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Permission familySingaporeHong Kong

E-money and payment accounts

Issuing electronic money or operating payment accounts, where customer balances sit with your business rather than with a bank the customer chose.

Published jurisdictions
Singapore, Hong Kong
Regulators involved
2 distinct authorities

Scope

What this permission family covers

Regulators assess the activity, not the product name. This is the activity that brings a business inside this family.

Issuing electronic money or operating payment accounts, where customer balances sit with your business rather than with a bank the customer chose.

Instruments in this family

  • Payment Services Act licence (e-money issuance and account issuance)

    Singapore · Monetary Authority of Singapore

  • Stored Value Facility (SVF) licence

    Hong Kong · Hong Kong Monetary Authority

Fit

Who needs this, and who does not

The negative list matters as much as the positive one. Businesses waste months applying for permissions they do not need.

Typically needed by

  • Wallet and multi-currency account products
  • Platforms that hold balances for users between transactions
  • Card programme managers issuing on their own permission

Usually not needed by

  • Businesses that route payments without ever holding customer balances
  • Merchants using a licensed provider's account infrastructure under that provider's permission

Jurisdiction variant

The instrument depends on where you are authorised

E-money (EMI) is not a single permission. Choose a jurisdiction to see the instrument that applies there, the regulator that grants it, and what that regulator examines.

Choose a jurisdiction

E-money (EMI) exists as a different instrument in each published jurisdiction, with a different regulator and a different requirement set.

Choosing one keeps it in the address, so the variant can be shared and reopened.

Open Singapore

Project model

How the programme runs

Three of these stages belong to the regulator. The platform records what the regulator has recorded and never anticipates a determination.

  1. Readiness and gap analysis

    You

    Structured questions establish which requirement areas you already satisfy and which are open. The result is a gap list, not an assessment of whether a regulator will authorise you.

  2. Scoping with a licensing specialist

    Qualified provider

    A qualified licensing provider reviews the gap list, confirms the target permission and scopes the work into a proposal.

  3. Application programme

    Qualified provider

    Policies, governance arrangements, controls documentation and the application pack are produced against the regulator's published requirements, tracked as milestones with document requirements.

  4. Submission to the regulator

    Qualified provider

    The provider submits the application and records the submission evidence. From this point the state shown reflects the regulator's position.

  5. Regulatory assessment

    External authorityOutcome not controlled by ZKCAP

    The regulator reviews the application and normally raises information requests. Each request appears as a first-class item with a response path, not as an email thread.

  6. Determination

    External authorityOutcome not controlled by ZKCAP

    The regulator authorises, refuses, or authorises with conditions or limitations. The platform records whichever determination is issued, including refusal and its remediation path.

  7. Ongoing supervision and renewals

    External authorityOutcome not controlled by ZKCAP

    Authorisation begins a supervisory relationship: reporting, notifications, attestations and periodic fees become tracked obligations.

Where this comes from

How this information is maintained

Boundary

Who is responsible, and who decides

A readiness assessment is not an application.

Check readiness