The Essential Guide to Launching a Fintech in Singapore

A complete overview of Singapore’s fintech regulations, licensing, and support ecosystem.

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Stable, Transparent Regulation
Gateway to ASEAN & Beyond
Deep Talent Pool
Leading Digital Infrastructure

Pre-2020

Fragmented Regime

MCRBA covered money-changers and remittance providers. PS(O)A covered certain stored value facilities and designated systemically important payment systems.

Nov 2017

Consultation Begins

MAS published its Consultation Paper on the proposed Payment Services Bill, seeking to unify and expand the scope of regulated payment services.

Jan 2020

PS Act Comes Into Force

The new unified framework consolidated payment regulations, repealed MCRBA and PS(O)A, and introduced seven categories of payment services.

Apr 2024

Major Amendments

Enhanced consumer protection, expanded DPT regulation, and strengthened requirements for custody and transmission of digital assets.

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Criteria
Services Covered
Money-Changing License
Money-changing only
Standard PI License (SPIL)
Any 1+ payment services (within thresholds)
Major PI License (MPIL)
Any 1+ payment services (above thresholds)
Monthly Txn Volume
N/A
< S$3M per service; < S$6M combined
Exceeds SPI thresholds
E-Money Float
N/A
< S$5M average daily
≥ S$5M average daily
Base Capital
N/A
< S$5M average daily
≥ S$5M average daily
Security Deposit
Varies
S$100,000
S$200,000
Compliance Burden
Lightest
Moderate
Most comprehensive
MCL
Money-Changing Licence
Monthly Txn Volume

N/A

E-Money Float

N/A

Base Capital

N/A

Security Deposit

Varies

Compliance Burden

Lightest

SPIL
Standard PI License
Monthly Txn Volume

< S$3M per service; < S$6M combined

E-Money Float

< S$5M average daily

Base Capital

< S$5M average daily

Security Deposit

S$100,000

Compliance Burden

Moderate

MPIL
Major PI Licence
Monthly Txn Volume

Exceeds SPI thresholds

E-Money Float

≥ S$5M average daily

Base Capital

≥ S$5M average daily

Security Deposit

S$200,000

Compliance Burden

Most comprehensive


Corporate Setup & Governance

Incorporate in Singapore

Register a Singapore-incorporated company (or a foreign branch) with a local registered office capable of securely housing books and records.

Appoint Key Personnel

Identify at least one director who is a Singapore citizen or permanent resident, a CEO, and a designated compliance officer. Prepare CVs for all key appointees.

Submit Individual Assessment Forms

Prepare the prescribed individual assessment forms (Form 3) for each proposed director and CEO to be submitted alongside your main application.

Demonstrate Fitness and Propriety

All directors, the CEO, shareholders, and key employees must satisfy MAS’ fit and proper criteria, including relevant experience in regulated financial institutions or the payments industry, and managerial capability.

Prepare Organizational Charts

Create detailed charts showing staff structure, names, functions, designations, and reporting lines — including compliance and internal audit functions, and relationships with outsourced service providers.

Ensure Full-Time Commitment

The CEO, executive directors, and senior management must be employed with and dedicated full-time to the applicant entity upon license grant. Address any conflicts of interest proactively.

Financial & Business Documentation

Historical Financial Statements

Prepare audited financial statements covering the last three years for the applicant, its consolidated group, and any entity providing a Letter of Responsibility or Letter of Undertaking.

Financial Projections

Develop three-year financial projections covering revenue, expenses, capital adequacy, and key business metrics that demonstrate the viability of your business model.

Shareholding Structure

Provide a complete shareholding chart showing all controlling interests, including percentage holdings, incorporation details, and any listed exchange where shares are traded.

Business Plan

Submit a comprehensive business plan meeting MAS’ prescribed requirements — typically covering your target market, product strategy, competitive positioning, risk management approach, and growth roadmap.

Obtain a formal legal opinion from a Singapore law firm experienced in PS Act matters, confirming the regulated payment services your business model triggers.

Transaction Flow Diagrams

Prepare detailed diagrams for each product and service, mapping the complete lifecycle of a typical transaction from initiation to settlement.

AML/CFT Documentation

Develop your anti-money laundering and countering the financing of terrorism (AML/CFT) policy suite, including group-wide information-sharing policies, governance and escalation procedures, enterprise-wide risk assessments, and compliance implementation plans.

Shareholder Identification

Collect recent business profiles for all corporate shareholders and identification documents for individual shareholders who are not Singapore citizens or permanent residents.

Additional Requirements for DPT Service Providers

Independent External Audit

Engage an independent external auditor to assess and provide a declaration on your proposed processes, policies, and procedures — a mandatory pre-application requirement for DPT license applicants.

Consumer Protection Policies

Prepare consumer protection policies that are approved by your board and consistent with those reviewed by the external auditor.

Technology & Cyber Security

Prepare cyber security and technology risk management documentation, complete MAS’ Technology Assessment Questionnaire, and plan for pre-launch penetration testing with remediation of all high-risk findings.


Core Obligations

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