In brief
On 16 October 2026, the Monetary Authority of Singapore ("MAS") issued a Consultation on Expanding FIDReC Membership to Payment Service Providers ("Consultation"). The Consultation may be viewed here.
- The Consultation covers MAS' proposal to include payment service providers ("PSPs") that are licensed standard payment institutions ("SPIs") and major payment institutions ("MPIs") as prescribed financial institutions ("FIs") in the Second Schedule of the Financial Services and Markets (Dispute Resolution Schemes) Regulations 2023 ("DRS Regulations").
- The Consultation also covers the MAS' intention to include MAS-regulated stablecoin issuers under the Payment Services Act 2019 ("PSA") as prescribed FIs under the DRS Regulations after the stablecoin regulatory regime under the PSA comes into force.
- Where SPIs and MPIs (and subsequently MAS-regulated stablecoin issuers) are included as prescribed FIs under the DRS Regulations, they would then be required to subscribe to an approved Dispute Resolution Scheme ("DRS") to provide consumers with an independent platform to resolve disputes against them. Currently, the only approved DRS operator is the Financial Industry Disputes Resolution Centre ("FIDReC").
- By requiring SPIs and MPIs (and subsequently MAS-regulated stablecoin issuers) to subscribe to FIDReC, customers of such SPIs and MPIs (and subsequently holders of MAS-regulated stablecoins) will be able to bring eligible disputes against them for mediation and adjudication. This will complement the suite of user protection measures which MAS has progressively introduced for customers of such PSPs.
If you have any feedback or comments for the MAS on the proposed amendment of the DRS Regulations to include SPIs and MPIs (and subsequently MAS-regulated stablecoin issuers) as prescribed FIs, please reach out to MAS via this link by 30 November 2026.
If you have any questions on how this may impact your business or operations, please feel free to reach out to us.
Current landscape on handling customer complaints and dispute resolution for FIs
Currently, MAS expects all FIs to handle customer complaints in an independent, effective, and prompt manner under the Guidelines on Fair Dealing. MAS has also issued guidance on recourse and dispute resolution for relevant FIs under the E-Payments User Protection Guidelines.
While the expectation is that customers should first approach their FIs to resolve any disputes, there may be instances where they remain dissatisfied with the FI-determined outcome and wish to seek recourse through other avenues. FIDReC, an independent and impartial dispute resolution body for consumer disputes involving FIs, is the approved alternative dispute resolution institution under the DRS Regulations, and provides an independent, accessible, and affordable avenue for recourse through its mediation and adjudication services. It is currently the only approved DRS operator under the DRS Regulations.
Generally, all classes of FIs serving retail customers are required to subscribe to FIDReC. However, to accommodate the PSPs' transition into the new licensing regime back in 2020, MAS decided not to impose the requirement for PSPs to subscribe to FIDReC under the DRS Regulations from the outset. Instead, MAS has fielded disputes and followed up with the PSPs on a supervisory basis during this intervening period.
Notably, in 2024, MAS and the Infocomm Media Development Authority formalised the Shared Responsibility Framework (SRF) to establish joint accountability amongst FIs, telecommunication companies and consumers to prevent and mitigate phishing scams. With the introduction of the SRF, MAS required PSPs offering electronic wallets that store e-money ("e-wallet service providers") to subscribe to FIDReC as part of the SRF's dispute resolution mechanism.
Scope of PSPs to subscribe to FIDReC
MAS now intends to require the wider PSP sector to subscribe to FIDReC, thereby allowing customers of such PSPs who are "eligible complainants" to file eligible disputes with FIDReC for dispute resolution, via amendments to the DRS Regulations. The scope of "eligible complainants" generally comprises individuals, sole proprietors, charities, and small businesses as defined under FIDReC’s Terms of Reference, that are customers of the FIDReC subscriber.
This is because PSPs, like other FI classes, provide services that handle customer monies and digital payment tokens, such as maintaining stored balances and executing payment transactions. Consequently, customers may experience disputes arising from their PSPs' potential service lapses, misrepresentations, misconduct, or apportionment of liability (including scam losses), leading to financial loss, where customers would be entitled to seek recourse.
However, MAS does not propose extending the requirement for FIDReC subscription to money-changing licensees. Such entities may only conduct money-changing services, and their business models are relatively simple. Given their small risk surface, MAS considers that imposing the requirement would be overly burdensome to such money-changing licensees.
MAS intends to introduce a fourth licence class under the PSA, MAS-regulated stablecoin issuers. Please refer to MAS' Consultation on Proposed Amendments to the Payment Services Act for Stablecoins Regulation issued on 1 September 2026 for more details about MAS-regulated stablecoin issuers.
MAS proposes that all MAS-regulated stablecoin issuers be required to subscribe to FIDReC within an appropriate timeframe after the stablecoin regulatory regime under the PSA comes into force. MAS is of the view that since holders of MAS-regulated stablecoins are envisaged to have a right to redeem their MAS-regulated stablecoin directly from the issuer, they should also have the option of bringing a claim to FIDReC against the MAS-regulated stablecoin issuer, if they qualify as an "eligible complainant".
Proposed amendments to the DRS Regulations
Currently, Part 1 of the Second Schedule of the DRS Regulations lists the prescribed FIs that are required to be members of an approved DRS under the DRS Regulations (i.e., FIDReC). Such prescribed FIs include (among others) licensed banks, licensed finance companies, certain direct insurers, licensed insurance brokers, certain holders of a capital markets services licence, and certain holders of a financial adviser's licence.
MAS proposes to introduce a new limb under Part 1 of the Second Schedule of the DRS Regulations to extend the requirement to SPIs and MPIs.
MAS also intends to make a further amendment to include MAS-regulated stablecoin issuers as a prescribed FI after the stablecoin regulatory regime in the PSA comes into force.
Fee structure and implementation timeline
As the onboarding of a significant number of SPIs and MPIs onto FIDReC is a major exercise, MAS recognises the need to cater sufficient time to coordinate the onboarding process between the PSP entities and FIDReC, including finalising the fee structure.
The fee structure will include the following:
- Initial onboarding fee: In order to ensure that FIDReC is sufficiently resourced to handle cases from a broader class of PSPs, FIDReC will collect an initial onboarding fee from the PSPs. MAS and FIDReC will engage the industry to determine a framework for the payment of the initial onboarding fee, for example, via a fixed fee to be shared equally by all onboarding PSPs (i.e., excluding e-wallet service providers that have already subscribed to FIDReC).
- Case fees: PSPs subscribed to FIDReC will be liable to pay case fees as provided by FIDReC's Terms of Reference. Case fees are payable for each eligible dispute handled by FIDReC.
- Annual general levy: PSPs subscribed to FIDReC will be liable to pay an annual general levy as provided by FIDReC's Terms of Reference. The annual general levy is intended to cover FIDReC's fixed operating costs, including staffing for caseload management. The share of the general levy attributable to each category of subscribers (e.g., banks, insurers) is determined based on the proportion of resources required to manage the disputes attributable to that category. Within each category, an individual FI's contribution to the general levy is determined based on an internal funding framework agreed upon by the FIs in the category, which may comprise a simple equal division, market share, and/or the FI's share of total eligible disputes for the category over a predetermined period. MAS and FIDReC will also engage the industry on the internal funding framework for the annual general levy, which will supersede the existing funding framework in place for e-wallet service providers.
From a policy perspective, MAS considers that the fee structure should observe the following principles:
- To be as fair as possible between FIs
- To provide FIs with an appropriate degree of certainty and flexibility for budget planning and financial management purposes
- To provide FIs with an incentive to resolve complaints where possible at an early stage, but without deterring them from using FIDReC where appropriate
MAS, in conjunction with FIDReC, will engage the industry on the details of the proposed fee structure, based on the principles and formats set out above, as well as the implementation timelines, over the course of 2027.
Next steps
If you have any comments on (i) the requirement for all SPIs and MPIs, and MAS-regulated stablecoin issuer licensees after the stablecoin regulatory regime comes into force, to subscribe to FIDReC; (ii) the exclusion of money-changing licensees from this requirement; and (iii) the corresponding amendments to Part 1 of the Second Schedule of the DRS Regulations, do consider providing your comments to the MAS via the link by 30 November 2026.
* * * * *
© 2026 Baker & McKenzie. Wong & Leow. All rights reserved. Baker & McKenzie. Wong & Leow is incorporated with limited liability and is a member firm of Baker & McKenzie International, a global law firm with member law firms around the world. In accordance with the common terminology used in professional service organizations, reference to a "principal" means a person who is a partner, or equivalent, in such a law firm. Similarly, reference to an "office" means an office of any such law firm. This may qualify as "Attorney Advertising" requiring notice in some jurisdictions. Prior results do not guarantee a similar outcome.