Are all services relating to payments regulated under the PS Act? If not, then why not? What are some of the services relating to payments that are not regulated as payment services under the PS Act?

Not all services relating to payments are regulated under the PS Act.

MAS had, after careful review and consultation with the industry, applied a risk-based approach to identify payment services that pose sufficient risk to warrant regulation, and where such risks are crucial to address, in order to build a simple, secure, and accessible payments ecosystem.

The services identified are those that have the following characteristics:

• The services have a clear payments nexus
• The service providers process funds or acquire transactions for merchants,
• The service providers contract or deal with the consumer or the merchant.

Service providers that process only data (e.g. payment instructions) and not money are treated as outsourcing services. For this reason, we do not require providers of payment instrument aggregation services and data communications platforms to be licensed under the PS Act. 

The PS Act also carves out from regulation some payment services that do not pose sufficient risk to warrant regulation.

The three most significant carve outs are:

• any Payment service that is provided by any person in respect only of any limited purpose e-money
• any Service of dealing in, or facilitating the exchange of, any limited purpose DPTs, and
• any Payment service solely incidental to or necessary for regulated activities carried out by a regulated financial services company.

Refer to Part 1 of the First Schedule to the PS Act for services that are payment services and Part 2 of the First Schedule to the PS Act for services that are not payment services.