On October 16, 2026, the Monetary Authority of Singapore (MAS) issued a consultation paper proposing that all major payment institutions (MPIs) and standard payment institutions (SPIs) be required to join the Financial Industry Disputes Resolution Centre (FIDReC); once the stablecoin regulatory framework takes effect, regulated stablecoin issuers holding the corresponding licences will also be brought within scope. The consultation closes at 7:00 p.m. on November 30, 2026.
This remains a policy proposal, not a remedy rule already in force. The draft may still be adjusted, and the implementation timeline and fee structure are also planned to be the subject of further industry consultation between MAS and FIDReC in 2027. But the problems it addresses are already quite specific: where wallet balances are wrongly debited, cross-border remittances are delayed or fail, payment institutions disagree over liability for scam losses, or stablecoin holders are unable to redeem as arranged, should customers have an independent, lower-cost avenue for mediation and adjudication, in addition to complaining to the institution, reporting to the regulator or bringing litigation?
From licence management to dispute resolution
FIDReC is an approved independent body under Singapore's existing financial dispute resolution regime. Designated financial institutions such as banks and insurers are required to join, and customers usually complain to the financial institution first; where internal handling still fails to resolve the matter, eligible disputes may proceed to FIDReC mediation and, where necessary, adjudication.
When the Payment Services Act established the payment institution licensing regime in 2020, MAS did not immediately require all payment institutions to join FIDReC, in order to allow the industry to transition. During that period, complaints relating to payment institutions were mainly followed up by MAS through supervisory means. In 2024, after Singapore introduced the shared responsibility framework for phishing scams, payment institutions providing stored-value e-wallets joined FIDReC ahead of others. The consultation paper discloses that, from the framework's entry into force to June 30, 2026, FIDReC received 416 applications against e-wallet service providers, of which 141 were ultimately accepted; among completed cases, 99% concluded at mediation and 1% proceeded to adjudication.
These figures cannot be used directly to infer customer win rates, nor do they show that all unaccepted cases lacked a factual basis. They at least show that independent dispute resolution is not a merely formal institutional appendage: eligibility screening will filter out some applications, most processed cases end through mediation, and payment institutions need to prepare materials capable of supporting their liability determinations.
This proposal expands the scope from specific e-wallets to all MPIs and SPIs. Both types of institution may provide one or more regulated services, including account issuance, domestic or cross-border money transfers, merchant acquisition, e-money issuance and digital payment tokens. The potential disputes listed by MAS include service failures, misleading or improper conduct, and how liability for losses is allocated, particularly scam losses. Pure money-changers, whose business is relatively simple and who handle smaller amounts of customer funds, are for now outside the proposed scope.
What stablecoin holders receive is not a "principal guarantee"
The consultation paper also brings within scope future stablecoin issuers regulated by MAS, for reasons connected to redemption rights. MAS previously proposed that stablecoin holders meeting the framework requirements may redeem directly from the issuer in accordance with the rules; if the issuer refuses, delays or mishandles redemption, and the holder is an eligible applicant, the holder should have an opportunity to bring a complaint to FIDReC.
This arrangement fills a remedial gap; it is not an investment guarantee. Joining FIDReC will not turn stablecoins into bank deposits, nor will it eliminate risks relating to reserve assets, custody, liquidity, technical failures, wallet freezes and cross-border enforcement. Whether FIDReC can handle a dispute depends on the applicant's eligibility, the identity of the respondent, the type of dispute and the exclusions in the terms. Even where a dispute is accepted, the applicant must still establish the transactional relationship, the basis of the right, the loss and the connection between the institution's conduct and that loss.
A further distinction must be drawn between "using a regulated stablecoin" and "asserting a redemption claim against a licensed issuer". If the loss occurs at an overseas exchange, a non-custodial wallet, a cross-chain bridge or another intermediary service provider, the entity that actually engaged in the disputed conduct may not be the stablecoin issuer. Once a token has moved among multiple platforms, a licence label does not automatically concentrate the liability of all participants on the issuer.
Whether a Chinese enterprise can apply depends on its status and the transactional relationship
The eligible applicants referred to in the consultation paper include individuals, sole proprietors, charities and small businesses as defined in the FIDReC rules, and they must be customers of the relevant member institution. Large enterprises, financial institutions or group entities that do not meet the definition of a small business cannot automatically use this channel merely because the transaction occurred in Singapore. Whether a small operating company established in Singapore by a Chinese enterprise is eligible should be determined on the basis of the FIDReC terms in force at the relevant time and the actual circumstances of the enterprise, and not solely by reference to registered capital, company name or the location of the parent company.
Eligibility of the entity is only the first step. Cross-border payments often simultaneously involve the account-opening bank, the payment institution, the receiving institution, the channel service provider and the technology provider. An enterprise needs to identify which institution it has contracted with, which institution holds an MPI or SPI licence, at which point the payment instruction is accepted, in which account customer funds are held, and at which stage the loss actually occurred, whether in currency exchange, remittance out, clearing, crediting or refund.
For example, a Chinese supplier collects payment for goods from an overseas customer through a Singapore trading company, and the trading company then engages a licensed payment institution to make payment to the mainland or to a third country. If the funds are returned because the payee information is incorrect, the dispute may concern the customer instruction and the institution's verification obligations; if the institution has remitted the funds in accordance with the agreement but the intermediary bank suspends the payment due to sanctions screening, liability may in turn depend on the channel rules, information disclosure and the third-party delay clause in the contract. The mere fact that "the money has not arrived" is insufficient to determine which institution should be approached and on the basis of which obligation the claim should be made.
For payment institutions, the changes fall on processes and evidence
MAS's current fair dealing guidelines require financial institutions to handle customer complaints independently, effectively and promptly; the e-payment user protection guidelines, in turn, allocate responsibility between institutions and users in respect of unauthorised and erroneous transactions in protected accounts. With the expansion of FIDReC membership, these internal determinations may be subject to external mediation and adjudication. Payment institutions cannot merely state in their terms that "transactions are irrevocable"; they must also explain how they verify instructions, warn of risks, handle anomalies, investigate fraud and calculate losses.
Institutions need at a minimum to connect four groups of materials. The first group is customer relationship materials, including customer identity, account control, product descriptions and applicable terms; the second group is transaction materials, including instructions, authentication, device and login records, payee information, timestamps and receipts at each point; the third group is risk-handling materials, including alert hits, grounds for interception, manual review, customer notifications and supplementary documents; and the fourth group is loss and recovery materials, including freezes, recalls, refunds, communications with intermediary institutions and the final destination of funds.
Payment businesses rely heavily on cloud services, identity verification, anti-fraud models, card schemes, banks and overseas agents. Outsourcing may change the division of operational tasks, but it does not automatically change the contracting party that the customer faces. Institutions need to re-examine supplier agreements in respect of log retention, incident notification, investigation assistance, evidence production and cost allocation. If a third party can only provide summary reports and cannot reconstruct a specific transaction, it will be difficult for the institution to explain its liability determination in independent dispute proceedings.
The fee mechanism will also affect operations. MAS has proposed that payment institutions may bear an initial onboarding fee, an annual general levy and case fees, although the specific allocation method has not yet been determined. One of the fee principles is to encourage institutions to resolve complaints at an early stage while not discouraging appropriate cases from using FIDReC. This will transform complaint quality from a customer service issue into a quantifiable operational and compliance cost: vague front-end disclosure, slow investigation processes or repeated occurrence of the same failure will ultimately increase compensation, case fees and management resources at the same time.
Cross-border businesses need to draft remedial clauses more precisely
Chinese enterprises using Singapore payment channels can start by examining their existing arrangements through three documents.
The first is the customer agreement. Confirm the contracting entity, licence number, scope of services, the point at which payment is completed, handling of erroneous instructions, rights to suspend or freeze, refund conditions, limitations of liability and complaint escalation methods. Where the platform brand differs from the licensed entity, web page disclosures, order pages and information on the actual receiving and paying accounts should be retained.
The second is the transaction evidence checklist. In addition to contracts, invoices and payment receipts, enterprises should also retain corporate authorisations, operator identities, records of changes to payees, dual approvals, institutional requests for supplementary documents, risk warnings, ticket numbers and the status at each point. Stablecoin transactions also require retention of wallet ownership, on-chain records, fiat currency deposits, redemption requests and issuer responses. A transaction hash can only prove on-chain status; it cannot independently prove customer identity, that a contractual debt has been discharged, or that a particular licensed institution bears liability for compensation.
Third, the dispute roadmap. Which institution to complain to first, how the internal response period is calculated, whether the FIDReC eligibility criteria are met, whether an arbitration or court clause applies, and how cross-border evidence is to be preserved should all be clarified before an incident occurs. Enterprises should also prepare backup payment and liquidity arrangements, so as not to treat remedial procedures as a substitute for business continuity.
How this consultation differs from existing articles
An article on this website dated 10 October discussed whose liabilities tokenized deposits, stablecoins and wholesale central bank digital currencies each represent, and when on-chain settlement is completed. This article discusses, after a funds operation error or a dispute over liability arises, to whom customers can complain, which entities may enter independent dispute resolution, and what evidence payment institutions need to support the outcome of their handling.
The former focuses on settlement assets and exit paths; this article focuses on dispute jurisdiction, allocation of liability and remedial evidence. Stablecoins account for only one of these scenarios; for cross-border remittance, merchant acquiring and e-wallet operators, the process changes brought about by the expansion of FIDReC membership are more direct.
Conclusion
This Singapore consultation does not create an unconditional right to compensation, nor does it automatically give all cross-border enterprises FIDReC eligibility. It advances the regulation of payment institutions one step further: in addition to meeting capital, customer fund protection and anti-money laundering requirements, licensed institutions must also face an independent and accessible dispute resolution mechanism and explain the factual and liability basis for each customer loss.
For Chinese enterprises, the criteria for assessing payment channels should change accordingly. Fees, speed and coverage areas remain important, but whether the contracting entity is licensed, whether complaints can be escalated, whether logs can be obtained, and how liability for losses is allocated also determine whether a funds path is reliable. The clearer the remedial mechanism, the more enterprises need to align the entity, contract, funds and evidence before a transaction.
Main reference materials
- Monetary Authority of Singapore, Consultation on Expanding FIDReC Membership to Payment Service Providers, 16 October 2026：Consultation page。
- Monetary Authority of Singapore, Consultation Paper on Expanding FIDReC Membership to Payment Service Providers, P017-2026, October 2026：Consultation paper (PDF)。
- Monetary Authority of Singapore, Guidelines on Fair Dealing — Board and Senior Management Responsibilities for Delivering Fair Dealing Outcomes to Customers, revised 30 May 2024：Official guidelines。
- Monetary Authority of Singapore, E-Payments User Protection Guidelines, revised 25 October 2024：Official guidelines。
- Financial Industry Disputes Resolution Centre, FIDReC Terms of Reference：Official page。
The information in this article was verified as of October 17, 2026. This article is provided for general information sharing only and does not constitute advice on Singapore law, PRC law, payments, foreign exchange, tax, stablecoins or dispute resolution in relation to any specific matter. The MAS documents are currently at the consultation stage, and the final rules, implementation timeline, fee arrangements and conditions for FIDReC applicability should be governed by the texts in force at the relevant time.
