Nikolai Timofejev
15 years in FinTech and payments. Maps your business model to the right licence scope and leads the file all the way to the Chief Executive's despacho, including banking and payment rails.
Get a payment license in Macao.
Macao has no payment-services law and no electronic-money law. A payment company is authorised as an other financial institution under article 3.º(1)(13) of Lei n.º 13/2023, recognised by the Monetary Authority of Macao and granted by despacho of the Chief Executive, which means political discretion, no statutory decision period and no published fee. Four entities hold that authorisation on the Monetary Authority's register of 26 May 2026, and one of them has not started trading. The printed capital figures belong to the two older routes: MOP 2,000,000 for a cash remittance company under Decreto-Lei n.º 15/97/M and MOP 1,000,000 for a money changer under Decreto-Lei n.º 38/97/M. For a payment institution the law prints no capital figure at all - the Monetary Authority fixes it case by case on the scale and risk of the business.
27 yrs
on the international marketon the market
60+
in-house specialistsspecialists
400+
Licenses obtainedlicenses obtained
Updated
Macao in brief
Four licensees, no payment law, and a licence signed by the Chief Executive.
Start with the number that decides most projects. On 26 May 2026, the date its own register was last revised, the Monetary Authority of Macao listed four entities in the category Other financial institutions - Payment services: Macau Pass S.A., Global Payments Asia-Pacific Macau Limited, Uepay Macao Limited and Keypay Limited, the last marked as authorised but not yet trading. The Monetary Authority's summary table of 18 August 2026 repeats that total of four, beside ten money changers, four cash remittance companies and six casino exchange counters, in a territory of 688,900 residents at the end of 2025. Entry is not closed by any statute. It is closed in practice, and a page that told you otherwise would be caught out by month three. The second thing to know is that no payment-services or electronic-money law exists here. Lei n.º 13/2023, the Regime jurídico do sistema financeiro, published in Boletim Oficial I n.º 33/2023 of 14 August 2023 at pages 2067-2130 and in force since 1 November 2023, names eleven types of financial institution and then adds a residual limb at article 3.º(1)(13): other financial institutions recognised by the Monetary Authority and authorised by the Chief Executive. That limb is the payment licence.
Article 3.º(3) then pulls the credit-institution regime of título II, and the administrative-offence chapter of título IV, across to those institutions with the necessary adaptations, and article 4.º(2) reserves payment services and stored-value means of payment. The authorisation itself is not the regulator's to give. Article 23.º puts it with the Chief Executive, case by case, by despacho, on the Monetary Authority's opinion; the two 1997 decree-laws work the same way, under article 2.º of Decreto-Lei n.º 38/97/M for money changers and article 6.º of Decreto-Lei n.º 15/97/M for remittance companies. Nothing prints a decision period, the licensing guidance promises only that applications will be handled expeditiously, and no fee is published anywhere. Capital follows the pattern: for a payment institution there is no statutory figure, and the Monetary Authority sets the minimum on the scale and risk of the business, with at least half of it deposited to its order. The printed figures sit elsewhere - MOP 1,000,000, about HKD 970,874, for a money changer; MOP 2,000,000, about HKD 1,941,748, for a remittance company; MOP 300 million for a bank and MOP 100 million for a restricted-licence bank under article 25.º. Two things are certain. The supervision fee of article 13.º runs from MOP 50,000 to MOP 5,000,000 a year, collected each June, and article 15.º requires the file in Chinese or Portuguese.
No payment law and no electronic-money law. A payment company is authorised as an other financial institution under article 3.º(1)(13) of Lei n.º 13/2023, in force since 1 November 2023: recognised by the Monetary Authority, granted by despacho of the Chief Executive. Four hold that authorisation on the register of 26 May 2026, one of them not yet trading.
No statutory capital figure for a payment institution, no published fee, no decision period. The Monetary Authority sets capital on scale and risk, with half of it blocked to its order. MOP 2,000,000 for remittance, MOP 1,000,000 for money changing. The file is written in Chinese or Portuguese. Budget twelve to twenty-four months.
The routes
The residual financial-institution licence, or one of the two 1997 decree-laws.
Two doors are realistic, and they differ in what the law is willing to print. The article 3.º(1)(13) route carries the payment scope and no capital figure. The 1997 routes carry a capital figure and a closed list of operations you may not step outside.
The article 3.º(1)(13) licence, or one of the two 1997 decree-laws.
01 - PAYMENT INSTITUTION
Other financial institution, article 3.º(1)(13)
The residual limb of article 3.º of Lei n.º 13/2023: an institution recognised by the Monetary Authority and authorised by despacho of the Chief Executive under article 23.º. Scope is whatever the despacho allows, because no statute lists the permitted payment services and no separate stored-value or electronic-money licence exists. Article 3.º(3) applies título II, the credit-institution regime, to the institution with adaptations, so the file is built to bank standards.
The residual limb of article 3.º of Lei n.º 13/2023: an institution recognised by the Monetary Authority and authorised by despacho of the Chief Executive under article 23.º. Scope is whatever the despacho allows, because no statute lists the permitted payment services and no separate stored-value or electronic-money licence exists. Article 3.º(3) applies título II, the credit-institution regime, to the institution with adaptations, so the file is built to bank standards.
- ✓No statutory capital figure; set on business scale and risk
- ✓At least half the amount deposited to the Monetary Authority's order
- ✓Recognised by AMCM, authorised by despacho (art. 23.º)
- ✓Credit-institution regime applies with adaptations (art. 3.º(3))
- ✓Five directors, three habitually resident, one a Macao resident (art. 56.º)
- ✓No decision period and no fee in any published text
02 - REMITTANCE OR MONEY-CHANGING COMPANY
Printed capital, closed scopeSEV under DL 15/97/M, casa de câmbio under DL 38/97/M
Both 1997 decree-laws survive, amended by Lei n.º 13/2023 and adapted by Lei n.º 27/2024. A sociedade de entrega rápida de valores em numerário delivers cash values in Macao or abroad on a third party's order once that party has handed over the counter-value, and carries on no other commercial activity. A casa de câmbio buys and sells foreign banknotes, coin and travellers' cheques on the closed list of article 12.º. Neither may lend or take repayable funds.
Remittance MOP 2,000,000, money changer MOP 1,000,000; closed list of operations, no lending, no deposits.
- ✓Remittance MOP 2,000,000 (HKD 1,941,748), art. 8.º DL 15/97/M
- ✓Money changer MOP 1,000,000 (HKD 970,874), art. 4.º DL 38/97/M
- ✓Sociedade anónima or sociedade por quotas, paid in cash
- ✓Half the minimum capital blocked to the Monetary Authority's order
- ✓One resident director; premises used only for the licensed object
- ✓Supervision fee capped at 3% of the minimum capital
Costs and timelines are confirmed for your case before any work begins. Neither Lei n.º 13/2023 nor the Monetary Authority's licensing guidance publishes an application or licence fee, and no text sets a decision period, so state charges and dates are quoted once the Banking Supervision Department confirms them for your file. The annual supervision fee of article 13.º runs from MOP 50,000 to MOP 5,000,000 and is collected each June, save where a specific statute provides otherwise: for money changers and cash remittance companies it is capped at 3% of the required minimum capital, which is MOP 30,000 and MOP 60,000. One more date to diarise - the authorisation lapses if the company is not incorporated, or does not start business, within six months of the despacho, extendable on a reasoned request.
Why Macao
Small, pegged, and wired into the Greater Bay Area.
Macao had 688,900 residents at the end of 2025. The reasons to license here are the currency, the rails and the tax table. None of them is a reason to expect an easy authorisation, and the card on the sandbox is the only door the regulator opens by itself.
✓
A currency board at HKD 1 : MOP 1.03
The pataca is fully backed under a currency board, at the rate the Monetary Authority states for the note-issuing banks. Capital, client balances and Hong Kong dollar revenue do not drift apart on an exchange rate.HKD 1 : MOP 1.03, fully backed.
✓
The Fast Payment System
The Monetary Authority built and runs the domestic instant rail, whose retail service is Easy Transfer. It reaches pataca and Hong Kong dollar accounts at participating financial institutions, runs around the clock and credits funds in as little as 30 seconds. The aggregated merchant QR scheme, Simple Pay, is also the Monetary Authority's own.AMCM rail, funds in 30 seconds.
✓
A signed link to the Mainland
The People's Bank of China and the Monetary Authority signed a memorandum on cross-boundary linkage of payment systems between the Mainland and Macao, announced by the Macao government on 13 October 2025, setting a cooperation framework for cross-boundary transfer channels.PBOC memorandum, 13 October 2025.
✓
Volumes that are actually published
Local mobile payment tools moved MOP 8.9 billion in the fourth quarter of 2025 across 103.8 million transactions, an increase of 7.4%, on the Monetary Authority's release of 13 February 2026. A market this size can be modelled from public numbers.MOP 8.9 billion in Q4 2025.
✓
Twelve per cent at the top
Complementary tax runs from 3% to 12%, with 12% above MOP 300,000 of taxable profit, and the budget law lifts the exempt slice to MOP 600,000 for the year. No VAT, GST or sales tax appears among the taxes the Financial Services Bureau administers.MOP 600,000 exempt, no VAT.
✓
The one authorisation AMCM grants itself
Título III of Lei n.º 13/2023 gives the Monetary Authority its own power to grant a temporary authorisation for financial innovation under article 113.º, valid for a year and extendable twice by a year each. Technology businesses are eligible under article 112.º.AMCM grants it itself, one year.
How it compares
How Macao differs from Hong Kong, Singapore and Taiwan.
Three of the four regulators in this table license in their own name. Macao's does not: the Monetary Authority gives an opinion and the Chief Executive signs. That one difference runs through the capital column, the clock column and the size of the register.
Macao vs other jurisdictions
| Feature |  Macao | Other jurisdictions |
|---|---|---|
| Who decides | Chief Executive by despacho, on AMCM's opinion (art. 23.º) | The regulator itself: HKMA, MAS, the Taiwanese FSC |
| Capital | No figure for a payment institution; set case by case | S$100,000 and S$250,000 Singapore · NT$500M Taiwan |
| Decision clock | None printed at any stage | None for a Taiwanese permit either; not published for Hong Kong or Singapore |
| Client money | No statutory float rule, no AMCM guideline | Full trust or a bank performance guarantee in Taiwan (art. 21) |
Who decides
MacaoChief Executive by despacho, on AMCM's opinion (art. 23.º)
Other jurisdictionsThe regulator itself: HKMA, MAS, the Taiwanese FSC
Capital
MacaoNo figure for a payment institution; set case by case
Other jurisdictionsS$100,000 and S$250,000 Singapore · NT$500M Taiwan
Decision clock
MacaoNone printed at any stage
Other jurisdictionsNone for a Taiwanese permit either; not published for Hong Kong or Singapore
Client money
MacaoNo statutory float rule, no AMCM guideline
Other jurisdictionsFull trust or a bank performance guarantee in Taiwan (art. 21)
Country by country
| Country | License type | Taxation | Requirements |
|---|---|---|---|
| Macao | Other financial institution - payment services | 12% above MOP 600,000 · no VAT | No capital figure · no decision period |
 Hong Kong | Stored value facility (HKMA, Cap. 584) | 8.25% / 16.5% | Capital figure not published here · 11 non-bank licensees |
 Singapore | SPI / MPI (MAS) | 17% · reliefs | S$100,000 SPI · S$250,000 MPI · citizen or PR director |
 Taiwan | E-payment institution (FSC) | 20% · turnover tax 5-10% | NT$500M full scope · full trust or bank guarantee |
MacaoLicense typeOther financial institution - payment services
Taxation12% above MOP 600,000 · no VAT
RequirementsNo capital figure · no decision period
Hong KongLicense typeStored value facility (HKMA, Cap. 584)
Taxation8.25% / 16.5%
RequirementsCapital figure not published here · 11 non-bank licensees
SingaporeLicense typeSPI / MPI (MAS)
Taxation17% · reliefs
RequirementsS$100,000 SPI · S$250,000 MPI · citizen or PR director
TaiwanLicense typeE-payment institution (FSC)
Taxation20% · turnover tax 5-10%
RequirementsNT$500M full scope · full trust or bank guarantee
Before you apply
Requirements for a Macao payment authorisation.Requirements for the authorisation.
Article 26.º sets what goes into the file and article 27.º sets what the Monetary Authority weighs. Everything else below comes from the credit-institution regime that article 3.º(3) applies to payment institutions with adaptations, and from the two decree-laws where the older routes differ.
01
A Macao-incorporated company or a Macao branch of a foreign institution, which is what the Monetary Authority's licensing guidance contemplates for a payment institution; local credit institutions must be sociedades anónimas under article 24.º, money changers and remittance companies may be a sociedade anónima or a sociedade por quotas, and article 12.º of Decreto-Lei n.º 15/97/M shuts the branch door for remittance by barring entities with their seat abroad from opening branches or representative offices in Macao for that activity.
02
Capital that the law declines to print: for a payment institution the Monetary Authority sets the minimum by reference to the scale and risk of the business, with at least half of it deposited with the Monetary Authority or with a credit institution authorised in Macao at its disposal. The printed figures are MOP 1,000,000 for a money changer under article 4.º of Decreto-Lei n.º 38/97/M and MOP 2,000,000 for a remittance company under article 8.º of Decreto-Lei n.º 15/97/M, both subscribed and paid in cash at incorporation, with the net situation never below the minimum and six months to cure a shortfall.
03
The article 26.º dossier: a feasibility study and business plan that explains why the institution suits Macao's economic and financial policy, a statement on corporate governance, risk management, internal control, contingency recovery and anti-money-laundering arrangements, draft articles of association, the rationale for the ownership structure, information on every direct or indirect holder of 5% or more and on the group above them, information on directors and supervisors, the source of the funds, and the human, material and technical resources behind the plan.
04
An ownership chain the Monetary Authority can assess under article 27.º, which weighs the suitability of qualifying holders, the adequacy and viability of the plan, the soundness of governance and risk management, and, for foreign qualifying shareholders, the economic and financial situation of their home jurisdiction, its supervisor's capacity and how effectively that supervisor cooperates with the Monetary Authority. Nothing in the law prohibits foreign ownership.
05
A management body built to article 56.º: at least five directors of good repute, three of them habitually resident in Macao and at least one of those a Macao resident, with a supervisory body of at least three members including a qualified accountant, and a branch run by at least two mandatários habitually resident in Macao. The licensing guidance applies the same template of five, three and one to other financial institutions, adjustable per circumstances; a money changer needs one resident member of its management body and a remittance company one resident executive member.
06
Individual clearance before anyone takes office. Article 57.º sets the fit-and-proper test and its negative list, which runs from bankruptcy and bad cheques through fraud, forgery, embezzlement, corruption, extortion, usury and unauthorised deposit-taking to money laundering and terrorist financing; article 58.º bars a director, supervisor, branch manager or senior manager from acting before the Monetary Authority has verified suitability and completed the special registration; article 59.º requires supervening facts to be reported afterwards.
07
Premises and public-facing conduct: money changers and remittance companies must work from premises suited to the business, easily accessible to the public and used exclusively for the licensed object, any further establishment needs prior authorisation from the Monetary Authority, and article 16.º(1) forbids an unauthorised entity to advertise financial products or services at all.
08
A client-money design you build rather than read off the page. Lei n.º 13/2023 has no segregation, trust or float-guarantee article for payment institutions, and the Monetary Authority publishes no notice or guideline on payment services, stored value, electronic money or float safeguarding, so there are also no published wallet caps, no interest prohibition and no redemption rule. The closest published requirements are the blocked deposit of half the minimum capital and, for remittance companies, article 17.º of Decreto-Lei n.º 15/97/M, which requires accounts at credit institutions operating in Macao for the movement of activity funds and routes money in and out of Macao through credit institutions. Anything further is written into the despacho, which is not published in full.
09
Anti-money-laundering under Lei n.º 2/2006 as amended by Lei n.º 3/2017, whose article 6.º names credit institutions, money changers and remittance companies but keeps the list open, so an article 3.º(1)(13) institution is caught as an entity supervised by the Monetary Authority: customer due diligence, detection of suspicious operations, refusal to transact where information is withheld, records kept at least five years, the tipping-off prohibition of article 7.º(4), and a report to the Gabinete de Informação Financeira within two working days of detection regardless of the amount, under article 7.º of Regulamento Administrativo n.º 7/2006 and the Monetary Authority's AML and CFT guideline.
10
A file written in Chinese or Portuguese. Article 15.º(1) requires applications, their instructing documents and public notices in at least one official language, and article 15.º(2) requires an authenticated translation of any document in another language unless the Monetary Authority expressly waives it, so English is not accepted as of right. The licensing guidance itself is published in Chinese only and there is no official English text of the Financial System Act. The authorisation then lapses if the company is not incorporated, or does not start business, within six months of the despacho.
01
Macao company, or a branch except for remittance.
02
Capital set case by case; half blocked at AMCM's order.
03
Article 26.º dossier: plan, governance, risk, AML.
04
Article 27.º assessment of qualifying shareholders.
05
Five directors, three resident, one Macao resident.
06
Fit and proper, plus special registration (art. 58.º).
07
Premises used only for the licensed object.
08
Client-money terms come from the despacho, not a rule.
09
STR to the GIF within two working days, any amount.
10
File in Chinese or Portuguese (art. 15.º).
Reflects Lei n.º 13/2023 of 14 August 2023, in force 1 November 2023, Decreto-Lei n.º 38/97/M and Decreto-Lei n.º 15/97/M as amended by Lei n.º 13/2023 and adapted by Lei n.º 27/2024, Lei n.º 2/2006 as amended, and the Monetary Authority's licensing guidance, as of 2026. Two figures a founder may expect to find are not published: the capital-adequacy ratio behind articles 67.º and 68.º and Notice n.º 011/2015-AMCM, and the daily per-client limits that article 5.º of Decreto-Lei n.º 15/97/M leaves to an aviso.Lei n.º 13/2023; DL 38/97/M and DL 15/97/M as amended; Lei n.º 2/2006 as amended; AMCM licensing guidance, as of 2026.
How it works
From first call to the despacho.
01
Route and scope
Payment institution under article 3.º(1)(13), remittance company, money changer or the sandbox, and the services you will actually sell, because the despacho fixes the scope.Payment institution, remittance, exchange or sandbox.
02
Company and capital
The Macao company incorporated, the capital figure agreed with the Monetary Authority for your scale and risk, subscribed and paid in cash, half of it blocked to the Monetary Authority's order.Paid in cash, half blocked to AMCM's order.
03
The application file
The article 26.º dossier assembled in Chinese or Portuguese and lodged with the Banking Supervision Department, with authenticated translations where a document comes in another language.Article 26.º dossier, Banking Supervision Department.
04
Opinion, then despacho
The Monetary Authority forms its opinion under article 23.º and the Chief Executive decides. No text sets a period for either stage and no processing statistics are published.No period set; 12-24 months realistic.
05
Six months to open
Incorporation completed and business started within six months of the despacho, extendable on a reasoned request, with every director specially registered before acting.Incorporate and start business, or it lapses.
Quick facts
RegulatorAMCM advises · Chief Executive grants
LawLei n.º 13/2023, in force 1 November 2023
LicenceOther financial institution, art. 3.º(1)(13)
CapitalNo statutory figure · case by case
Older routesMOP 2,000,000 remittance · 1,000,000 exchange
DecisionNo statutory period · no published fee
Supervision feeMOP 50,000 to 5,000,000, each June
Timeline12-24 months realistic
The only hard clock in this process runs after the decision rather than before it: six months from the despacho to incorporate and start business, extendable on a reasoned request, under article 16.º of Decreto-Lei n.º 38/97/M and article 21.º of Decreto-Lei n.º 15/97/M, with the same six months for a foreign bank branch to lodge its working-capital deposit under article 31.º(2). Before the decision there is nothing to count. We budget twelve to twenty-four months and say plainly that the outcome is discretionary.
Your Macao desk
Run from our Greater Bay Area desk.
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Dubai · coordinating Macao mandates
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01
The Macao company
Incorporation, the shareholding documented to the beneficial owner for article 27.º, capital subscribed and paid in cash, and half of it blocked with the Monetary Authority or a Macao credit institution at its order.Incorporation, capital, blocked deposit.
02
The file for the Banking Supervision Department
The article 26.º dossier - feasibility study, business plan, governance, risk management, internal control, recovery and AML - drafted in Chinese or Portuguese, with authenticated translations of anything that arrives in another language, and defended through the question rounds.Article 26.º dossier, in Chinese or Portuguese.
03
People the register will accept
Five directors with three habitually resident in Macao and one of them a Macao resident, a supervisory body including a qualified accountant, and every one of them cleared and specially registered under article 58.º before taking office.Directors cleared and specially registered.
04
The gaming boundary
Article 11.º of Lei n.º 20/2024 punishes unauthorised currency exchange for gaming with up to five years in prison, and exchange carried out in a casino is presumed to be for gaming, casinos including the adjacent hotel, retail and entertainment areas. We draw that line into the product before it is built.Casino exchange is criminal without authority.
We also have offices in
Tallinn
Estonia
Roseni 13
Vilnius
Lithuania
Gedimino pr. 2
Prague
Czech Republic
Vlkova 532/8, Žižkov
London
United Kingdom
7 Bell Yard
Madeira
Portugal
Rua da Alegria 31, 1F
Budapest
Hungary
Korányi Sándor u. 4
Istanbul
Turkey
Perpa Ticaret Merkezi, A Blok
Good to know
Taxation of payment companies in Macao.
The rate table is short and the top rate is 12%. The budget law then exempts the first MOP 600,000 of profit for the year, and there is no VAT to model into pricing.
Complementary tax, 3% to 12%
The Regulamento approved by Lei n.º 21/78/M, with the rate table amended by Lei n.º 4/2005: exempt to MOP 32,000, then 3%, 5%, 7% and 9% through the bands, and 12% above MOP 300,000 of taxable income.3% to 12% on the statutory table.
The MOP 600,000 exemption
The exempt slice is granted year by year in the budget law, currently Lei n.º 13/2025 for the 2026 budget, which the Financial Services Bureau publishes at MOP 600,000. The practical effect for a profitable payment company is 12% above that.MOP 600,000 for the year.
Territorial by design
Article 2.º(1) taxes income earned in the territory whatever the taxpayer's residence or seat. Lei n.º 24/2024 added article 2.º(2), reaching dividends, interest, royalties and capital gains earned outside Macao by ultimate parent entities of multinational groups that are Macao tax residents.Income earned in the territory.
No VAT, GST or sales tax
None appears among the taxes the Financial Services Bureau administers, which are complementary tax, salaries tax, property tax, stamp duty, business tax, consumption tax, motor vehicle tax and tourism tax.None among the taxes administered.
Stamp duty and business tax
The same annual relief exempts stamp duty on banking transactions and on insurance contracts, and exempts payment of business tax. For a payments model that removes a per-transaction tax layer other jurisdictions charge.Exempted on banking transactions.
Group A accounting
Audited Group A accounts are required of joint-stock companies, of ultimate parent entities of multinational groups, and of companies with capital of MOP 1,000,000 or more or average taxable profit of MOP 1,000,000 over three years. Most licensed payment companies land there.Audited accounts from MOP 1,000,000.
Tax summary
Complementary tax3% to 12% · 12% above MOP 300,000
Annual exemptionMOP 600,000 (Lei n.º 13/2025)
ScopeTerritorial (art. 2.º(1))
VAT / GSTNone among the taxes administered
Stamp dutyExempted on banking transactions
Dividends to non-residentsNo withholding rule published
*Figures as of 2026, from the Regulamento do Imposto Complementar de Rendimentos approved by Lei n.º 21/78/M as amended by Lei n.º 4/2005 and Lei n.º 24/2024, and from the Financial Services Bureau's tax pages, which carry no last-updated date. Two honest gaps: the Regulamento contains no withholding provision for dividends paid to non-residents and no official page states a rate, so that position is confirmed for your structure rather than quoted here; and although no VAT, GST or sales tax appears among the taxes administered, no official sentence says so in terms. Treaty and regime positions are assessed per structure.
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Macao · AMCM
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The Macao payment licence, answered.
What licence does a payment business need in Macao?+
There is no payment licence as such, because Macao has no payment-services law and no electronic-money law. A payment company is authorised as an other financial institution recognised by the Monetary Authority and authorised by the Chief Executive, under article 3.º(1)(13) of Lei n.º 13/2023, and its permitted activity is whatever the despacho says. Article 4.º(2) reserves payment services and stored-value means of payment, which is what makes the authorisation compulsory. Beside that limb sit the two 1997 decree-laws, for cash remittance and for money changing.
How many payment institutions hold a Macao authorisation?+
Four, and one of them has not opened for business. The Monetary Authority's register, last revised 26 May 2026, lists Macau Pass S.A., Global Payments Asia-Pacific Macau Limited, Uepay Macao Limited and Keypay Limited, the last marked as authorised but yet to start trading. The Monetary Authority's summary table of 18 August 2026 repeats the total of four alongside ten money changers, four cash remittance companies and six casino exchange counters. Read the register as the honest measure of how open this market is.
Who grants the licence and who supervises afterwards?+
The Chief Executive grants it. Article 23.º makes the authorisation his, case by case, by despacho, on the Monetary Authority's opinion, and article 6.º puts superintendence of the financial market with him as well, while article 7.º leaves the Monetary Authority with supervision and coordination. In its own name the Monetary Authority decides only secondary matters, such as a change of registered office or the opening, relocation and closure of branches under article 23.º(4). The one authorisation it grants itself is the temporary authorisation for financial innovation under article 113.º.
How much capital is required?+
For a payment institution the law prints no figure. The licensing guidance says the minimum capital of a locally established company, or the working capital of a Macao branch, is fixed by reference to the scale and risk of the business, with at least half of it deposited with the Monetary Authority or with a credit institution authorised in Macao at its disposal. The printed figures belong to the older routes: MOP 1,000,000, about HKD 970,874, for a money changer under article 4.º of Decreto-Lei n.º 38/97/M, and MOP 2,000,000, about HKD 1,941,748, for a cash remittance company under article 8.º of Decreto-Lei n.º 15/97/M. For scale, article 25.º asks MOP 300 million of a bank and MOP 100 million of a restricted-licence bank.
How long does a decision take?+
No text sets a period at any stage, and no processing statistics are published. The licensing guidance says only that applications will be handled expeditiously. We budget twelve to twenty-four months from the first call and tell clients plainly that the outcome is discretionary, because the file goes to the Chief Executive rather than into a queue with a service standard. The only hard clock arrives after the decision: six months from the despacho to incorporate and start business, extendable on a reasoned request.
How is customer money protected?+
By whatever the despacho requires, because nothing general is published. Lei n.º 13/2023 has no segregation, trust or float-guarantee article for payment institutions, and the Monetary Authority has issued no notice or guideline on payment services, stored value, electronic money or float safeguarding, which also means no published wallet caps, no interest prohibition and no redemption rule. The nearest published requirements are the blocked deposit of at least half the minimum capital, held with the Monetary Authority or to its order, and article 17.º of Decreto-Lei n.º 15/97/M, which makes a remittance company keep accounts at credit institutions operating in Macao and move money in and out of the territory through them.
Can a foreign group own a Macao payment institution?+
Yes. Nothing in Lei n.º 13/2023 prohibits foreign ownership; article 27.º(6) instead makes the home jurisdiction of foreign qualifying shareholders an assessment factor, weighing its economic and financial situation, its supervisor's capacity and how effectively that supervisor cooperates with the Monetary Authority. The one hard exclusion is narrower: article 12.º of Decreto-Lei n.º 15/97/M bars an entity with its seat abroad from opening a branch or representative office in Macao for remittance activity, so that route needs a locally incorporated company. Residency bites at board level rather than shareholder level, under article 56.º.
Which language is the application filed in?+
Chinese or Portuguese. Article 15.º(1) requires applications, their instructing documents and the notices a financial institution issues to the public in at least one official language, and article 15.º(2) requires an authenticated translation of any document in another language unless the Monetary Authority expressly waives it. English is therefore not accepted as of right. The licensing guidance is published in Chinese only and there is no official English text of Lei n.º 13/2023, so translation and local counsel belong in the budget from day one.
Is currency exchange near a casino restricted?+
It is a criminal matter. Article 11.º of Lei n.º 20/2024, in force since 29 October 2024, punishes anyone who runs a currency-exchange business for gaming without legal authorisation with up to five years in prison, and it presumes that exchange carried out in a casino is for gaming, with casino covering adjacent premises used for artistic, cultural, recreational, commercial or hotel activities. Exchange counters inside casinos are a closed category under Decreto-Lei n.º 39/97/M, held by the six concessionaires on a register last revised 16 January 2026. Money changers and remittance companies are separately barred from lending and deposit-taking, which forecloses any casino-credit adjacency.
Why Macao rather than Hong Kong or Singapore?+
Only if the Macao market itself is the point: the gaming and tourism economy, the pataca, the cross-boundary link the People's Bank of China and the Monetary Authority signed on 13 October 2025. On process the alternatives are easier: Hong Kong's Monetary Authority licenses stored-value facilities in its own name under the Payment Systems and Stored Value Facilities Ordinance and had eleven non-bank licensees on its register at 14 August 2026; Singapore's MAS licenses under the Payment Services Act 2019 with published base capital of S$100,000 for a standard payment institution and S$250,000 for a major one. Macao has four payment institutions, no payment law, no published capital figure and no decision period. Groups that need a regional hub build it in Hong Kong or Singapore and come here for the Macao business.
Which licence?+
Other financial institution, art. 3.º(1)(13).
How many hold it?+
Four, one of them not yet trading.
Who grants it?+
The Chief Executive, on AMCM's opinion.
Capital?+
No figure; set on scale and risk.
How long?+
No statutory period; 12-24 months realistic.
Client money?+
No published float rule; terms come from the despacho.
Foreign owners?+
Allowed; the home supervisor is assessed.
Language?+
Chinese or Portuguese, art. 15.º.
Casino exchange?+
Up to five years in prison without authority.
vs Hong Kong / Singapore?+
Both easier on process; Macao for the Macao market.
Client notes
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