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Consumer Credit Act 2025 (Act 873) in force 1 March 2026 under new Consumer Credit Commission; licensing/registration commences 1 June 2026 with transition to 30 Nov 2026.
Outlook
No near-term change to the core FSA/IFSA market-access architecture is signalled; the framework is treated as an established baseline. Continuity of prior approvals under the repealed Payment Systems Act 2003 remains structurally significant for any entity that entered the market before the FSA consolidation. Market-access conditions should instead be read alongside the parallel tightening documented in conduct/safeguarding (W1b) and operational resilience (W3), which raise the ongoing compliance burden attached to holding a BNM approval without altering the entry route itself.
Licensing, Authorisation & Market Access
Malaysia's licensing perimeter for payments-adjacent credit activity expanded materially this cycle. The Consumer Credit Act 2025 (Act 873) was gazetted 31 December 2025 and came into force on 1 March 2026, establishing the Consumer Credit Commission (SKP) as an independent regulator for buy-now-pay-later, leasing, factoring, debt-collection and debt-counselling activities. This creates a licensing perimeter for sectors that had previously operated without dedicated prudential or conduct oversight, most notably BNPL, which had scaled significantly in Malaysia's consumer market ahead of any bespoke regulatory framework. Licensing and registration requirements for credit providers and credit service businesses take effect 1 June 2026, with a transition period running through to 31 December 2026, giving existing market participants roughly seven months to achieve compliance before enforcement of the full licensing requirement begins.
Separately, Malaysia's Real-time Retail Payments Platform (RPP), operated by PayNet, was confirmed as a designated payment system as of March 2026 under the Financial Services (Designated Payment System) Order 2023. This designation formalises RPP's position within Malaysia's supervised payments infrastructure, distinguishing it from the newly-licensed non-bank credit-services perimeter being built out under the Consumer Credit Act. The bank-PSP versus non-bank credit-services distinction is material here: RPP's designation operates through the existing bank-centric payment-systems oversight architecture, while the Consumer Credit Commission's new licensing regime is purpose-built for non-bank credit providers that fall outside that architecture.
Outlook
The 31 December 2026 end of the Consumer Credit Act's transition period is the key date for Malaysia's licensing perimeter this cycle. Market participants in BNPL, leasing, factoring, debt-collection and debt-counselling that have not secured licensing or registration by that date, following the 1 June 2026 requirement effective date, will fall outside the newly-formalised regulatory perimeter. Watch for Consumer Credit Commission guidance clarifying scope boundaries for these sectors as the transition period progresses.
3 earlier distinct update(s)
Licensing, Authorisation & Market Access
Malaysia's payment-systems licensing and market-access architecture is undergoing a structural consolidation this cycle. The Real-time Retail Payments Platform (RPP), the infrastructure underpinning DuitNow, carries a confirmed designation as a designated payment system under the Financial Services (Designated Payment System) Order 2023, establishing its regulatory standing as core national payment infrastructure. Alongside this standing designation, Bank Negara Malaysia's revised Policy Document on Electronic Money took effect 31 January 2025, introducing a two-tier issuer regime distinguishing e-money issuers by scale or risk profile; this fact carries Probable confidence, resting on a single Tier-4 aggregator source for the precise effective date pending further corroboration.
The most consequential development is Bank Negara Malaysia's Interoperable Fund Transfer Framework (IFTF), which requires all banks and e-wallet operators to retire proprietary and closed-loop QR payment networks by 30 June 2028 in favour of the interoperable DuitNow QR standard. This is a confirmed, materially significant market-access mandate: it removes the option for individual banks or e-wallets to maintain closed-loop QR ecosystems, pushing the entire retail payments market toward a single interoperable rail. For both bank-affiliated payment service providers and non-bank payment-instrument/e-money issuers, this represents a structural narrowing of permissible technical architecture rather than a change to licensing eligibility criteria themselves; both bank-PSPs and non-bank PIs/EMIs face the same 2028 deadline under the IFTF, though the two-tier e-money issuer regime under the revised Policy Document differentiates obligations by issuer scale within the non-bank segment specifically.
Outlook
The two-year runway to the 30 June 2028 QR-retirement deadline is the operative market-access timeline for the sector. Continued monitoring of BNM guidance on the two-tier e-money issuer regime's specific thresholds, and of migration progress among proprietary QR-network operators, will clarify how orderly this consolidation proves to be.
Licensing, Authorisation & Market Access
The Consumer Credit Act 2025 (Act 873) is the defining licensing-and-market-access development for Malaysia this cycle. Gazetted on 31 December 2025, the Act entered into force on 1 March 2026, with Part V, the licensing provisions, commencing separately on 1 June 2026. The Act establishes a unified statutory regime for buy-now-pay-later providers, leasing companies, factoring companies, and debt-collection businesses, replacing what had previously been a fragmented multi-ministry patchwork of oversight split across Bank Negara Malaysia, the Securities Commission, and other legacy ministries.
A newly-established Consumer Credit Commission, known as SKP, is the new licensing and registration authority under the Act. BNPL, leasing, and factoring companies must obtain an SKP licence; debt-collection agencies, impaired-loan-acquisition entities, and debt-counselling agencies must register with SKP instead. A six-month transition period runs from 1 June to 30 November 2026, during which existing market participants must complete their licence or registration applications as oversight is phased in from the legacy ministries.
Outlook
The transition deadline of 30 November 2026 is the key near-term watchpoint. Whether SKP completes the phased transfer of oversight from the legacy ministries smoothly, and whether the existing BNPL, leasing, factoring, and debt-collection population completes licensing or registration within the six-month window, will determine whether this reform is remembered as an orderly consolidation or a disruptive one.
Licensing, Authorisation & Market Access
Bank Negara Malaysia's regulatory-perimeter clarification for electronic money took effect on 31 January 2025 through a revised e-money Policy Document and accompanying FAQ, formally exempting limited-purpose e-money issuers from BNM's purview under two 2024 Exemption Orders, P.U.A 463/2024 and its Islamic-finance equivalent P.U.A 461/2024. This is a genuine perimeter-narrowing event rather than a mere clarification of existing practice: the Financial Services (Limited Purpose Electronic Money) (Exemption) Order 2024 supersedes the prior full-scope supervisory treatment that had applied to limited-purpose issuers, meaning a defined category of e-money issuer now sits outside BNM's direct licensing perimeter entirely.
At the same time, BNM's licence-processing channel for new payments entrants remains active: SunRate's licence approval, reported 28 April 2026, illustrates continued throughput for new entrants even as the regulator narrows its supervisory scope at the margins. This is a single T3-sourced report without primary BNM licence-register confirmation this cycle, so it is best read as an illustrative data point on continued market access rather than a confirmed count of new licensees.
Read together, these two developments describe a liberalising market-access posture this cycle: BNM is simultaneously narrowing which e-money issuers require its direct oversight and continuing to process new licence applications. The distinction between bank and non-bank payment institution treatment is central to reading this correctly: the e-money exemption orders apply specifically to non-bank e-money issuers operating limited-purpose models, and do not alter BNM's supervisory posture toward bank-issued e-money or full-purpose non-bank e-money issuers, which remain within the standard licensing perimeter.
Outlook
Further BNM licence-processing activity for new payments entrants is expected through the remainder of 2026 via the existing sandbox and standard application channels. Primary-source confirmation of the SunRate approval, and of the practical operating impact of the two 2024 Exemption Orders on the limited-purpose e-money issuer population, are the most valuable confirmations to seek next cycle.
Sources and findings (5)
- T3https://www.lexology.com/library/detail.aspx?g=efce9f8d-681b-47e9-b293-cd3552dbf3c8 [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]
- T1https://www.bnm.gov.my/-/pd-pso-2022retrieved
- T1https://www.bnm.gov.my/application-for-approval-and-registrationretrieved
- T3https://www.pcalaw.com.my/2021/12/09/e-money-overview/ [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]
- T1https://www.commonlii.org/my/legis/consol_act/psa2003221/retrieved