MAS Payment Services Act

With effect from 26 August 2024, new licence applicants intending to carry on digital payment token (“DPT”) services pursuant to the Payment Services Act 2019 (“PS Act”), as well as PS Act licensees that are applying to add DPT services would be required to submit an Independent External Auditor’s Assessment Report as part of its licence application.

The onus is on the applicant to ensure that it appoints an appropriate and suitably qualified External Auditor to conduct the independent assessment. The applicant may engage more than one External Auditor to perform the independent assessment of each area as appropriate, depending on the External Auditor’s expertise, experience, and track records in the field. External Auditor(s) appointed by the applicant to conduct the independent assessment should meet the following criteria:

Criteria
Minimum Requirements

1. Qualifications, credentials, and track record of the External Auditor and its lead engagement partner
   
   
   1. The External Auditor should be a company, firm or limited liability partnership approved or deemed to be approved as an accounting corporation, accounting firm or accounting limited liability partnership, respectively, under the Accountants Act 2004.
   
   
   2. The External Auditor, as well as its lead engagement partner, must have made:
      
      at least one report in respect of a statutory audit pursuant to MAS regulations on a financial institution regulated or authorised by MAS, or
      at least one independent review/ assessment commissioned by MAS in the area of AML/CFT on a financial institution regulated or authorised by MAS.
   
   
2. Independence
   
   The External Auditor should be independent from the applicant, its group or group companies.
   
   In the provision of its services for purpose of conducting the independent assessment for the applicant, the External Auditor must satisfy itself that there are no conflicts of interest arising from its ongoing business relationships with the applicant, its group or group companies, up to the conclusion of its engagement.

The following firms[1] are amenable to conduct the independent external auditor’s assessment:

Firm

Baker Tilly Singapore
BDO LLP
Crowe Singapore
Deloitte & Touche Singapore
Ernst & Young Singapore
Grant Thornton Singapore
Goh Yau Kee & Co.
Helmi Talib
H.S. Lim & Co.
KPMG Singapore
Forvis Mazars Singapore
Nexia Singapore
Oakfield & Associates
ONEMillennium PAC
PKF Singapore
PwC Singapore
RSM Singapore
RT LLP
(updated as of 30 October 2024)

Neither MAS nor ISCA endorses any of the listed firms, and it is not mandatory for potential applicants to engage an External Auditor from the list. Applicants are ultimately responsible for assessing and appointing a qualified External Auditor that meets the criteria and has relevant experience and expertise to perform the independent assessment.

Please be advised that the list is non-exhaustive and would continue to be updated. Firms that meet the criteria and are interested to be included in the list above may write to professionalstandards@isca.org.sg. You may wish to refer to the MAS’ Guidelines on Licensing for Payment Service Providers at the following link for further details on the External Auditor criteria and assessment scope.

---

[1] Firms that undertake the assessment should be approved or deemed to be approved as an accounting corporation, accounting firm or accounting limited liability partnership, respectively, under the Accountants Act 2004.