PSN04 Reporting in Singapore: Forms 1A to 9 and the 30-Day Rule

RegReportingDesk card: MAS, Monetary Authority of Singapore, Singapore

PSN04 reporting is the periodic data return that every payment licensee of the Monetary Authority of Singapore (MAS) owes under MAS Notice PSN04, the Notice on Submission of Regulatory Returns. MAS issued the Notice on 5 December 2019 under the Payment Services Act 2019 and amended it on 2 April 2024, with the amended forms taking effect on 1 January 2025. It reaches every holder of a licence under the Act: money-changing licensees, standard payment institutions (SPIs) and major payment institutions (MPIs).

The core rules are short. Each return is due no later than 30 days after the period it covers, every amount is reported in Singapore dollars, and the forms need approval at a set level, which for a corporate licensee means a director or a board-authorised executive officer. Section 17 of the Act makes a failure to submit the required returns an offence. On the audit side, MAS’s existing Form 4, the auditor’s report under section 37 of the Act, lets the auditor link a qualified or adverse conclusion, or a disclaimer, to a material misstatement, error or omission in information submitted under Notices PS-N04 and PS-N04A. The revised Form 4, used for audits of financial years ending 31 December 2026 onwards, drops that option, while MAS’s audit guidelines PS-G04 make the accuracy and completeness of PSN04 figures a mandatory annual audit area for the same years.

The 2025 forms added a large block of digital payment token (DPT) and cross-border remittance detail, including exposure to wallets that use anonymity-enhancing technologies. MASNET, the filing channel the Notice names, has since been decommissioned.

Related reading: MAS Stablecoin Framework: PS Act Amendments, 16 October Deadline

The Notice states its own footing in paragraph 1: MAS issued it under section 102(1) of the Payment Services Act 2019 for the purposes of section 17(1), and it applies to all holders of a licence. Section 17(1), headed “Obligation of licensee to submit periodic reports”, is the reporting duty itself: a licensee must submit reports or returns relating to its business in the form, manner and frequency MAS specifies by written notice. Section 17(2) makes a contravention an offence punishable by a fine of up to S$100,000, plus up to S$10,000 for every day a continuing offence runs after conviction. Section 102 is the general power under which MAS issues written notices to licensees, and its list of permitted subjects includes the type, form, manner and frequency of returns to be submitted to MAS.

PSN04 is therefore a written notice issued by MAS under the Act, and no separate regulation sets out the returns. The Payment Services Regulations 2019 matter to PSN04 mainly because it borrows definitions from them: base capital and net head office funds (regulation 2), identifiable source (regulation 28(7)) and overseas personal deposit account (regulation 33(5)).

Two versions exist, and the Notice itself says which one governs a given period:

  • The original Notice, dated 5 December 2019, took effect on 28 January 2020 (paragraph 15 and the endnotes).
  • MAS Notice PSN04 (Amendment) 2024, issued on 2 April 2024, took effect on 1 January 2025. Amended form items carry the tag “[MAS Notice PSN04 (Amendment) 2024]” in the consolidated PDF, which is the quickest way to see what changed.
  • Paragraph 16 requires a licensee to apply the version in force immediately before 1 January 2025 to any reporting period ending on or before 31 December 2024.

The cover of the current PDF reads “Effective Date: 1 January 2025”, while paragraph 15 inside the same document still says the Notice takes effect from 28 January 2020. The two lines describe different events: the cover date belongs to the amendment, and paragraph 15 records the original commencement. The consequence sits in paragraph 16. A late or restated return for any month or half-year of 2024 belongs on the pre-2025 forms, even when it is prepared in 2025 or later.

Who must report under PSN04: licence class and licensed services

Paragraph 1 applies PSN04 to every licensee, and the MAS notice page lists the three licence types it reaches: standard payment institutions, major payment institutions and money-changing licensees. Section 6 of the Act sets out the licence classes and lists the seven payment services: account issuance, domestic money transfer, cross-border money transfer, merchant acquisition, e-money issuance, digital payment token service and money-changing. A money-changing licence covers money-changing only; SPI and MPI licences can cover any combination of the services.

Two things decide which forms a licensee files. The first is the set of services on its licence: paragraph 5 attaches the forms in Table 1 to each payment service the licensee is licensed to carry out, for every reporting period. The second is the licence class, which switches on three extra obligations (paragraphs 5 to 7, instruction 7 for Forms 1A to 1C and instruction 3 for Form 9).

Obligation Money-changing licensee SPI MPI
Service forms in Table 1 Form 7 only Forms for each licensed service Forms for each licensed service
Form 1C (e-money account issuance, annual) Not required Not required Required; nil return if no e-money account issuance service was provided
Form 8 (safeguarding, monthly) Not required Not required Every month licensed for domestic or cross-border money transfer, merchant acquisition or e-money issuance
Form 9 (profit and capital, annual) Part A only Parts A and B Parts A and B

Outside those three rows, the class makes no difference to the form set. An SPI licensed for DPT services files Forms 6A and 6B on exactly the cycle an MPI does, and an SPI running cross-border remittance files the full fifteen-item Form 3B.

Size thresholds sit in the Act

Size enters PSN04 only indirectly. The licence-class thresholds are set by section 6(5) of the Payment Services Act 2019. For account issuance (other than e-money account issuance), domestic and cross-border money transfer, merchant acquisition and DPT services, the test is the average, over a calendar year, of the total value of payment transactions accepted, processed or executed in one month: above S$3 million for any one of those services, or above S$6 million for two or more.

Section 6(5)(b) applies a S$5 million threshold to the sum of two calendar-year averages of daily e-money stored in payment accounts the licensee issues, distinguished by the statutory residency and place-of-issuance conditions. Section 6(5)(c) applies a separate S$5 million threshold to the calendar-year average of daily specified e-money the licensee issues. For the e-money float test, MAS’s FAQs on the Act add that e-money already spent by the user is excluded and that the annual float total is divided by every day of the calendar year.

Under section 6(6), a licensee without an MPI licence must apply for a licence change within the prescribed period after the relevant threshold is first met. Regulation 6(2) of the Payment Services Regulations 2019 sets that period at 30 days after the relevant date defined in the Act, and regulation 9 prescribes Form 2 for a licence variation application. Where that application is made within the period, section 6(5) does not apply while the application is pending, subject to the statutory conditions. PSN04 form obligations therefore follow the licence actually in force, as read with the Notice.

The monthly PSN04 values, and the Form 5 daily average in particular, can give a licensee the same raw figures it needs to watch its position against those tests; this is an inference, not a rule in the Notice. PSN04 does not perform the calendar-year averaging, though, so a threshold check has to be built separately from the return.

Entities outside PSN04

Persons exempt under section 13 of the Act hold no licence, so paragraph 1 does not reach them. Section 13(2) applies sections 15 to 19 of the Act, which include the section 17 reporting duty, to banks, merchant banks, finance companies and credit or charge card issuers exempt under section 13(1)(a) to (d), as if they were licensees, for their relevant payment services. Section 102(1)(f) lets MAS issue notices to exempt payment service providers, so any periodic returns for that group are specified outside PSN04. MAS applies its AML/CFT Notice PSN10 to the exempt group for certain account issuance, domestic money transfer and e-money issuance services. Entities granted an exemption to provide specified payment services under the Payment Services (Exemption for Specified Period) Regulations 2019 reported under a different instrument, Notice FSM-N01 on Submission of Returns by Notified Entities.

The Notice has no group or consolidated return. Instruction 4 for Form 9 requires the profit and capital figures on a legal entity basis, and the only provision aimed at foreign companies is the net head office funds line in part B of Form 9. A person granted a licence, or varying one, after a reporting period has begun starts with a short first period under paragraph 14, running from the grant date to the end of that month, half-year or year.

What the PSN04 report contains: forms, fields and valuation rules

All forms sit in the Appendix to the Notice under a common header: the Act, section 17 and section 102(1), the licensee’s name, and the start and end dates of the period. The fields fall into three types: values and counts of transactions for the period, stocks at period end (accounts, customers, balances, terminals), and ranked lists such as top 10 corridors, top 10 merchants or top 5 tokens.

Form Service and cycle What it captures
1A Account issuance, monthly Placements and withdrawals for e-money and non-e-money accounts; accounts issued to enable other services; customer count
1B Account issuance, half-yearly Higher-risk customers (politically exposed persons and others); customers by residency; e-money flows through products exempted under PSN01
1C E-money account issuance, annual (MPI only) Personal payment accounts and customers; customer bands by e-money drawn and by highest balance; transfers to the customer’s own overseas deposit account
2A / 2B Domestic money transfer, monthly / half-yearly Transaction value and number; moneys accepted by residency and person type; higher-risk customers; exempted products
3A / 3B Cross-border money transfer, monthly / half-yearly Outward, inward and brokering flows; 15 breakdowns covering counterparties, channels, sources of funds, top 10 corridors, payout method and overseas agents
4A / 4B Merchant acquisition, monthly / half-yearly Transactions for Singapore and non-Singapore merchants; EFTPOS and contactless terminals; top 10 Singapore merchants with UEN
5 E-money issuance, monthly Average daily specified e-money issued; period-end balance of e-money issued
6A / 6B DPT service, monthly / half-yearly Dealing, exchange, transfer, inducement, safeguarding and administration activity; accounts; balances; top tokens; higher-risk tokens, jurisdictions and wallets
7 Money-changing, annual Note purchases and sales by counterparty; transactions above S$5,000; higher-risk customers; top 10 currencies
8 Safeguarding, monthly (MPI) Daily relevant moneys; amounts safeguarded by guarantee, undertaking or trust account; changes of arrangement
9 All licensees, annual Income, expenditure and profit before tax; base capital or net head office funds

Currency, units and the net-of-fee rule

Paragraph 10 requires every monetary amount in Singapore dollars. Paragraph 11 then fixes what a “total value” is: where the licensee charges the customer a separate commission, charge or fee, the value is reported net of it; in all other cases it is the amount of money the licensee receives for the transaction. Paragraph 12 handles currency direction. When foreign currency comes in and foreign currency goes out, the value is the SGD equivalent of what the licensee received; when the payee receives Singapore dollars, the value is that SGD amount; and when the licensee receives Singapore dollars for a foreign-currency payout, it reports the SGD it received.

The Notice says nothing about decimal places, rounding or whether figures are reported in units or thousands, and it sets no sign convention beyond the two-way captions “Foreign exchange gain / loss” and “Profit / loss before tax” on Form 9.

Exchange rates by form

The instructions carry three different conversion rules, and they are easy to collapse into one by mistake:

  • Fiat payment forms (Form 1A item 2, Form 1B non-e-money values, Forms 2A to 4A, Form 7 and the relevant-moneys lines of Form 8) convert per transaction: the rate the licensee offered the customer; failing that, for an MPI only, the rate published by the safeguarding institution that holds its relevant money under section 23(2) or (4); failing that, a rate published by any bank in Singapore on the transaction date.
  • E-money values in Forms 1A, 1B and 1C convert daily, at the safeguarding institution’s published rate where the issuer is an MPI or an exempt payment service provider, falling back to a Singapore bank’s published daily rate where that rate is not available. The daily trust account balance in Form 8 item 5 follows the same daily pattern, at the rate published by the safeguarding institution that maintains the trust account, falling back to a Singapore bank’s published daily rate. Form 5 uses a Singapore bank’s daily rate, and its closing balance uses the rate on the last day of the period.
  • DPT values in Forms 6A and 6B use the rate prevailing on the transaction day as published by the licensee in its business or offered to its customer. A rate the licensee determines itself is allowed only where it neither publishes nor offers one. Period-end holdings use the rate on the last day of the period.

An SPI never reaches the second step of the fiat hierarchy, because that step is written for MPIs. Where no customer rate exists, an SPI goes straight to a published Singapore bank rate.

The DPT block and anonymity-enhancing technologies

Form 6B is where the 2025 amendment added most weight. Item 2 splits transfers by the other side: an account controlled by the same DPT service provider, one controlled by another provider that is subject to AML/CFT supervision, one controlled by a provider that is not, and an account no provider controls. Item 4 asks for a trimmed average balance, which instruction 4 defines as the mean of six month-end averages, each computed after removing the top 10% and bottom 10% of accounts by value. Item 5 lists tokens by their common ticker (the instructions give BTC, ETH, XRP and DOGE as examples), and instruction 4A says that where a licensee facilitates two or more transactions in the same token, such as a purchase followed immediately by placement into safeguarding, it should count them as one transaction for the item 5(a) list of top 5 tokens transacted.

Item 6 covers transactions assessed as higher risk: tokens sent to or received from high-risk jurisdictions, and tokens sent to or received from wallet addresses that use anonymity-enhancing technologies. Only the two anonymity-enhancing technology lines, for tokens sent and tokens received, carry a separate exposure line (items 6(d) and 6(f)). Instruction 6B requires direct transactions and indirect ones, through more than one hop, that the licensee has assessed as higher risk. Instruction 6C sets the exposure method, assuming tokens from the flagged wallet are commingled with the other tokens in the intermediate wallet.

MAS’s own example, in its dollar figures: $50 of DPT from a known mixer reaches wallet A, which then holds $500; wallet A sends $100 to the licensee. The licensee may report $100 under item 6(e) and an exposure of $10 under item 6(f). Had the $50 come straight from the mixer, it should report $50 in both. A footnote adds that where a licensee becomes aware of a customer using IP anonymisers such as The Onion Router or the Invisible Internet Project, it should also report this under item 6.

The supervised and unsupervised counterparty split mirrors the distinction behind our FATF Travel Rule implementation analysis, and the unhosted-wallet line overlaps with our review of the FATF stablecoins and unhosted wallets report.

Safeguarding and capital: Forms 8 and 9

Form 8 is a daily ledger submitted monthly. Items 1 and 2 give the daily total of relevant moneys, in the section 23(14) sense, for money transfer and merchant acquisition business on one line and e-money issuance on the other, with a row for each day from 1 to 31. Items 3 to 5 break out the amounts safeguarded by a guarantee, by an undertaking, or in a trust account (with the daily trust account balance), with a slot for each named safeguarding institution under each method. Instruction 3 requires every arrangement in effect during the period, and item 6 records any commencement or discontinuation with its type, institution and effective date.

Form 9 has two parts. Part A is a short profit and loss statement for the calendar year: commission, charges and fees earned, foreign exchange gain or loss and other income, against commission and fees paid, staff costs and other expenses. Part B gives base capital, or net head office funds where the licensee is a foreign company, at year end. A money-changing licensee completes part A only.

PSN04 deadlines and frequency: the 30-day rule across three cycles

Paragraph 8 sets one rule for every form: submission no later than 30 days after the last day of the reporting period. The Notice defines the half-year period as six months beginning on 1 January or 1 July, and the annual period as the calendar year. Counting calendar days, the fixed calendar runs as follows.

Cycle Forms Period ends Due no later than
Monthly 1A, 2A, 3A, 4A, 5, 6A and 8 Last day of each month 30 days later (30 May for April; 30 June for May)
Half-yearly 1B, 2B, 3B, 4B and 6B 30 June and 31 December 30 July and 30 January
Annual 1C, 7 and 9 31 December 30 January

The dates in the last column are a straight calendar-day count from the Notice’s wording. PSN04 contains no weekend or public-holiday provision, and that absence does not by itself settle the legal treatment of a deadline. The Interpretation Act 1965 contains time-computation rules for written law (section 50); whether they apply to the PSN04 filing obligation, and how MAS applies them in practice, is not established here and should be confirmed before relying on an adjusted due date. The calendar-day dates are best treated as conservative internal targets. Short months shift the monthly dates: a January return falls due on 2 March, or on 1 March in a leap year.

30 January is the date to plan around. The December monthly forms, the second-half half-yearly forms and all three annual forms fall due together, so an MPI with several licensed services can face its entire form set on one day. 30 July carries the June monthly forms and the first-half half-yearly forms.

For the amended forms, the first reference periods were January 2025 for the monthly cycle, the half-year ending 30 June 2025 and the calendar year 2025. Every later period follows the same pattern: the month, half-year or year now running is due 30 days after it closes.

Submission of PSN04 returns: MASNET, MAS eServices and sign-off

Paragraph 8 requires electronic submission on MASNET. MAS’s MASNET portal page now states that the MASNET application has been decommissioned and that its applications and services have moved to a new platform, and it asks users to update saved submission links. Under “Payment Service Providers” it lists three returns, each linked to MAS’s eServices site: the Payment Services Act Monthly Return, Semi-Annual Return and Annual Return. The page gives no decommission date. Those three names line up with the three deadline groups in paragraph 8, which suggests the forms are filed in bundles by cycle; that is my reading of the portal labels, and MAS does not spell it out.

The wording of the Notice, last amended on 2 April 2024, still names MASNET. I read the portal change as a change of channel only, leaving the forms and deadlines in the Notice untouched.

On format, paragraph 4 requires the forms to be completed in English, in accordance with the instructions attached to each form, and lodged in the relevant form. MAS publishes the forms as part of the PSN04 PDF. Neither the Notice nor its MAS page sets out a taxonomy, an XBRL or XML schema, a file-naming convention or a resubmission procedure, so those points cannot be answered from MAS’s published PSN04 material.

Paragraph 9 fixes who approves the documents in paragraphs 5, 6 and 7. For a sole proprietor, the licensee; for a partnership or limited liability partnership, any partner; for a corporation, any director, or an executive officer whom the board has authorised to approve them. A corporate licensee that relies on executive-officer approval needs that board authorisation to exist before the first filing it covers.

PSN04 validation: what MAS publishes and what the instructions imply

The external check on PSN04 data that MAS documents sits in the auditor’s report. MAS’s existing Form 4 (used for financial years ending before 31 December 2026), the auditor’s report of a licensed payment service provider, under section 37 of the Act read with regulation 20 of the Payment Services Regulations, asks the auditor to identify what any qualified conclusion, adverse conclusion or disclaimer in the assurance report relates to. The first option listed is that information submitted to MAS under Notices PS-N04 and PS-N04A contains a material misstatement, error or omission. PSN04 figures are therefore inside the assurance scope of that form.

MAS’s Guidelines on Audit of Payment Service Providers (PS-G04), published on 16 July 2026, apply to annual audits for financial years ending 31 December 2026 onwards. They describe the Independent Assurance Report as limited assurance on whether the financial data in PSN04 has been prepared, in all material aspects, in accordance with the Act and the Payment Services Regulations, and list the accuracy and completeness of the reported figures in PSN04 among the mandatory annual audit areas. MAS has also published a revised Form 4 for those financial years. Its audit scope list includes “Accuracy of Regulatory Returns”, and the existing form’s option naming Notices PS-N04 and PS-N04A does not appear in the specimen.

The Notice and its MAS page carry no validation rule set, error codes or rejection statistics, and none are listed here. The instructions do imply checks a reporting team can run before filing:

  • Customer counts in Forms 1A and 1B treat all accounts sharing the same unique identifier, as defined in section 2 of the Act, as one customer (instruction 4 for Forms 1A to 1C).
  • Each form uses a different limb of the PSN01 definition of “exempted product”: limb (a) for Form 1B item 3, limb (b) for Form 2B item 4 and limb (c) for Form 3B item 15. Form 2B items 1 and 2 and Form 3B items 1 to 5 exclude exempted-product transactions altogether.
  • Form 4B item 3 needs the ACRA-registered UEN for each of the top 10 Singapore merchants (instruction 4).
  • Form 5 item 1 divides the sum of daily specified e-money issued by the number of days in the month (instruction 2), and the closing balance nets off e-money spent by or returned to users (instruction 4).
  • Form 3B counterparty lines use different limbs of the “financial institution” definition in Part 3 of the First Schedule to the Act depending on the item (instructions 3, 4 and 4A).

A tie-out between the monthly and half-yearly domestic transfer forms need not balance. Six monthly Forms 2A cover transactions accepted, processed or executed with no product carve-out, while Form 2B items 1 and 2 cover moneys accepted and exclude exempted products. My reading is that the gap should be explainable, at least in part, by the exempted-product figure in Form 2B item 4, and an unexplained gap is the one worth investigating.

Nil returns are the open point. Instruction 7 for Forms 1A to 1C tells an MPI to file a nil Form 1C if it provided no e-money account issuance service. For every other form, the Notice ties the obligation to the services a licensee is licensed to carry out and does not say whether a dormant licensed service needs a zero-filled return; that question is one to confirm with MAS.

Caveats and interactions: AML notices, PSN03 and PSN04A

For its higher-risk lines, PSN04 relies on the licensee’s own AML risk assessment. The instructions point back to the determinations made under paragraph 9.6 of PSN01 (including the customers described in paragraph 9.7) or, for DPT customers, paragraph 8.5 of PSN02 (including paragraph 8.6), with politically exposed persons defined in paragraph 9.1 of PSN01 or 8.1 of PSN02. The same applies to “higher risk countries / jurisdictions” in Forms 3B and 6B. My reading is that a change in AML risk methodology moves PSN04 figures in the next half-yearly forms, so the two need to be versioned together. Form 7 adds a twist of its own: its higher-risk line excludes “specified money-changing transactions” as PSN01 defines them.

Two other notices sit close to PSN04 and are easy to confuse with it:

  • PSN03, the Notice on Reporting of Suspicious Activities and Incidents of Fraud, carries event reporting. PSN04 itself carries no fraud data. EU payment institutions, by comparison, report fraud data as one of their PSD2 reporting streams, as set out in our PSD2 reporting requirements guide.
  • PSN04A, the Notice on Submission of Statement of Transactions and Profit/Loss, applied to existing money-changing and remittance licensees under the Money-changing and Remittance Businesses Act until 31 December 2020. It still appears in the existing Form 4 but not in the revised specimen, and it covers transition-era periods only.

The Notice contains no waiver mechanism, materiality threshold or national discretion. Proportionality works only through scoping: a licensee files the forms for the services and licence class it holds. Its two transitional provisions are narrow: paragraph 13 relieved former money-changer’s licence, remittance licence and WASVF holders until 31 December 2020, and paragraph 16 keeps 2024 periods on the old forms.

Changes to PSN04: the 2025 forms and the stablecoin consultation

The current form set traces to MAS consultation P004-2023, issued on 8 May 2023 to operationalise the 2021 amendments to the Act. It proposed PSN04 reporting for newly scoped-in services, additional breakdowns and reporting on exposure to anonymity-enhancing technologies, with six months to comply. The newly regulated activities included arranging cross-border transfers between two other countries, DPT transfer and safeguarding services, and inducing DPT transactions. They appear in the brokering lines of Forms 3A and 3B and the safeguarding, administration and inducement lines of Forms 6A and 6B. MAS’s Payment Services Act page records that the expanded scope under the Payment Services (Amendment) Act 2021 commenced on 4 April 2024.

MAS’s response to feedback, published on 2 April 2024, moved the start of the revised PSN04 to 1 January 2025 because firms needed time to upgrade data and reporting systems. Licensees licensed before that date kept the existing forms until then. On the anonymity-enhancing technology lines, MAS accepted that firms may use third-party blockchain surveillance tools. It also said each firm should set and document its own materiality and proximity thresholds, avoid undue reliance on tool settings it has not reviewed, and set its own method for exposure from commingled tokens. Instruction 6C and its worked example reflect that position.

The move from MASNET to MAS eServices, described under submission above, is the latest operational change, and MAS has not dated it.

The next change in view comes from consultation P015-2026, published on 1 September 2026 with comments due by 16 October 2026. It proposes a stablecoin issuance licence under the Act. In its section on designated systemic stablecoins, Question 16 seeks comments on reporting requirements applicable to all DPT service providers. The paper does not say whether those requirements would be implemented through PSN04 or another instrument, so no change to the PSN04 forms is final. The wider proposals are set out in our MAS stablecoin framework explainer.

Frequently Asked Questions

A customer holds a payment account with us and also trades DPTs. Our PSN02 assessment rates them higher risk, but our PSN01 assessment does not. Do they go into the higher-risk lines of Form 1B?

Yes. Instruction 6B for Forms 1A to 1C says that where a licensee provides a customer with a DPT service and also an account issuance, domestic transfer, cross-border transfer or money-changing service, the customer counts as higher risk for Form 1B item 1 if either assessment classes them as higher risk.

We have no residency evidence for some customers. Which residency line do they go in?

Resident outside Singapore. The residency instructions for Forms 1B, 2B, 3B and 6B treat a person as resident in Singapore only on evidence of actual Singapore residency, such as a Singapore address, phone number, business registration or incorporation. A lack of that evidence places the person outside Singapore for reporting.

We receive US dollars from the sender and pay out Singapore dollars. Which amount is the transaction value?

The Singapore dollar amount the payee receives, under paragraph 12(b). If the payout were in another foreign currency, paragraph 12(a) would apply instead: the SGD equivalent of the US dollars received, converted under that form’s exchange-rate hierarchy. Any separately charged fee comes off first under paragraph 11(a).

Our SPI licence becomes an MPI licence part-way through the year. When does Form 8 start?

Paragraph 6 requires Form 8 for every month the licensee is licensed, as an MPI, for domestic or cross-border money transfer, merchant acquisition or e-money issuance. Paragraph 14 deals with a licence granted or varied after a period has begun, with the first period running from the grant date to month end. My reading is that Form 8 starts with the partial month in which the MPI licence takes effect, and that Form 1C becomes due for that calendar year. The Notice does not address a change of licence class in terms, and section 6(6) of the Act separately provides a prescribed period and pending-application treatment for threshold crossings, so confirm the first period with MAS.

Is the S$5,000 line in Form 7 a reporting threshold for money-changers?

No. Item 1 of Form 7 captures all purchases and sales of foreign currency notes by counterparty type, with commissions, charges and fees. Item 2 is a sub-analysis of transactions above S$5,000. Item 3, on higher-risk customers, excludes specified money-changing transactions as PSN01 defines them.

We found an error in a return already filed. How do we correct it?

PSN04 has no resubmission procedure, so the correction route is a matter to agree with MAS directly. If the period ended on or before 31 December 2024, the corrected figures belong on the pre-2025 forms under paragraph 16, and a misstatement that stands uncorrected is the kind of item the auditor’s report form asks the auditor to identify.

Key Takeaways

  • Run the 30 January release as a single project: December monthly, second-half half-yearly and all annual forms share that due date.
  • Replace any MASNET bookmarks with the MAS eServices links for the Monthly, Semi-Annual and Annual Returns.
  • Record which exchange-rate source each form uses; on the fiat payment forms, an SPI without a customer rate falls back to a published Singapore bank rate.
  • Keep written materiality and proximity thresholds and a commingling method behind the Form 6B item 6 anonymity-enhancing technology figures, as MAS’s April 2024 response expects.
  • Re-run the half-yearly higher-risk lines whenever the PSN01 or PSN02 risk methodology changes.
  • Watch the outcome of Question 16 in consultation P015-2026 before redesigning the DPT forms.

Sources and References

  • MAS, PSN04 Notice on Submission of Regulatory Returns (notice page, last revised 2 April 2024): mas.gov.sg
  • MAS Notice PSN04, issued 5 December 2019, effective date 1 January 2025 (amended 2 April 2024), with Forms 1A to 9 and instructions (PDF): mas.gov.sg
  • MAS Notice PSN04 (Amendment) 2024, tracked version (PDF): mas.gov.sg
  • Payment Services Act 2019 (Act 2 of 2019): sso.agc.gov.sg; full Act PDF: sso.agc.gov.sg
  • Payment Services Bill (Bill No. 48 of 2018), clause 17: parliament.gov.sg
  • Payment Services Regulations 2019 (current consolidated version, Singapore Statutes Online): sso.agc.gov.sg
  • Subsidiary legislation under the Payment Services Act 2019: sso.agc.gov.sg
  • MAS, Payment Services Act page: mas.gov.sg
  • MAS, FAQs on the Payment Services Act 2019 (last revised 19 April 2024): mas.gov.sg
  • MAS, Response to Feedback on Proposed Amendments to the Payment Services Regulations 2019 and Notices (P004-2023, 2 April 2024): mas.gov.sg
  • MAS, 2023 consultation on proposed amendments to the Payment Services Regulations and Notices: mas.gov.sg
  • MAS, Consultation on Proposed Amendments to the Payment Services Act 2019 for Stablecoins Regulation (P015-2026): mas.gov.sg; paper (PDF): mas.gov.sg; Annex C, consolidated draft Act text including sections 6 and 102 (PDF): mas.gov.sg
  • MAS, MASNET Application Decommission and Migration Notice: masnet.mas.gov.sg
  • MAS, Form 4, Auditor’s Report for a Licensed Payment Service Provider (existing form, financial years ending before 31 December 2026; specimen PDF): mas.gov.sg
  • MAS, Revised Form 4, Auditor’s Report for a Licensed Payment Service Provider (financial years ending 31 December 2026 onwards; specimen PDF): mas.gov.sg
  • MAS, Guidelines on Audit of Payment Service Providers (PS-G04, 16 July 2026): mas.gov.sg
  • MAS, PSN04A Notice on Submission of Statement of Transactions and Profit/Loss: mas.gov.sg
  • MAS, FSM-N01 Notice on Submission of Returns by Notified Entities: mas.gov.sg
  • MAS, PSN10 AML/CFT Notice for Exempt Payment Service Providers: mas.gov.sg
  • MAS, PSN03 Notice on Reporting of Suspicious Activities and Incidents of Fraud: mas.gov.sg

Planning the next PSN04 filing window

The artifact to produce before the next window is a form map: each licensed service set against its Table 1 forms, the licence-class extras (Form 1C, Form 8 and part B of Form 9), and the date each falls due under paragraph 8. Consultation P015-2026 set 16 October 2026 as its comment deadline; until MAS publishes an amended PSN04, DPT service providers keep filing Forms 6A and 6B in the version effective from 1 January 2025.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.

Similar Posts

  • Riksbank Payment Statistics Reporting: The 1 October 2026 Go-Live

    Report Library › Payments & E-MoneyFrom 1 October 2026 the Sveriges Riksbank starts collecting payment statistics directly from payment service providers and payment system operators, and Riksbank payment statistics reporting becomes a standing filing obligation. The obligation sits in the Riksbank’s regulations RBFS 2025:1, adopted on 25 June 2025. Subject to Section 1’s exclusions, it…

  • PSR Specific Direction 20: APP Scam Reimbursement Reporting

    Report Library › Payments & E-MoneyOn 7 October 2024 the reimbursement requirement in PSR Specific Direction 20 became live, and every payment service provider that sends a Faster Payments transaction from a relevant UK account acquired two obligations at once. The first is reimbursement: where an FPS APP scam claim is reimbursable, the sending PSP…

  • PSD2 Reporting Requirements for Payment Institutions: Complete Practitioner Guide

    Updated July 2026In this guideIntroductionLegal Basis and Regulatory FrameworkWho Must Report Under PSD2Types of PSD2 Reporting ObligationsReporting Recipients: Where Reports GoCommon PSD2 Reporting ErrorsLuxembourg Specifics: CSSF ExpectationsPSD2 Reporting Evolution: PSR and PSD3Related reporting guidesFrequently Asked QuestionsKey TakeawaysSources and ReferencesReport Library › Payments & E-MoneyIntroduction PSD2 reporting is not optional – payment institutions face multiple overlapping…