Stage five: in-principle approval
MAS grants in-principle approval (IPA) when it is satisfied with the application subject to conditions that must be met before the licence is issued. The IPA letter lists the conditions. They typically include the completion of the technology build-out, the appointment of any outstanding staff, the lodging of the security deposit and the opening of the trust account for customers' money and tokens. They also include the completion of the independent assessment if outstanding and a final confirmation that the policies in operation are those reviewed. The IPA is valid for a defined period, commonly six months, which MAS may extend on application.1
The IPA is not a licence. The applicant may not commence the regulated activity on the strength of it unless it was already lawfully operating under a transitional exemption. The applicant may announce that it has received an IPA. Most do, because the announcement helps with bank accounts, hiring and investors. The announcement should say precisely what has been granted and should not describe the firm as licensed.
Notes
- MAS practice on in-principle approvals for payment institution licences, as described in PS-G01 and in MAS correspondence; the validity period and the conditions vary by applicant. ↩
For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of October 2026.