What licensing and disclosure requirements apply to a startup planning to offer online payment services under Singapore's Payment Services Act?

Dear Sir/Madam,

Thank you for reaching out. I understand you are planning to launch a fintech startup in Singapore to provide online payment services and are seeking clarity on the regulatory requirements under the Payment Services Act (PSA).

Based on the information you've provided, here is a general overview of your obligations.

MAS Authorization and Licensing
Yes, you will need to obtain a license from the Monetary Authority of Singapore (MAS) before you can begin to operate your payment services business. For new businesses that have not yet commenced operations, it is not permitted to offer regulated payment services while a license application is pending.

Applicable License Tiers
The PSA has three license categories, but based on your business of processing online payments and holding customer funds, you will likely need to apply for either a Standard Payment Institution (SPI) license or a Major Payment Institution (MPI) license. The specific tier depends on the scale of your transactions:

Standard Payment Institution (SPI) Licence: This is for businesses that do not exceed certain thresholds, such as processing a monthly average of S$3 million for any single payment service or S$6 million for two or more payment services.

Major Payment Institution (MPI) Licence: This is required if your business exceeds the thresholds mentioned above, or if you provide an e-money account service and the average daily e-money float exceeds S$5 million.

Key Licensing Requirements
To apply for either an SPI or MPI license, your startup will generally need to meet the following criteria:

Business Presence: Be a company incorporated in Singapore (or an overseas-incorporated company with a registered branch in Singapore) and have a permanent place of business or registered office in Singapore.

Directorship: Have at least one executive director who is a Singapore Citizen or Permanent Resident.

Base Capital: Meet the minimum base capital requirements, which are S$100,000 for an SPI and S$250,000 for an MPI.

Legal and Audit Assessments: As part of your application, you will need to submit a legal opinion from a Singapore law firm confirming that your proposed activities are regulated under the PSA, as well as an assessment from an independent external auditor.

Fit and Proper Criteria: The MAS must be satisfied that the applicant and key individuals meet its \"fit and proper\" guidelines.

There are ongoing compliance obligations, technology risk management requirements, and rules for safeguarding customer funds that you will need to adhere to once licensed.

This information provides a starting point for your planning. The application process and regulatory landscape can be quite detailed.

I would be happy to provide a more in-depth consultation to discuss your specific business model and guide you through the licensing process. Please feel free to contact me on WhatsApp to arrange a session at a competitive rate.