Summary
How to Apply for an SPI or MPI License in Singapore (MAS Compliance Guide)
Singapore is a top fintech hub, and the Monetary Authority of Singapore (MAS) regulates payment services under the Payment Services Act (PSA 2019).
If your business offers digital payments, remittances, e-money, or crypto services, you need either a:
- Standard Payment Institution (SPI) License – For smaller-scale operators
- Major Payment Institution (MPI) License – For high-volume payment service providers
At Triangle Legal LLC, we advise startups and established businesses on how to secure the necessary licenses from the Monetary Authority of Singapore (MAS) — either a Standard Payment Institution (SPI) license or a Major Payment Institution (MPI) license — depending on the scope and scale of your business. Here’s what you need to know.
Overview: Payment Services Act (PSA)
The Payment Services Act, which came into force on 28 January 2020, provides a modular and risk-based framework for regulating seven types of payment services in Singapore:
- Account issuance services
- Domestic money transfer services
- Cross-border money transfer services
- Merchant acquisition services (Eg. Payment gateways)
- E-money issuance services
- Digital payment token (DPT) services (Eg. Crypto exchanges)
- Money-changing services
If your business provides any of the above services, you must be licensed with MAS — unless exempted.
Exemptions
Certain classes of persons who carry on a business below certain thresholds and carry on businesses with low ML/TF risk are exempted from holding a SPI licence. These class exemptions are set out in regulation 28 of the Payment Services Regulations 2019.
Additionally, domestic money transfer service providers that only facilitate the domestic leg of cross-border money transfers on behalf of a customer of
a) a licensed cross-border money transfer service provider;
b) a person who is exempted from holding a licence to perform cross-border money transfer service under regulation 28(1);
c) an exempt payment service provider, do not need to hold a licence to provide cross-border money transfer services.
Some Key Exemptions (MAS Guide Excerpt)
- Note that these exemptions are examples and are not exhaustive. To see the full article from MAS, click here.
- Exemption in respect of providing money-changing services that is incidental to hotel business:
- Which exemption?
Exemption from PS Act s.28 ("Control of shareholding in licensee") and s.34 ("Approval of chief executive officer, director or partner of licensee") - Purpose
-> A person who intends to become a 20% controller of a hotel operator does not need to seek approval to do so.
-> Hotel operators which are money changers do not need to seek approval of chief executive officers, directors, or partners in certain circumstances.
- Which exemption?
- Exemption from section 9 of Act
- Which exemption?
Exemption from PS Act s.9 ("Prohibition against solicitation") - Purpose
-> Relaxation of prohibition against solicitation
- Which exemption?
- Exemption from section 20(1) of Act
- Which exemption?
Exemption from PS Act s.20 ("Prohibition from carrying on certain businesses") - Purpose
-> Allow extension of credit by casinos in some circumstances
- Which exemption?
- Exemption from section 23 of Act
- Which exemption?
Exemption from PS Act s.23 ("Safeguarding of money received from customer") - Purpose
-> No need for merchant acquirers to safeguard funds owed to foreign merchants
- Which exemption?
- Exemption from requirements in section 24 of Act
- What exemption?
Exemption from PS Act s.24 ("Restrictions on personal payment account that contains e-money") - Purpose
-> Allow stock cap to be exceeded in certain circumstances
- What exemption?
Click here to see full article from MAS.
Types of Licenses: SPI vs MPI
Under the PSA, there are three license types, but most businesses apply for one of the following:
Standard Payment Institution (SPI) License
Issued to businesses that do not exceed the following thresholds:
- S$3 million monthly transactions for any payment service (other than e-money account issuance and money-changing services)
- S$6 million monthly transactions for two or more payment services (other than e-money account issuance and money-changing services).
- S$5 million daily outstanding electronic money (e-money)
Major Payment Institution (MPI) License
Required for businesses that exceed SPI thresholds.
MAS Application Requirements (Checklist)
MAS assesses applications based on financial soundness, governance, compliance, and risk management of the applicant. Briefly, common requirements include:
Corporate and Governance:
- Entity must be incorporated in Singapore
- At least one executive director must be a Singapore resident
- Fit and proper test for directors, shareholders, and officers
- Clear shareholding structure and legitimate ultimate beneficial owners
Business and Compliance:
- Minimum base capital of S$100,000 for SPI and S$250,000 for MPI
- A comprehensive business plan
- Anti Money Laundering (AML) /CFT policies and procedures in line with MAS guidelines
- Technology risk management framework (especially for DPTs or e-wallets)
- Cyber hygiene and incident response protocols
- Risk management framework (for fraud, cybersecurity, DPTs)
Application Timeline & Common Delays
MAS reviews SPI and MPI applications on a rolling basis, with a typical timeline of at least 4 to 6 months, sometimes longer, depending on the completeness and quality of the submission.
Delays often occur if:
- Documents are incomplete or unclear
- Business models raise additional regulatory concerns
- The applicant fails to adequately respond to MAS’ follow-up queries
- Weak AML/CFT controls
- Unclear business model (especially for crypto firms)
How Triangle Legal LLC Can Help
We provide end-to-end legal and regulatory support to guide you through the licensing process.
Our Services Include:
- Pre-application assessment – determining whether you require an SPI or MPI license
- Corporate structuring – ensuring your business structure aligns with MAS expectations
- Document preparation – business plans, internal controls, AML/CFT policies
- Regulatory liaison – responding to MAS requests and follow-up queries
- Ongoing compliance – support with post-licensing obligations and internal audits
Why Choose Triangle Legal LLC?
As a boutique Singapore law firm with deep expertise in fintech regulatory frameworks, commercial contracts, and compliance, Triangle Legal LLC offers:
- Practical, business-first legal solutions
- Transparent and startup-friendly pricing
- Personalised attention from senior lawyers
Get In Touch
Need legal advice on your SPI or MPI license application? Contact Triangle Legal LLC today for a consultation.
