Singapore proposes FIDReC membership for payment institutions
On 16 October 2026, the Monetary Authority of Singapore (MAS) published consultation P017-2026. It proposes that all major payment institution (MPI) and standard payment institution (SPI) licensees under the Payment Services Act 2019 (PS Act) be required to subscribe to the Financial Industry Disputes Resolution Centre (FIDReC).
The paper does not use the word “crypto”, but it refers to digital payment tokens and lists digital payment token (DPT) service among the regulated payment services that MPI and SPI licensees may provide. PS Act-licensed DPT service providers would therefore be in scope. P017-2026 does not mention digital token service providers licensed under Part 9 of the Financial Services and Markets Act 2022. On our reading, they would fall outside the proposed limb, which applies to PS Act licensees.
What MAS proposes
MAS would add a new limb to Part 1 of the Second Schedule of the Financial Services and Markets (Dispute Resolution Schemes) Regulations 2023. Payment service providers were not required to join FIDReC when the PS Act commenced in 2020. Since the Shared Responsibility Framework for phishing scams took effect on 16 December 2024, only payment service providers offering e-wallets that store e-money have had to subscribe. Meanwhile, MAS has fielded disputes involving other payment service providers and followed up with them on a supervisory basis.
MAS notes that payment service providers “provide services that handle customer monies and digital payment tokens” and that customers may experience disputes from “potential service lapses, misrepresentations, misconduct, or apportionment of liability (including scam losses)”.
MAS-regulated stablecoin issuers would follow “within an appropriate timeframe after the stablecoin regulatory framework comes into force”. MAS notes that holders are expected to have the right to redeem directly from the issuer; an eligible complainant could bring a claim to FIDReC.
Money-changing licensees would be excluded. MAS says their business models are relatively simple, they handle significantly smaller amounts of customer money, and complaints against them typically concern poor customer service and uncompetitive exchange rates rather than financial losses or claims for redress, so that the requirement would be “overly burdensome”.
Business model: how disputes would be handled
Eligible customers who remain dissatisfied with a firm’s own decision could take the dispute to FIDReC for mediation and, if needed, adjudication. Customers are still expected to approach the firm first, and only eligible complainants — individuals, sole proprietors, charities, and small businesses, as defined in FIDReC’s Terms of Reference — could use the scheme.
As a reference point, from the start of the Shared Responsibility Framework to 30 June 2026, FIDReC received 416 claims against e-wallet service providers and handled 141 of them. Of the claims completed, 99% concluded at mediation and 1% required adjudication. Those figures cover e-wallet claims only and may not reflect disputes involving DPT or cross-border transfer services.
Products: which services are covered
Scope is set by licence type rather than by product. On our reading, that brings in DPT services alongside account issuance, domestic and cross-border money transfer, merchant acquisition, and e-money issuance, to the extent that the dispute is an eligible one under FIDReC’s Terms of Reference. Stablecoin issuance follows later, once the stablecoin framework is in force.
Revenue and cost: fees
No start date is proposed. Joining firms would pay an initial onboarding fee; MAS gives as an example, a fixed fee shared equally by onboarding payment service providers, excluding e-wallet providers already subscribed. Members would then pay case fees for each eligible dispute FIDReC handles and an annual general levy.
Each category’s levy share reflects the resources needed to handle its disputes. Within each category, the split follows a funding framework agreed by the firms in that category, which may use equal division, market share and/or each firm’s share of the category’s eligible disputes over a set period. MAS and FIDReC will engage industry on the framework for payment service licensees, the fee structure and implementation timelines “over the course of 2027”. For e-wallet service providers already subscribed, the new funding framework would supersede the existing one.
For firms not already subscribed, this would be a new cost.
What firms can do now?
Firms can respond to the consultation by 7.00 p.m. on 30 November 2026 (Singapore time, on our reading of the MAS page). The consultation has a single question. It covers the requirement itself, the exclusion of money-changing licensees and the drafting of the amendments. On drafting, the legend under Annex A refers to the Payment Services Regulations 2019, while the annex heading refers to the DRS Regulations; respondents may wish to ask MAS to confirm the instrument being amended. MAS will publish submissions and attribute them to respondents unless they expressly ask MAS not to.
In our view, firms can also review open complaints involving scam losses or alleged misrepresentation in the light of FIDReC’s Terms of Reference.
Other dated items to track
MAS stablecoin consultation (P015-2026). MAS’s consultation on proposed amendments to the Payment Services Act 2019 for stablecoin regulation closed on 16 October 2026. As at 17 October 2026, MAS had not published a response.
FSB note to the G20 (12 October 2026). The Financial Stability Board described global stablecoins as an “inherently cross-border and cross-sectoral issue” and set out their structure, how vulnerabilities could spread, monitoring metrics and available data sources.
Eurosystem TIPS cross-border contact group (16 October 2026). The Eurosystem invited payment service providers and automated clearing houses involved in cross-border retail payments to apply to a market contact group on TIPS cross-border services. Applications close on 15 November 2026; the first meeting is scheduled for the first quarter of 2027.
UK draft regulations for financial market infrastructure sandboxes. A draft of the Financial Services and Markets Act 2023 (Addition of Relevant Enactments) Regulations 2026 would add the Payment Services Regulations 2017, among other enactments, to the list that sandbox regulations can modify. The draft requires approval by each House and would come into force the day after it is made.
US comment deadlines. Comments on the Treasury’s proposed GENIUS Act rule on payment stablecoin issuance, offer and sale close on 19 October 2026. Comments on the SEC’s proposed Regulation Crypto Assets and the CFTC’s request for comment on compute derivatives contracts close on 20 October 2026.
FATF. The FATF Plenary and working group meetings take place in Paris from 26 to 30 October 2026.
James Ross, Head of Advisory, denouement. This article is for information only and is not legal advice.
Comments