Singapore’s payments industry is getting a new conduct playbook at a time when digital wallets, cross-border transfers and instant payments have become part of daily life for consumers and businesses.
The Singapore FinTech Association (SFA), together with industry players, today launched the Payments Industry Code of Conduct, a voluntary framework that sets out common standards for payment service providers in the city-state. The Code covers areas including pricing transparency, advertising, fraud prevention, card dispute liability, data protection, operational resilience, and anti-money laundering and countering the financing of terrorism controls.
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The move comes as Singapore’s payments market matures beyond basic digital adoption. Consumers now expect payment services to be fast, cheap and available across borders. At the same time, regulators and industry bodies are facing a more difficult question: how to preserve trust when payment products are increasingly embedded into apps, platforms and regional business flows.
Unlike a regulation issued by the Monetary Authority of Singapore (MAS), the Code is not mandatory. Instead, payment service providers may assess their own policies, systems and processes against the standards and publicly declare themselves as “Code Adherents”. These declarations are valid for one year and must state the year in which the self-assessment was conducted.
That voluntary structure is important. It gives the industry room to adopt a common baseline without creating a new licensing regime. But it also means the Code’s impact will depend heavily on how many providers sign up, how seriously they conduct their assessments, and whether customers begin to treat adherence as a marker of trust.
What the Code covers
The Code applies to holders of major payment institution licences, standard payment institution licences and money-changing licences, as well as exempt payment service providers, in relation to regulated fiat currency payment services under the Payment Services Act 2019. It does not cover digital payment token services, even where those services are offered by the same provider.
At its core, the Code is an attempt to make payment costs easier to understand before a customer commits to a transaction. Code Adherents are expected to show the full cost upfront, including the principal amount, transaction fees, applicable exchange rate, any mark-up, and the final amount to be transacted.
This is especially relevant for cross-border payments, where consumers and small businesses often compare providers based on advertised fees, only to discover that part of the cost is built into the foreign exchange spread. The Code explicitly discourages “free” or “zero fee” claims where the provider still earns through an exchange rate mark-up, unless that cost is clearly disclosed.
It also takes aim at drip pricing, where mandatory charges are added partway through a transaction. For consumers, this means fewer surprises. For providers, it raises the bar for how pricing must be presented in user flows, advertisements and competitor comparisons.
The Code also states that marketing must not create a false or misleading impression about the cost of a service. Comparisons with competitors must be fair, accurate and capable of being substantiated. Providers should not selectively omit their own costs while highlighting rivals’ fees to suggest savings that may not exist.
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SK Saraogi, CEO of Wise Asia Pacific and outgoing Co-Chair of the SFA Payments Subcommittee, said the Code sends a clear message that customers should understand the total cost before making a payment. “A mark-up hidden in the exchange rate is still a cost to the customer and should be displayed transparently,” he said.
Fraud, data and resilience move up the agenda
Pricing may be the most visible part of the Code, but its wider significance lies in how it frames consumer protection as a shared industry responsibility.
Code Adherents are expected to maintain a documented fraud prevention framework. This includes regular risk assessments, transaction monitoring, clear escalation procedures and user education on common scams. They are also expected to participate in or support structured industry-wide initiatives led by SFA, MAS or other bodies where relevant and proportionate to their business model, size and risk profile.
That caveat on proportionality matters. Singapore’s payments sector includes large regional players, specialist remittance firms, card issuers, money changers and smaller fintech companies. A one-size-fits-all compliance model could be costly and impractical. The Code instead tries to establish common expectations while recognising that providers face different levels of risk and operational complexity.
The framework also addresses card dispute liability. For card-based payment services, Code Adherents are expected to adopt liability standards aligned with those applying to banks under the Association of Banks in Singapore Code of Practice. This includes caps on customer liability for unauthorised transactions and clear procedures for reporting lost or stolen cards.
On data privacy and security, the Code requires internal controls, data minimisation and compliance with the Personal Data Protection Act. In the event of a notifiable data breach, providers must notify affected users and the Personal Data Protection Commission as soon as practicable, and within three calendar days of assessing the breach.
Operational resilience is another major pillar. Code Adherents are expected to identify and stress-test critical systems such as ledger and wallet systems, payment gateways, customer-facing application programming interfaces and authentication services. In plain terms, these are the systems that keep money moving, users verified and balances accurate. When they fail, the impact can ripple quickly across merchants, consumers and platforms.
Why it matters beyond Singapore
Singapore has long positioned itself as a trusted fintech hub for Southeast Asia, and payments sit at the centre of that strategy. The city-state is a regional base for global fintech companies, a launchpad for cross-border services, and a testbed for regulatory frameworks that often influence conversations elsewhere in the region.
Across Southeast Asia, payments remain one of fintech’s most competitive and strategically important segments. Digital wallets, real-time payment rails, QR payments and remittance platforms have expanded rapidly, but customer experiences remain uneven. Fees can be opaque, fraud risks are rising, and cross-border payment costs are still a pain point for consumers, migrant workers and small businesses.
Singapore’s new Code does not solve these issues across the region. It is domestic in scope and voluntary by design. Still, it may become a useful reference point for markets trying to balance innovation with consumer protection, especially as payment providers increasingly operate across borders.
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For Singapore-based providers with regional ambitions, adherence could also become part of their trust narrative when dealing with partners, regulators and enterprise customers in neighbouring markets. In payments, credibility is not just about speed or price; it is about whether users believe the provider will behave fairly when something goes wrong.
Holly Fang, President of the SFA, said payments now touch almost every part of daily life in Singapore, making transparency and protection central to public trust. “For consumers, that means fewer surprises and clearer recourse when something goes wrong. For the industry, it raises the baseline of trust that good businesses are built on,” she said.
The Code will be reviewed and updated regularly as the payments industry evolves. SFA has also said it will welcome new market participants and providers over time.
The key test will come after the launch. A voluntary code can clarify expectations, but it only becomes meaningful if providers adopt it, customers notice it, and the industry treats self-assessment as more than a box-ticking exercise. For now, Singapore’s payments sector has a clearer benchmark for what fairer, more transparent payment services should look like.
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