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APAC payment licensing perimeters are expanding rapidly and independently into digital-asset and stablecoin regulation across Singapore, Hong Kong, India, Australia and Japan; no harmonised regional framework exists, and each jurisdiction's instrument moves on its own schedule.
Hong Kong licenses stored-value facility issuers under the Payment Systems and Stored Value Facilities Ordinance (Cap. 584), a regime in force since 13 November 2015. The first five SVF licences — Alipay, HKT, Tencent, TNG and Octopus — were granted on 25 August 2016. The HKMA grants an SVF licence only where minimum criteria are met and continue to be met, and also designates retail payment systems.
India authorises non-bank Payment Aggregators under the PSS Act 2007 via the PA-PG Guidelines (Circular DPSS.CO.PD.No.1810/02.14.008/2019-20, dated 17 March 2020, updated November 2024). Requirements include an India-incorporated company, ₹25 crore net worth, escrow with a single scheduled commercial bank, and T+1 merchant settlement. The bank-versus-non-bank split is explicit: only non-bank PAs need RBI authorisation, with bank PAs exempt.
Japan's Act No. 66 of 2025, enacted in June 2025, creates the Electronic Payment Instrument and Crypto-asset Intermediary Service Business (ECISB) registration category under the Payment Services Act, covering registration, disclosure, explanation obligations and prohibited conduct. This new intermediary perimeter complements existing funds-transfer and EPI licensing and opens a distribution route for crypto and EPI services without full issuer licensing.
Australia is mid-transition to an activity-based AFSL payments perimeter. The Treasury Laws Amendment (Payments System Modernisation) Bill 2025 received Royal Assent on 19 September 2025, and the Tranche 1a exposure draft of 9 October 2025 establishes AFSL-based payments licensing under which any PSP performing a defined 'payment function' must obtain an AFSL from ASIC. Tranche 1 consultation closed on 9 April 2026. This is a technology-neutral, activity-based perimeter replacing the non-cash payment facility framework, materially reshaping market-access economics.
Outlook
Australia's AFSL payments-licensing perimeter is the dominant forward variable, advancing through 2026 H2 after the closed Tranche 1 consultation, with APRA prudential standards for major SVFs to follow. The remaining regimes are established standing positions; Japan's new ECISB category bears watching as its distribution-route implications crystallise.
Licensing, Authorisation & Market Access
Three licensing and market-access developments define this module this cycle, spanning enforcement, consolidation and reform-in-progress, and all three concern non-bank payment institutions and electronic-money institutions rather than banks directly. The Monetary Authority of Singapore revoked the Major Payment Institution Licence held by Bsquared Technology Pte Ltd, effective 14 May 2026 (wpm-2026-W1a-001). The regulator record cites false statements made to it and breaches spanning governance, outsourcing arrangements and conflict-of-interest controls. This is a corrective action against a firm already inside Singapore's Major Payment Institution licensing tier rather than a change to that tier's structure or requirements, and it is a single strong tier-one primary-source finding.
In India, the Reserve Bank of India issued consolidated Payment Aggregator Directions 2025, effective 15 September 2025, restructuring the payment aggregator category into three distinct sub-categories: PA-Online, PA-Cross Border and PA-Physical (wpm-2026-W1a-002). The consolidation supersedes the prior 2020 and 2021 PA-PG Guidelines and the separate 2023 cross-border payment aggregator framework, folding what had been a fragmented set of instruments into a single directions document. This is squarely a non-bank payment-institution and electronic-money-institution matter: payment aggregators in India are licensed entities distinct from banks, and the consolidated framework governs their authorisation and ongoing obligations specifically, leaving bank-operated payment infrastructure under separate prudential frameworks. Confidence on this finding is Assessed, reflecting reliance on a single legal-commentary source rather than a direct Reserve Bank of India circular retrieved this cycle.
In Australia, the Treasury released Tranche 1 draft legislation in March 2026 proposing an activity-based licensing regime that would extend the Australian Financial Services Licence framework to a broader population of payment service providers than are currently captured (wpm-2026-W1a-003). The draft includes prudential obligations specifically for stored-value-facility providers holding more than AUD 200 million, a threshold that targets non-bank e-money and stored-value operators of meaningful scale while leaving smaller providers outside that particular prudential tier. As with the Indian consolidation, this is a non-bank payment-institution and electronic-money-institution development rather than a bank-licensing one, and it remains at the draft-legislation stage rather than in force, which limits the confidence and finality that can currently be attached to its eventual form.
Read together, these three developments describe a market-access environment across Singapore, India and Australia that is tightening specifically for non-bank payment institutions and electronic-money institutions, whether through direct enforcement in Singapore, framework consolidation in India, or a proposed activity-based licensing extension in Australia. None of the three developments this cycle directly reaches bank-operated payment infrastructure or bank-held payment licences; the regulatory attention in this module this cycle is concentrated on the non-bank tier specifically. For market entrants and existing non-bank payment service providers alike, the combined effect of these three developments is to raise the near-term cost and complexity of maintaining non-bank payment licences across three of the region's larger payment markets, even though the specific mechanisms differ: an enforcement action in Singapore, a consolidated compliance framework in India, and a proposed new licensing tier in Australia. Firms operating across more than one of these three jurisdictions face materially different compliance obligations in each, since none of the three developments this cycle references or aligns with the others, underscoring the continued absence of a harmonised regional non-bank payment-licensing standard across APAC even as individual national frameworks tighten in parallel.
Outlook
The Reserve Bank of India consolidated framework is already in force and the near-term item to watch is enforcement practice under it, specifically how aggressively the three new sub-categories are policed relative to the framework they replace. Australia's Tranche 1 draft legislation is the item most likely to generate material change over coming cycles, since draft legislation at this stage can still shift materially before enactment, particularly around the AUD 200 million stored-value-facility threshold and the scope of activities brought under the Australian Financial Services Licence framework. Singapore's Bsquared revocation is a closed matter; the item to watch there is whether the Monetary Authority of Singapore follows with further action against other Major Payment Institution licensees, which would indicate a broader supervisory sweep rather than an isolated case.
Sources and findings (6)
- T1MAS — Payments / PS Act 2019
- T1MAS — Licensing for Payment Service Providers
- T1HKMA — Stored Value Facilities and Retail Payment Systems
- T1RBI — PA/PG Guidelines under PSS Act 2007
- T1FSA — Payment Services Act (Act No. 59 of 2009)
- T2Australian Treasury — Payments licensing reforms / Gilbert + Tobin