Obtain an Electronic Money Institution (EMI) License in Singapore

EMI (Electronic Money Institution) is a financial institution authorized to issue and manage electronic money that can be used for payments.
In Singapore, this activity is licensed and regulated by the Monetary Authority of Singapore (MAS), which acts as the country’s central bank and primary financial regulator.
Law and Trust International provides legal support services for obtaining an EMI license in Singapore.

Why is it important to comply with all regulatory requirements? The reason is that Singapore authorities constantly monitor EMI activities. When applying for a license to operate with electronic money, you need to prepare for all key stages in advance to ensure successful licensing.

Why an EMI license in Singapore is needed?

An EMI has several advantages over banks and other financial institutions. Holding the license provides the owner with a range of benefits:

Fast money transfers.
Ability to work with multiple currencies simultaneously.
Internet-based management of electronic money.
Cryptographic protection against potential hacks.
Cost-efficient issuance.

In Singapore, an EMI can operate as either a Small Payment Institution (SPI) or a Major Payment Institution (MPI).

SPI: Limited to accepting, processing, or executing payment transactions and storing electronic money with a capped average daily turnover.
MPI: No limits on payment flows or thresholds, but required to maintain a guarantee deposit as a buffer to protect client funds.

Who needs an EMI license in Singapore?

In Singapore, a license for electronic money activities is required for companies providing payment services with electronic money. Regulation is carried out by MAS under the Payment Services Act (PSA, 2019).

EMI licenses are required for:

Companies issuing electronic money, such as digital wallets, corporate cards, or tokenized balances.
Payment solution providers that hold client funds electronically without a bank account.

E-money licensing requirements in Singapore

Obtaining an EMI license is a complex process that requires significant financial and time investments, which pay off once the business starts operations in Singapore. Key requirements include:

Minimum paid-up capital: SGD 100,000 (~USD 78,000) for SPI, SGD 250,000 (~USD 195,000) for MPI.
No restrictions or prohibitions from Singapore regulatory authorities.
Registered office in Singapore.
Director who is a Singapore resident.

Applicants must also prepare:

A business model, business plan, and risk analysis.
Documentation detailing company structure, management methods, and reporting mechanisms.
Proof of compliance with legal requirements, including anti-money laundering (AML) measures.
Information on directors, secretaries, authorized persons, and other key personnel.

Documents required for an EMI license in Singapore

Along with standard documents such as passports, bank statements, and source-of-funds declarations for key individuals, the following supporting documents are required:

Corporate documents (e.g., Articles of Association).
Certificates of good conduct / criminal record checks.
Proof of minimum paid-up capital.
Description of measures to protect client funds.
Internal controls and AML/CFT policies.
Organizational structure.
Other documents confirming the good reputation and compliance of key personnel.
Registered office address.

All documents must be submitted to MAS in English or Chinese.

EMI licensing process in Singapore

Once MAS accepts the application, the authority reviews the company information to ensure full compliance with regulatory standards. If MAS cannot verify any information, additional documents or clarifications may be requested, otherwise the application may be rejected for one year.

Preparation stage

Develop a business plan, revenue forecasts, market strategies, marketing, and risk assessment.
Assess company structure, staff qualifications, and capital availability.
Company registration

Select a legal entity type and license class.
Appoint a director.
Open a corporate bank account for minimum capital.
Document preparation

Corporate documents: Articles of Association, registration certificates.
Key personnel: notarized passports, certificates of good conduct, qualifications, and experience.
Financial documents: business plan, proof of capital payment.
AML/CFT policies and procedures.
IT and security systems plan.
Submission to the regulatory authority

MAS reviews the completeness of documents and compliance.
Payment of registration fees and minimum capital deposit.
Application review

Verification of key personnel’s reliability and reputation.
Review of business plan and management structure.
Assessment of IT systems and security standards
License issuance and business launch

MAS issues the license authorizing the provision of electronic money services.
Company must comply with regulatory requirements, including reporting, audits, and maintaining capital levels.

Estimated cost: approximately USD 26,000.

Why Law & Trust International?

Law and Trust International provides full legal support to obtain an EMI license in Singapore according to all regulatory requirements. Services include:

Professional legal guidance
Submission of primary and supporting documents to MAS
Assistance with filling applications and forms
Legal representation and contract drafting with third parties (auditors, service providers)
Company and trademark registration
Bank account opening in Singapore
Legal opinions for payment systems, cryptocurrency operations, and banking relationships

Contact our lawyers for a free consultation to start your EMI licensing process in Singapore.

F.A.Q.

What is the timeline and cost for obtaining an EMI license?

The process usually takes 6–12 months and requires significant investments beyond minimum capital, including legal fees, audit costs, and compliance policy development. MAS may request additional documentation at any stage.

What are the penalties for operating without an EMI license in Singapore?

Singapore law imposes severe sanctions, including fines up to SGD 250,000 and imprisonment up to 3 years. MAS actively monitors unlicensed electronic payment operators.

Are there alternatives to avoid the complex licensing process?

Some companies partner with licensed providers or limit product functionality to avoid regulation. However, this approach is often less profitable long-term, especially for projects planning regional expansion in Southeast Asia.

Our clients