Fintech Company Setup in Singapore: MAS MPI vs SPI Licensing Guide (2026)

Published: 18 September 2026 · Reviewed by Ray Tay, Co-Founder & Managing Director, VIVOS PTE. LTD. (ACRA Filing Agent FA20240323 · MOM EA Licence 24S2425)

Quick answer: A Singapore fintech or payments business almost always needs two separate things: a Private Limited (Pte Ltd) company incorporated with ACRA, and — if it carries out any of the seven regulated activities under the Payment Services Act 2019 — a licence from the Monetary Authority of Singapore (MAS). Most founders need either a Standard Payment Institution (SPI) licence, with S$100,000 base capital and an S$1,500 application fee, or a Major Payment Institution (MPI) licence, with S$250,000 base capital (S$500,000 if you handle digital payment tokens or cross-border money transfers) and an S$5,000 fee. Incorporation takes 1-3 days. The MAS licence takes 4 months in MAS’s own best case, and 5-14 months in practice depending on tier and complexity.

TL;DR:

• Seven activities are regulated under the Payment Services Act: account issuance, domestic money transfer, cross-border money transfer, merchant acquisition, e-money issuance, digital payment token (DPT) services, and money-changing.
• You need an SPI licence (base capital S$100,000) if you stay under MAS’s volume thresholds; an MPI licence (base capital S$250,000, or S$500,000 for DPT/cross-border transfer) once you cross them.
• MPI status is triggered at S$3 million/month in transactions for any single regulated service, or S$5 million in daily e-money float.
• You must incorporate the Pte Ltd, appoint a Singapore-resident director, and have a physical registered address before MAS will accept a licence application.
• Since 30 June 2025, digital token service providers incorporated in Singapore but serving only overseas customers must also be licensed — the old “we only serve foreign clients” exemption is closed.
• VIVOS incorporates the entity and handles the pre-licensing structuring; the MAS licence application itself is normally run alongside a specialist payments-compliance consultant or law firm.

What Counts as a Regulated Payment Activity in Singapore?

Not every fintech idea needs a MAS licence. The Payment Services Act 2019 (PS Act) only regulates seven specific activities. If your business does none of these, you may only need standard ACRA incorporation. If it does even one, you need either an SPI or MPI licence before you can operate:

1. Account issuance services — issuing a payment account (e.g. an e-wallet) for a customer.
2. Domestic money transfer services — moving money between accounts within Singapore on a customer’s instruction.
3. Cross-border money transfer services — remittances into or out of Singapore.
4. Merchant acquisition services — processing payments on behalf of a merchant.
5. E-money issuance services — issuing stored value that can be used to pay multiple merchants.
6. Digital payment token (DPT) services — buying, selling, or facilitating the exchange or transfer of cryptocurrency, plus custodial wallet services. Covered in detail in our crypto/DPT licensing guide.
7. Money-changing services — physical currency exchange.

MPI vs SPI: The Two Licence Tiers

Once you know you need a licence, the next question is which tier. MAS sets the line based on transaction volume, not company size or funding raised:

Most first-time fintech founders start with an SPI application and only need to upgrade to MPI once they scale past the volume thresholds — MAS allows this transition, but it requires a fresh capital injection and an updated application, so it is worth modelling your 12-18 month transaction forecast before choosing.

Step-by-Step: Incorporating Before You Apply

MAS will not accept a payment services licence application from an unincorporated business. The entity has to exist first, with specific features already in place:

1. Incorporate a Pte Ltd with ACRA. A sole proprietorship or LLP cannot hold a payment services licence — it must be a company.
2. Appoint a Singapore-resident director. MAS expects at least one director (ideally an executive director involved in day-to-day operations) who is a Singapore citizen, PR, or Employment Pass holder ordinarily resident here.
3. Set your paid-up capital at or above the base capital requirement for the licence tier you are applying for — S$100,000 for SPI, S$250,000 or S$500,000 for MPI. This has to be actually paid into the company’s bank account, not just stated on paper.
4. Secure a physical registered address — a virtual mailbox is fine for standard incorporation but MAS applications are scrutinised more closely on operational substance.
5. Open a corporate bank account. This has become harder for fintech and crypto-adjacent entities specifically — banks apply extra AML scrutiny before a licence is even granted. See our guide on opening a Singapore bank account as a foreign founder.
6. Draft your MAS Form 1 application, business plan, AML/CFT policies, and technology risk management framework — normally done with a payments-compliance specialist.
7. Appoint an approved compliance officer before submission, or show a credible plan to hire one.

What MAS Actually Checks

MAS licensing is not a form-filling exercise. Applications are assessed against admission criteria that go well beyond what ACRA checks at incorporation:

• Fit and proper criteria for every director, CEO, and 20%+ shareholder — criminal record, bankruptcy history, and past regulatory actions anywhere in the world are all in scope.
• AML/CFT controls — customer due diligence procedures, transaction monitoring, and suspicious transaction reporting, all documented before you are approved, not after.
• Technology risk management — how you secure customer funds and data, incident response plans, and (for larger applicants) independent security testing.
• Financial soundness — evidence the paid-up capital is genuine and the business plan is realistic, not just enough to clear the minimum on paper.
• Business substance in Singapore — MAS has become noticeably less tolerant of “letterbox” applications where the real operations sit offshore.

Timeline and Fees: What to Budget

MAS quotes roughly four months as its own processing benchmark for a straightforward, complete application. In practice, most applicants report longer timelines because the first submission comes back with follow-up questions — budget for at least two review rounds and do not announce a launch date publicly until the licence is actually granted.

Common Mistakes Fintech Founders Make

• Incorporating first, then discovering the paid-up capital was set too low and having to do a fresh capital call mid-application.
• Assuming “we only serve customers outside Singapore” exempts a digital token business from licensing. Since 30 June 2025 this is no longer true — see our DPT licensing guide.
• Opening a bank account after incorporating but before understanding bank AML requirements for payments/crypto-adjacent entities, leading to account closures mid-application.
• Under-resourcing the compliance function — a part-time or nominal compliance officer is a common reason MAS sends applications back.
• Treating the MAS application as a solo DIY project. The business plan and AML/CFT framework MAS expects are specialist regulatory-compliance documents, not generic templates.

Why Fintech Founders Use VIVOS — and What VIVOS Does NOT Do

“We incorporate the Pte Ltd, get the paid-up capital, resident director, and registered address structured correctly before a licence application ever goes in, and we handle the ongoing company secretary and accounting work once you are licensed,” says Ray Tay, Co-Founder and Managing Director of VIVOS. “What we do not do is file the MAS Form 1 application itself or write your AML/CFT policy — that is a specialist regulatory-compliance function, and for a payments or crypto licence we work alongside a payments-compliance consultant or law firm rather than pretending to be one ourselves. Founders who try to run a MAS licence application without that expertise are the ones who end up in a second or third round of MAS follow-up questions.”

Get Your Entity Structured for a MAS Application

VIVOS incorporates the Pte Ltd, structures the paid-up capital and resident director requirement, and keeps your company secretary and accounting compliant while your MAS licence application is in progress. Start with our Singapore company incorporation guide or get in touch to discuss your fintech structure.

Sources

This guide draws on MAS’s Payment Services Act 2019 and its official licensing guidance, cross-checked against multiple 2026 regulatory-compliance publications. Licensing rules and thresholds can change — always confirm current requirements with MAS or a licensed payments-compliance advisor before applying. Read our editorial and accuracy policy.

• MAS — Payment Services Act 2019
• MAS — Licensing for Payment Service Providers
• MAS — How to Apply
• MAS — Form 1: Application for a Payment Service Provider Licence
• MAS — Payments Service Licensing FAQs

Frequently asked questions

Do I need a MAS licence to build a fintech app in Singapore?

Only if your app carries out one of the seven regulated activities under the Payment Services Act — account issuance, domestic or cross-border money transfer, merchant acquisition, e-money issuance, digital payment token services, or money-changing. A budgeting app that only reads bank data, for example, is not automatically regulated. When in doubt, get a scoping opinion before you build.

Can a foreigner own 100% of a Singapore fintech company?

Yes, for the Pte Ltd incorporation itself — Singapore places no restriction on foreign ownership. The constraint is the resident-director requirement: at least one director must be a Singapore citizen, PR, or Employment Pass holder ordinarily resident in Singapore, separate from the ownership question.

How much capital do I actually need to start a Singapore payments business?

S$100,000 in paid-up base capital for a Standard Payment Institution licence, or S$250,000 (S$500,000 for digital payment token or cross-border transfer services) for a Major Payment Institution licence — on top of your incorporation costs and enough working capital to cover 8-14 months of runway while MAS reviews the application.

Can I start operating while my MAS licence application is pending?

No. Carrying out a regulated payment service without a licence is an offence under the Payment Services Act. You can incorporate, build your product, open bank accounts, and hire — but you cannot process regulated transactions until the licence is granted.

What is the difference between an MPI and an SPI licence?

The tier is set by transaction volume, not company size: you need an MPI once you process S$3 million or more per month in any single regulated service, or hold S$5 million or more in daily e-money float. Below those thresholds, an SPI licence is sufficient and has a lower base capital requirement (S$100,000 vs S$250,000-S$500,000).