Quick Answer
The UK offers the strongest fintech brand in the world, FCA authorisation, London's ecosystem and US$6.6 billion of fintech funding in 2025, but a UK licence no longer reaches the EU, so firms wanting European coverage now run 2 regulated entities. Singapore's MAS framework offers comparable regulatory credibility with lower capital requirements at entry and a hub position covering Asia-Pacific, where most regional fintech capital already flows. Fintechs targeting the UK or EU consumer market belong under the FCA; fintechs building for Asia or for global B2B payments are better based in Singapore.
The Choice Fintechs Actually Face
For payments companies, e-money issuers and neobanks, jurisdiction choice is a licensing decision before it is a tax decision. The licence determines which customers you can serve, how much capital sits idle, and how many regulators you answer to.
The UK and Singapore are the 2 most credible fintech licensing venues outside the EU. Both run respected regulators, both pioneered regulatory sandboxes, and both tightened their regimes in the last 2 years. The difference lies in what each licence buys you beyond its home market.
Licensing Regimes Side by Side
|
Factor |
Singapore (MAS) |
United Kingdom (FCA) |
|
Core framework |
Payment Services Act 2019 |
Payment Services Regulations 2017, Electronic Money Regulations 2011 |
|
Entry licence |
Standard Payment Institution (SPI): base capital S$100,000 |
Authorised Payment Institution: capital £20,000 to £125,000 by service type |
|
Full licence |
Major Payment Institution (MPI): base capital S$250,000, no volume caps, plus a security deposit of S$100,000 to S$200,000 |
E-Money Institution: £350,000 capital |
|
Volume thresholds |
SPI capped at S$3 million/month per service, S$6 million combined, S$5 million e-money float |
No SPI-style tier for e-money at scale; small EMI regime exists for sub-scale firms |
|
Realistic timeline |
SPI: roughly 5 to 9 months. MPI: 8 to 14 months |
9 to 12 months for a well-prepared EMI file, longer in practice for complex models |
|
Crypto / digital assets |
Digital payment token services licensed under the same Act since 2022 |
Separate FCA registration regime for cryptoasset firms |
|
Recent tightening |
Independent legal opinion mandatory with every SPI/MPI application since August 2024 |
New CASS 15 safeguarding rules for PIs and EMIs in force from 7 May 2026 |
Neither regulator is fast, and neither is a rubber stamp. MAS rejects templated compliance documentation; the FCA's statutory 4-month clock bears little relation to real elapsed time. The practical difference at entry: a payments startup can get operating in Singapore under an SPI with S$100,000 of base capital, a materially lower bar than a UK EMI's £350,000.
The Substance Requirement Both Sides Impose
A point most comparison content skips: licensed fintech is not a remote business in either jurisdiction.
MAS licences are available only to Singapore-incorporated companies with a permanent place of business in Singapore, at least 1 executive director ordinarily resident here (a citizen, PR, or an Employment Pass holder alongside a resident director), and a CEO with real payments experience. The FCA equally expects UK mind-and-management, local key function holders and UK operational substance.
For fintech founders, the jurisdiction question is therefore also a relocation question. Whichever regulator you choose, someone senior is moving there. That reframes the comparison: you are choosing where your company's regulatory centre of gravity, and part of your leadership team, will physically sit.
What Brexit Did to the UK Licence
Before 2021, an FCA licence passported across the EEA: one authorisation, 30 countries. That is gone.
- A UK PI or EMI has no passport into the EU. Serving European customers requires a separately regulated EU subsidiary
- The reverse flow ended too: the Temporary Permissions Regime for EEA firms serving the UK closed on 31 December 2025, so European fintechs now need full FCA authorisation for UK business
- The standard pattern is dual licensing: an FCA entity for the UK plus an EU entity, typically in Ireland or Lithuania. Stripe, Square, Coinbase and Gemini all chose Ireland for their EU authorisation
- The second licence is not a formality: an Irish EMI runs €350,000 capital and a 12-to-18-month process, with full local substance expectations
The UK remains an excellent licence for the UK. It stopped being a licence for Europe. Any fintech whose market includes both now budgets for 2 regulators, 2 capital pools and 2 compliance functions.
What Singapore Actually Offers on Market Access
Honesty first: there is no ASEAN passporting. A MAS licence authorises business in Singapore, and serving customers in Indonesia, Thailand or the Philippines requires local licences or partnerships in each market, exactly as EU coverage requires an EU entity.
Singapore's regional case rests on different mechanics:
- Capital and headquarters gravity. Singapore captured roughly 90% of Southeast Asian fintech and tech funding through 2025. Regional fintechs raise, bank and headquarter here even when their users are elsewhere
- Regulatory reputation that travels. A MAS licence is the strongest compliance signal in Asia. Banks, partners and regulators across the region treat MAS-licensed firms as pre-vetted counterparties, which shortens partnership and licensing conversations in neighbouring markets
- Payment infrastructure links. Singapore has built real-time payment linkages with regional systems, and MAS runs the region's reference innovation programmes and the annual FinTech Festival
- The operating model fits the region. Southeast Asian fintech expansion runs through local partnerships and licensed subsidiaries anyway. A Singapore hub coordinating licensed local entities is the standard structure, so the absence of passporting costs less here than losing it cost the UK
The parallel is clean: post-Brexit UK and Singapore are both hub jurisdictions without passporting. The UK's hub serves one large domestic market. Singapore's serves a region of 600+ million people whose capital already routes through it, on top of a domestic market that is small but wealthy.
Ecosystem and Funding
|
Factor |
Singapore |
United Kingdom |
|
Fintech funding 2025 |
Dominant share of Southeast Asia's total |
US$6.6 billion, the UK's most funded sector |
|
Ecosystem depth |
Regional HQs, MAS FinTech Festival, dense banking partnerships |
London: Europe's largest fintech cluster, deep talent pool, US$17.7 billion of total VC into the city |
|
Corporate tax on fintech profits |
17% headline, effective 4.25% to 8.5% for new companies |
19% to 25%, with a 26.5% marginal band |
|
Exit treatment |
No capital gains tax |
Gains taxed |
The UK's ecosystem is deeper in absolute terms, and for consumer fintech brands, London remains the best place in Europe to hire, raise and launch. Singapore's advantage is concentration: it is the single point where Asian fintech capital, regulators and banking partners already meet.
Which Fintechs Should Choose the UK
- Consumer fintechs and neobanks whose primary market is the UK itself
- Firms whose model depends on FCA-regulated status for UK counterparties (acquiring, open banking, UK payroll)
- Companies raising from London fintech investors who want a domestic champion
- Teams already based in the UK, since the substance requirement is then free
Which Fintechs Should Choose Singapore
- Payments and B2B fintech serving Asia-Pacific corridors
- Cross-border money movement businesses anchoring in the region's banking hub
- Crypto and digital asset firms wanting a single Act covering payments and DPT services
- Global-facing fintechs with no UK or EU consumer base, where an FCA licence adds brand but no market
- Founders who would rather scale one licence plus partnerships than run parallel UK and EU regulated entities
How Savvy Platform Supports Fintech Founders
A MAS licence application sits on top of a properly built Singapore company: incorporated locally, with resident directorship resolved, a physical registered presence and clean accounting from day one. That foundation is Savvy Platform's core work.
Savvy Platform provides:
- Singapore incorporation through SavvyStart, structured for a regulated subsidiary or headquarters
- Registered address and company secretary from day one
- Employment Pass assistance for the founder or executive relocating to satisfy the resident executive director requirement
- Local director arrangements during the setup period
- Accounting and compliance filings, with banking setup support including non-bank payment institution options
- Ongoing corporate maintenance while counsel handles the MAS application itself
Savvy Platform builds and runs the entity; specialist regulatory counsel drives the licence. Founders get both workstreams running in parallel instead of sequentially.
Conclusion
The UK sells the strongest fintech brand in the world attached to a licence that now stops at its own border, so European ambitions mean 2 regulated entities and 2 pools of trapped capital. Singapore sells a licence with lower entry capital, a regulator whose approval opens doors across Asia, and a hub position at the centre of the region's funding flows, with the honest caveat that regional expansion still runs through local licences.
Fintechs serving UK and EU consumers should be under the FCA. Fintechs building for Asia or global B2B flows are better anchored in Singapore, and Savvy Platform stands up the corporate side through SavvyStart while regulatory counsel runs the licence.
FAQ
What licence does a payments startup need in Singapore?
A Standard Payment Institution licence under the Payment Services Act, with S$100,000 base capital, for volumes up to S$3 million per month per service. Above the thresholds, a Major Payment Institution licence applies, with S$250,000 base capital and a security deposit.
How long does MAS licensing take?
Roughly 5 to 9 months for an SPI and 8 to 14 months for an MPI, including preparation, MAS review rounds and operational walkthroughs. Since August 2024, every application must include an independent legal opinion mapping each product to the Act.
Does a UK FCA licence work in the EU?
No. Post-Brexit, UK authorisation carries no EEA passport. Serving EU customers requires a separately authorised EU entity, most commonly in Ireland or Lithuania, with its own capital and substance requirements.
Does a Singapore MAS licence work across ASEAN?
No. There is no ASEAN passporting. Singapore's regional value is as a hub: MAS credibility, regional capital concentration and payment linkages make it the standard base from which fintechs run licensed subsidiaries and partnerships in neighbouring markets.
Can a fintech founder run a licensed company remotely?
Not in either jurisdiction. MAS requires a Singapore-incorporated company with a permanent local place of business and a resident executive director; the FCA expects UK mind-and-management. For licensed activity, someone senior relocates.
What are the capital requirements compared?
Singapore: S$100,000 for an SPI, S$250,000 for an MPI plus a security deposit. UK: £20,000 to £125,000 for an Authorised Payment Institution and £350,000 for an E-Money Institution, with new CASS 15 safeguarding rules from 7 May 2026.
Is Singapore good for crypto and digital asset companies?
Digital payment token services are licensed under the same Payment Services Act, giving crypto firms a defined path under one regulator. Applications face heavy scrutiny, including an external auditor assessment for DPT applicants.
How does Savvy Platform help with a fintech setup?
Savvy Platform builds and maintains the Singapore entity the licence requires: incorporation through SavvyStart, registered address, company secretary, Employment Pass support for the relocating executive, accounting and banking setup, while specialist counsel prepares the MAS application.
Main sources
- Bratby Law, FCA authorisation for payment institutions and EMIs (passporting, TPR end, CASS 15): https://bratby.law/practice-areas/payments-regulation/authorisation-and-licensing/
- Crassula, UK Authorised Payment Institution licence 2026 (capital and framework): https://crassula.io/guides/licenses/uk-api/
- Raffles Corporate Services, MAS Payment Services Act licensing, MPI and SPI 2026 guide: https://rafflescorporateservices.com/mas-payment-services-act-licensing-mpi-and-spi-complete-2026-guide/
- Three Squared Nine, MAS licensing requirements including the independent legal opinion rule: https://threesquarednine.com/publications/mas-licensing-singapore-fintechs/
- HSBC Innovation Banking analysis of UK VC and fintech funding 2025: https://ffnews.com/newsarticle/fintech/uk-vc-investment-rebounds-in-2025-marking-first-annual-growth-in-four-years/
