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Payment activities require prior Chief-Executive authorisation via Executive Order on AMCM advice under two licence categories; 2023 Financial System Act revision raised bank minimum capital to MOP 300 million and board minimum to five directors, and empowered AMCM to grant temporary fintech/insurtech sandbox licences.
The prudential overhaul embedded in Law 13/2023 lifts minimum registered bank capital from MOP100m to MOP300m and creates a new restricted licence bank category requiring MOP100m minimum capital, raising the entry bar for full banking authorisation while preserving a lighter-capital pathway for narrower-scope banks. For non-bank payment institutions, safeguarding of client funds is not addressed through a dedicated segregation or trust rule; instead, a Payment Services Institution licensee that invests or uses client funds, including funds held for future payments, must escalate to the more stringent non-bank credit institution licence. That licence-tiering approach makes safeguarding a function of authorisation category rather than a standalone conduct obligation, a structural distinction worth carrying into any cross-jurisdictional comparison of Macau's non-bank payments regime against ring-fencing regimes elsewhere.
Outlook
With Law 13/2023 now nearly three years in force, the near-term licensing question is less about further statutory change and more about how AMCM applies the raised capital thresholds and the non-bank credit institution escalation trigger to the territory's payment institution population as it matures alongside the new private-fund regime.
Licensing, Authorisation & Market Access
Macau has no dedicated payment-services or electronic-money statute. In its absence, the AMCM authorises non-bank payment entities as 'other financial institutions' under Article 3º(1)(13) of Lei n.º 13/2023, a general provision rather than a payments-specific licensing framework. As of 26 May 2026 the AMCM register carried four such entities: Macau Pass S.A., Global Payments Asia-Pacific Macau Limited, Uepay Macao Limited, and Keypay Limited, with the last of these not yet trading.
The authorisation mechanism itself is discretionary rather than procedural: it proceeds via a despacho, an executive order issued by the Chief Executive, with no published fee schedule and no statutory decision period disclosed. This places market entrants in a materially different position from jurisdictions with codified payment-institution licensing timelines and fee structures, since there is no statutory benchmark against which an applicant can measure expected processing time or cost.
This finding rests on a single Tier-4 source, and the interpreter has flagged the absence of a primary AMCM-published register as a gap; the structural picture -- despacho-based rather than statute-based authorisation -- is nonetheless the clearest available read on how market access currently works for non-bank payment institutions in Macau.
Outlook
Absent the introduction of a dedicated payment-services statute, new non-bank entrants to Macau's payments market will continue to depend on the same discretionary despacho mechanism, with no fixed timeline or published cost structure to plan against. Any future legislative move to codify payment-institution licensing would represent a material structural change to market access in Macau; no such proposal was found this cycle.
2 earlier distinct update(s)
Licensing, Authorisation & Market Access
Macau's payment-services licensing structure requires prior Chief-Executive authorisation, granted on the advice of the Monetary Authority of Macao (AMCM), for the carrying out of payment activities, explicitly including the provision of payment services through internet or mobile devices. Authorisation is granted under one of two licence categories: non-bank credit institution or other financial institution, a dual-category structure that applies across both bank and non-bank payment-services providers and is unchanged by this cycle's other developments.
The 2023 revision of the Financial System Act introduced a material tightening specifically on the bank side of this licensing landscape. Minimum registered capital for banks was raised from MOP 100 million to MOP 300 million, with restricted-licence banks retained at the MOP 100 million threshold, and the minimum board composition was increased from three to five directors. AMCM was also given new supervisory powers to oversee accountants connected to licensed institutions and to obtain urgent information from them, extending the market-access gatekeeping function beyond the licensed entity itself.
The same revision paired this tightening with an innovation-facilitation provision: AMCM may grant temporary licences allowing qualified entities to carry out fintech or insurtech projects on an experimental basis under the Act's financial-innovation provisions. This creates a distinct, lighter-touch market-access route for entrants pursuing novel payment or financial-technology models, running alongside the higher standing thresholds now applicable to conventional bank licensees. The bank-versus-non-bank distinction is material here: the capital and board-size changes apply to banks, while the payment-institution licensing route and the sandbox mechanism are structured to be available more broadly across both bank and non-bank applicants.
Outlook
The sandbox mechanism's practical uptake is the item to watch: whether AMCM begins granting temporary experimental licences under this provision, and to which categories of applicant, will indicate how the tightened standing framework and the innovation-facilitation route interact in practice for new market entrants.
Licensing, Authorisation & Market Access
Macau's non-bank payments landscape operates without a dedicated electronic-money-institution or payment-institution licensing regime comparable to the EU's PSD2/EMD2 framework; the Autoridade Monetaria de Macau treats mobile wallets as bank-linked intermediaries rather than as independently licensed non-bank payment institutions (wpm-2026-W32-001). This is a standing structural gap rather than a new-cycle development, and it defines the baseline against which this cycle's licensing news should be read: Macau's first formal licensing gate for payment-adjacent activity is arriving not through a general EMI/PI framework but through a narrower, virtual-asset-specific channel.
The Macau government has circulated a draft AML/CFT law, currently under sectoral consultation, that would introduce licensing for virtual-asset operators generally, beyond the gaming sector specifically, with administrative fines for unlicensed operation (wpm-2026-W32-004). This is an assessed-confidence, Tier 3-sourced finding carrying a high impact rating, and it constitutes the first formal virtual-asset-operator licensing track proposed for Macau. No primary legislative text has been independently retrieved this cycle, and no enactment date is confirmed; expected timing is assessed at 2027 Q2 with a year-wide uncertainty band. Because the draft law targets virtual-asset operators specifically rather than payment institutions generally, its enactment would not close the broader EMI/PI licensing gap identified above.
Outlook
Watch for whether the draft law's scope, once a primary legislative text becomes available, extends beyond virtual-asset operators to cover payment institutions more broadly, and for any AMCM signal of an intention to introduce a dedicated EMI/PI regime independent of the virtual-asset track.
Sources and findings (5)
- T1https://www.asianlii.org/mo/legis/laws/fsadl3293255/retrieved
- T1https://www.amcm.gov.mo/en/banking-sector/license-applicationretrieved
- T3https://valsen-corporate.com/macau-payment-services-institutions-license-_guideline/retrieved
- T3https://www.lexology.com/library/detail.aspx?g=7bc996ae-0df9-4309-b7c6-7adbbdf9010eretrieved
- T3https://valsen-corporate.com/macau-payment-services-institutions-license-_guideline/retrieved