments: roadmap | Press release
- (13 July 2020) CPMI Stage 2 Report to the G20: Enhancing cross-border payments: building blocks of a global roadmap | Technical background report | Press release
- (9 April 2020) FSB Stage 1 Report to the G20: Enhancing cross-border payments | Press release
- (December 2014) CPMI/IOSCO Assessment methodology for the oversight expectations applicable to critical service providers - clarifies guidance on FMI's critical service providers against oversight expectations in Annex F of the April 2012 Principles for both supervisors and service providers
- (December 2012) CPSS/IOSCO Principles for financial market infrastructures: Disclosure framework and Assessment methodology
- (April 2012) CPSS/IOSCO Principles for financial market infrastructures - Sets of Principles on organisation of FMIs, credit and liquidity risk management, settlement, central securities depositories and exchange-of-value settlement systems, default management and responsibilities for supervisors. Replaces 2001 Principles | (August 2015) CPMI/IOSCO report on application of principles
ECB Regulation on SIPS
ECB Regulation No 795/2014 (ECB/2014/28), amended by ECB Regulation No 2017/2094 (ECB/2017/32) and ECB Regulation (EU) 2021/728, on oversight requirements for systemically important payment systems implements the CPSS-IOSCO principles and defines systemically important payments systems (SIPS) for the eurozone and specifies oversight requirements for SIPS. Applies to systems operated by central banks and private operators | Consolidated version dated 6 December 2017
Entered into force 12 August 2014. Applied from 21 August 2015. Four SIPS identified by ECB: TARGET2, EURO1, STEP2-T and CORE(FR)
- (26 July 2019) Decision of the ECB (ECB/2019/25) on the procedure and conditions for the exercise by a competent authority of certain powers in relation to oversight of SIPS | Response to the consultation on the draft Decision | Published in the OJ 16 August 2019 (Decision EU 2019/1349)
- (15 June 2018) ECB methodology for payment systems
Other EU materials
- (27 November 2021) ECB consultation on the revision of the ECB Regulation on oversight requirements for systemically important payment systems and two implementing ECB Decisions
- (27 October 2020) ECB consultation on the draft Eurosystem oversight framework for electronic payment instruments, schemes and arrangements (PISA) | Draft framework | Draft assessment methodology | Draft exemption policy
- (July 2020) HMT Payments Landscape Review: Call for evidence - closed 20 October 2020 | Webpage
- (July 2018) Memorandum of Understanding on Payment Systems between the Bank of England, FCA, PSR and PRA
Payment Systems Regulator (PSR)
The PSR regulates payment systems designated by HM Treasury as systemically important under s. 185 Banking Act 2009 | Current list. It is an independent regulator operating as a subsidiary of the FCA, has competition objectives and concurrent powers with the Competition and Markets Authority (CMA) and works to promote innovation, particularly in relation to infrastructure. It became fully operational on 1 April 2015.
Established under the Financial Services (Banking Reform) Act 2013:
- Part 5 - Regulation of payment systems
- Schedule 4 - The Payment Systems Regulator
- Schedule 5 - Procedure for appeals to the CMA
See also Financial Services (Banking Reform) Act 2013 (Commencement No 1) Order 2014 (came into force 1 March 2014) and Financial Services (Banking Reform) Act 2013 (Commencement No 4) Order 2014 (came into force 1 April 2014).
- Annual plans and reports | Annual plan and budget 2019/20
- List of policy statements
- Policy Statement: A new regulatory framework for payment systems in the UK (PSR PS 15/1)
- Policy Statement: PSR Competition Concurrency Guidance (PSR PS15/2) | Finalised Guidance: Enforcement of the Competition Act 1998 (PSR PS15/2.1) | Finalised Guidance: Market reviews, market studies and market investigation references (PSR PS15/2.2)
- PSR General directions
- Market reviews
- (28 July 2016) Final report: Market review into the ownership and competitiveness of infrastructure provision (MR15/2.3) | Factsheet | Press release
- (25 February 2016) Interim report: market review into the ownership and competitiveness of infrastructure provision (PSR MR15/2.2) | Press release
- (25 March 2015) Draft terms of reference
- (21 July 2016) Final report: market review into the supply of indirect access to payment systems (MR15/1.3) | Press release
- (10 March 2016) Interim report: market review into the supply of indirect access to payment systems (PSR MR15/1.2) | Press release
- (25 March 2015) Draft terms of reference
Consultations and responses
- (21 May 2021) PSR consultation on phase 2 of confirmation of payee
- (29 July 2020) PSR launches engagement on development of a long-term strategy | Strategy webpage | Initial consultation on innovation and future payment methods theme
- (5 March 2020) Review of existing Directions: response to consultation CP19/3 on draft Directions (RP20/1) | Press release | Webpage | Factsheet
- (28 January 2020) Call for input: competition and innovation in the UK's New Payments Architecture | Webpage | Press release
- (15 May 2017) House of Commons Library, Briefing Paper: Payment Services Regulator
Payment Strategy Forum
The Payment Strategy Forum was established by the PSR in October 2015 to develop a strategy for payment systems in the UK. It was disbanded in December 2017 having fulfilled its remit.
- (July 2017) Blueprint for the Future of UK Payments | Builds on 2016 report and sets out proposals for developing a new payments architecture (NPA), consolidating the interbank operator governance of Bacs, Cheque & Credit Clearing Company (C&CCC) and Faster Payments Scheme (FPS) into a single consolidated payment system operator (PSO), and measures on financial crime
- (29 November 2016) A Payments Strategy for the 21st Century: Putting the needs of users first - final report on future UK payment strategy | Press release
Bank of England
- Payment and settlement webpage
- (9 February 2021) Update on BoE and FCA Memorandum of Understanding on the supervision of market infrastructure and payment systems
- (13 October 2020) BoE revised approach to ISO 20022 migration | Revised approach and final schemas document
(14 July 2020) RTGS System and CHAPS Annual Report
- (6 July 2020) CHAPS Enhanced ISO 20022 Messages - Industry Review
- (December 2019) Access to UK Payment Schemes for Non-Bank Payment Service Providers
- (9 October 2019) Financial Policy Summary and Record of the BoE's FPC meeting on 2 October discussing, among other things, principles to guide prudential regulation and supervision of payments activities
- (July 2019) A brief introduction to RTGS and CHAPS
Formerly the New Payment System Operator (NPSO), Pay.UK is the UK's retail payments authority tasked with providing retail payment services, rules and standards.
- (19 May 2021) Pay.UK report on future trends in payments
- (30 November 2020) Pay.uk Report: Next Generation Standard for UK Retail Payments - sets out conclusions and intentions regarding the implementation of ISO 20022
- (29 May 2020) Request to Pay Framework launched | Press release
- (5 February 2020) Consultation on the adoption of ISO 20022 for the clearing and settlement capability of the NPA
- (14 September 2020) Next Generation Standard for UK Retail Payments - mid term consultation update
- (1 May 2018) BoE and PSR, Press release: consolidation of three UK Payment System Operators
Image Clearing System (ICS)
- C&CCC FAQs
- HM Treasury consultation on legislation to support cheque imaging - Government response published 30 April 2018
Payment systems may be designated under the PS Act for closer supervision if they play a crucial role in the safety and efficiency of the financial system. A payment system may be designated for any of the following reasons:
- if it is considered a systemically important payment system (i.e. systems where a disruption in operations could trigger, cause or transmit further disruption to participants or cause systemic disruption to the financial system of Singapore);
- if it is considered a system-wide important payment system (i.e. systems where a disruption in operations could affect public confidence in payment systems or the financial system of Singapore);
- where the payment system is widely used in Singapore, the designation is necessary to ensure efficiency or competitiveness in any of the services provided by the payment system; or
- the designation is otherwise in the public interest
Currently, only the following payment systems have been designated under the PS Act:
- Fast and Secure Transfers (FAST);
- NETS Electronic Fund Transfers at Point of Sale (EFTPOS);
- Singapore Dollar Cheque Clearing System;
- Inter-bank General Interbank Recurring Order (GIRO) System;
- US Dollar Cheque Clearing System; and
- MAS Electronic Payment System (MEPS+).
MAS also regulates "relevant payment systems", which would encompass payment systems operated by MPIs and other payment services providers, in addition to designated payment systems. The MAS has interoperability powers over relevant payment systems and can impose an access regime on the operators, settlement institutions or participants of that relevant payment system or any other persons or class of persons that determines access to a payment system, on such terms and conditions as it considers appropriate. In considering whether to do so, the MAS will have regard to:
- whether the imposition of that access regime would be in the interests of the public;
- the interests of the current participants, operator and settlement institution of that payment system;
- the interests of persons who, in the future, may require or desire access to that payment system; and
- such other matters as the MAS may consider to be relevant.
(See Section 51 of the PS Act.)
See also, the MAS website, which has a section on payment systems.
This section of the topic guide outlines the investigative and emergency powers of the MAS, as set out in Part 4 and Part 5 of the PS Act.
MAS may, from time to time, inspect under conditions of secrecy, the books of any licensee, an operator, settlement institution or participant of a designated payment system, or an exempt payment service provider (see Section 72 of the PS Act).
MAS may conduct such investigation as it considers necessary or expedient for any of the following purposes:
- to determine whether a licensee or settlement institution of a designated payment system is carrying on business in a manner likely to be detrimental to the interests of its customers or the participants of the payment system, as the case may be;
- to investigate any alleged or suspected offence or contravention of any provision of the PS Act; and
- to ensure compliance with the Act or any notice in writing issued by the MAS under the PS Act.
(See Section 73 of the PS Act.)
Where the payment entity (defined as a licensee, operator or settlement institution of a designated payment system):
- informs the MAS that it is or is likely to become insolvent, is or is likely to become unable to meet its obligations, or has suspended or is about to suspend payments;
- is insolvent, becomes unable to meet its obligations, or suspends payments;
- the MAS is of the opinion that it: (i) is or is likely to become insolvent, is or is likely to become unable to meet its obligations, or has suspended or is about to suspend payments; or (ii) has contravened any provisions of the PS Act; or
- the MAS considers it in the public interest to do so,
- require the payment entity to immediately take any action (or do or not do any act) in relation to its business that the MAS considers necessary;
- appoint one or more persons as statutory adviser to advise the payment entity on the proper management of such business of the payment entity as the MAS may determine on such terms as the MAS may specify by notice in writing; and/or
- assume control of and manage such business of the payment entity as the MAS may determine, or appoint one or more persons as statutory manager to do so on such terms as the MAS may specify by notice in writing.
Further, MAS has specific emergency powers applicable to designated payment systems; where it has reason to believe an emergency exists, or thinks it is necessary or expedient in the interests of the public (or a section thereof) to so act, MAS may:
- direct an operator or settlement institution of a designated payment system to take such action as MAS considers necessary to maintain or restore the safe and efficient operation of the designated payment system (including modifying or suspending any of its rules);
- apply to the General Division of the High Court of Singapore for the winding up or bankruptcy of an operator or settlement institution of a designated payment system; and/or
- require an operator of a designated payment system to cease operation of the designated payment system.
(See Section 79 of the PS Act.)
MAS also has the other following miscellaneous powers under the PS Act, including the power:
- to ensure interoperability between payment accounts and payment systems, and between payment systems (see Section 25, Section 26 of the PS Act).
- to impose an access regime in respect of a relevant payment system (see Section 51 of the PS Act); and
- to obtain information relating to the shareholders of a licensee or of the operator of a designated payment system (see Section 31, Section 62 of the PS Act).