Alongside the uncommenced licensing reform, the Central Bank's supervisory powers over licensed financial institutions, including banks that provide payment services, have already been strengthened. The Banking (Amendment) Act 2025, No. 14 of 2025, inserts a market-conduct-supervision regime that applies to financial services and financial products offered by a licensed financial institution notwithstanding anything contained in the general Consumer Protection Act 2025. This carve-out gives the Banking Act's sector-specific conduct regime primacy over the general consumer-protection statute for licensed financial institutions, which has direct relevance for how payments-sector consumer protection is administered in Antigua and Barbuda going forward.
Other Developments
The repeal-and-replace structure of the 2025 Payment Systems and Services Act leaves existing businesses a 12-month transitional window once it does commence. Once the Minister's Gazette notice brings the Act into operation, payment service providers and payment-system operators already active under the legacy regime will have 12 months to come into compliance with the new licensing framework. Until that notice is published, the Act's substantive licensing provisions remain latent rather than operative, a distinction with real consequence for any entity assessing its current versus prospective regulatory status in the jurisdiction.
The Banking (Amendment) Act 2025's market-conduct provisions extend into territory the general Consumer Protection Act 2025 would otherwise occupy. By disapplying the general consumer-protection statute in favour of its own Part VIIA regime for licensed financial institutions, the Banking Act creates a sector-specific conduct and consumer-protection track for banks and similarly licensed institutions, separate from the protections available to consumers of non-financial goods and services under the general Act.
The Eastern Caribbean Central Bank has stepped back from its DCash 2.0 CBDC successor project in favour of regional payments infrastructure. Following the end of the original DCash CBDC pilot in January 2024, the ECCB's Monetary Council, at its 112th meeting on 13 February 2026, suspended the DCash 2.0 successor project, redirecting priority toward a regional Fast Payment System and participation in CARICOM Payments and Settlement System (CAPSS) integration. As an Eastern Caribbean Currency Union member, Antigua and Barbuda is affected by this region-wide strategic reset, which replaces a proprietary CBDC-wallet approach with an emphasis on upgraded bank-rail interoperability across the currency union.
Cross-Monitor Connections
The uncommenced Payment Systems and Services Act 2025 and the already-effective Banking (Amendment) Act 2025 together illustrate a jurisdiction sequencing its payments-sector reform: supervisory and conduct powers are being strengthened first, while the core licensing re-architecture waits on ministerial commencement. This sequencing has a financial-integrity dimension, since the Banking Act's expanded information-gathering powers, which allow the Central Bank to request books, records and other documents from licensed institutions, sit adjacent to AML/CTF supervisory capacity even though their immediate statutory basis here is market-conduct supervision rather than anti-money-laundering enforcement.
Outlook
The Payment Systems and Services Act 2025's commencement date is the single most consequential variable for Antigua and Barbuda's payments-licensing landscape going forward; until a Ministerial Gazette notice appears, payment service providers should expect to continue operating under the 2007 framework notwithstanding the 2025 Act's enactment. Separately, the ECCB's pivot toward a regional Fast Payment System and CAPSS participation, rather than a proprietary CBDC wallet, signals that Antigua and Barbuda's near-term digital-payments infrastructure development will likely be shaped more by currency-union-wide interoperability initiatives than by a jurisdiction-specific CBDC programme.
Standing brief · as of 8 September 2026
Written before the update above. Where they differ, the update is the more recent position.
Lead Signal
Antigua and Barbuda's payments regulatory architecture has reached a structural inflection point. The Payment Systems and Services Act, 2025 (No. 13 of 2025) has been passed by Parliament, establishing a modernised licensing, safeguarding and interoperability framework administered jointly by the Eastern Caribbean Central Bank and the Financial Services Regulatory Commission — but the statute comes into operation only on a date the Minister appoints by Gazette Notice, and no such notice has yet been published. Until that commencement notice appears, the 2008 Payment System Act remains the operative baseline, leaving the country's most consequential payments reform enacted in law but dormant in practice. The gap between enactment and commencement is now the single highest-value forward marker for this jurisdiction, and it sits alongside a codified but equally suspended set of conduct provisions: the same statute defines an "e-float" mechanism requiring electronic-money issuers to segregate customer funds in an account held at the Central Bank or another licensed institution, and it imposes a prior-authorisation requirement before any payment service is extended to consumers through an agent. None of this takes legal effect until the Minister acts.
Other Developments
Two other threads moved this cycle. First, the Eastern Caribbean Central Bank's Monetary Council, at its 112th meeting on 4 May 2026, formally suspended further development of "DCash 2.0," the intended commercial successor to the ECCU's completed 2021–2024 DCash retail central bank digital currency pilot. This is a reversal, not a pause on a live rollout, and it comes as the ECCB's institutional attention visibly shifts toward the CARICOM Payment and Settlement System, a PAPSS-modelled scheme intended to enable real-time local-currency settlement across CARICOM and reduce reliance on correspondent banks; the ECCB has signalled it will likely join an expanded pilot bringing in additional central banks. Second, a new United States 1% excise tax on certain remittances took effect on 1 January 2026, and digital-wallet transfer providers serving the US-Antigua corridor report that their services are not subject to the cash-focused levy — a carve-out that favours digital channels over cash remittance without, on current evidence, disrupting the corridor materially. Separately, the country's non-bank licensing perimeter continues to run well ahead of the still-dormant bank-route reform. The Money Services Business Act 2011, administered by the Financial Services Regulatory Commission, already provides a functioning licensing structure for money-services businesses. The Digital Assets Business Act 2020 separately establishes a tiered licensing system covering issuance, exchange and custodial wallet services for digital-asset activity, also administered by the FSRC. Together the two statutes create a visible asymmetry between a mature non-bank perimeter and a bank-route regime still awaiting a start date. The domestic banking sector remains concentrated in Eastern Caribbean Amalgamated Bank, built through the earlier acquisitions of ABI Bank and Scotiabank's Antigua operations. Around it sits a comparatively thin regional fintech layer of roughly forty digital financial-service providers, including the regional payment facilitator WiPay Group. On the consumer side, the Office of National Drug and Money Laundering Control Policy issued a public advisory in August 2025 warning of increased account-compromise and top-up scam activity, a consumer-facing vigilance measure that sits outside any dedicated statutory scheme for reimbursing authorised-push-payment fraud victims.
Cross-Monitor Connections
Antigua and Barbuda's continued engagement with the Caribbean Financial Action Task Force — most recently a delegation appearance at the 61st Plenary in December 2025 as the country prepares for its Fifth Round Mutual Evaluation, building on 2018 and 2021 assessment outcomes — has been flagged for continued tracking on the Financial Integrity Monitor's own surface, since the underlying AML/CFT posture questions sit outside this monitor's payments-systems remit even though the preparatory activity is payments-adjacent.
Outlook
The forward calendar for Antigua and Barbuda is dominated by two unresolved dates: when the Minister will gazette commencement of the Payment Systems and Services Act, and whether the paused DCash 2.0 track resumes in some form or is formally superseded by the CARICOM Payment and Settlement System as the region's primary modernisation vehicle. Both are currently open, and both will determine whether the licensing, safeguarding and settlement changes now visible in statute and in regional policy statements translate into an operating environment that differs from today's. A third marker worth watching is the correspondent-banking file: Antigua and Barbuda has pressed this issue at CARICOM level for a decade, and the CARICOM Payment and Settlement System is now the clearest institutional vehicle for addressing de-risking exposure directly, rather than through advocacy alone.