15 years in FinTech and payments. Maps your business model to the right licence scope and leads the file all the way to registration on the FSPR, including banking and payment rails.
Get a payment license in New Zealand.
New Zealand licenses no payment institutions and no e-money issuers, because it has no such licence to give. A payments business registers instead: section 11 of the Financial Service Providers (Registration and Dispute Resolution) Act 2008 requires registration for each financial service provided, and section 5 catches the work through paragraph (f), operating a money or value transfer service, paragraph (g), issuing or managing the means of payment, and paragraph (ab), a regulated client money or property service. There is no minimum capital, no bond and no guarantee anywhere in that Act or in the Financial Service Providers (Registration) Regulations 2020. What sits in place of capital is membership of an approved dispute resolution scheme under section 48(1), supervision by the Department of Internal Affairs under the AML/CFT Act 2009, and a power for the Financial Markets Authority to refuse or strike off a registration that would create a false or misleading appearance about how much of the business is really here. Registration costs NZ$300 plus GST with an FMA levy of NZ$600 plus GST, and the Act prints no decision period at all.
Updated
No licence, no capital, and one power that decides whether an offshore-facing registration survives.
New Zealand has no payment-institution licence and no e-money licence. What it has is a register. Section 11 of the Financial Service Providers (Registration and Dispute Resolution) Act 2008, 2008 No 97, requires a person in the business of providing a financial service to be registered for that service and, where section 48 applies, to belong to an approved dispute resolution scheme; carrying on without registration costs an individual up to 12 months of imprisonment or a fine of NZ$100,000, and a company NZ$300,000. Three paragraphs of section 5 catch a payments business: (f), operating a money or value transfer service; (g), issuing or managing the means of payment, which the section itself illustrates with electronic money; and (ab), a regulated client money or property service. Section 48(1) adds scheme membership for anyone serving retail clients. The third statute is the Anti-Money Laundering and Countering Financing of Terrorism Act 2009, which makes a payments firm a financial institution and so a reporting entity under section 5, supervised by the Department of Internal Affairs, or by the Financial Markets Authority under section 130 where the firm is also a client money or property service provider. The Companies Office says the rest out loud: being registered as a financial service provider does not mean that you are licensed or regulated in New Zealand.
There is no minimum capital. No own funds, no net tangible assets, no bond, no guarantee, no professional indemnity insurance: no figure of any kind appears in the Act or in the Financial Service Providers (Registration) Regulations 2020, and section 13 asks only that the applicant is not disqualified under section 14 and holds any licence another enactment requires. Four things fill that space. Dispute resolution scheme membership under section 48. Anti-money-laundering supervision, which for most payments firms is the only continuing prudential-style scrutiny they will meet. Directors' duties under the Companies Act 1993. And, where client money is held, the trust, segregation, accounting and record-keeping duties in subpart 5B of Part 6 of the Financial Markets Conduct Act 2013, sections 431V to 431ZJ, which bite with no licence at all. The state fees are small: NZ$300 plus GST to apply, an FMA levy of NZ$600 plus GST on registration, NZ$11.30 plus GST for each criminal history check, then NZ$75 plus GST a year and the levy for your class, NZ$660 plus GST for a Class 7 provider. Section 10(d) of the Companies Act 1993 asks for one director who lives in New Zealand, or who lives in Australia and sits on the board of an Australian company. Australia is the only country prescribed for that purpose.
New Zealand has no payment or e-money licence. Section 11 of the FSP Act 2008 requires registration for each service: section 5(f) money or value transfer, 5(g) issuing or managing the means of payment, 5(ab) client money. Section 48(1) adds a dispute resolution scheme. The AML/CFT Act 2009 puts a payments firm under the Department of Internal Affairs.
No capital, bond or guarantee anywhere in the Act or the 2020 regulations. NZ$300 plus GST to apply, a NZ$600 FMA levy, no decision period. One director must live in New Zealand or Australia. The trap: sections 15A and 18A let the FMA refuse or strike off a false or misleading appearance of New Zealand business.
Registration on the register, or a licence from the Financial Markets Authority.
Almost every payments and money-transfer model in New Zealand takes the first route and never meets a licensing decision. The second route is not an upgrade. It is what happens when the product design crosses into derivatives, into a debt security, into regulated advice or into holding client money, and the application fee moves from NZ$300 plus GST to NZ$10,695 including GST. We test the perimeter first.
Register on the FSPR - or take an FMC Act licence when the product crosses the line.
Registration under the FSP Act 2008
The ordinary path for a remitter, a wallet issuer or a cross-border payments firm. Section 11 requires registration for each financial service, the Registrar records it, and nobody grants anything: the Companies Office states that being registered as a financial service provider does not mean that you are licensed or regulated in New Zealand. No capital test, no decision period in the Act.
The ordinary path for a remitter, a wallet issuer or a cross-border payments firm. Section 11 requires registration for each financial service, the Registrar records it, and nobody grants anything: the Companies Office states that being registered as a financial service provider does not mean that you are licensed or regulated in New Zealand. No capital test, no decision period in the Act.
- ✓Section 5(f) money or value transfer service
- ✓Section 5(g) issuing or managing the means of payment
- ✓Section 5(ab) regulated client money or property service
- ✓No capital, own funds, bond, guarantee or insurance
- ✓Approved dispute resolution scheme (section 48(1))
- ✓NZ$300 plus GST · FMA levy NZ$600 plus GST
Market services licence under the FMC Act 2013
Four product decisions pull a payments firm into Part 6 of the Financial Markets Conduct Act 2013. Selling forward or non-deliverable foreign exchange to retail customers makes the firm a derivatives issuer, and section 41 requires a licence for a regulated offer. A redeemable wallet balance can answer the section 8(1)(a) description of a debt security, and section 8 prints no prepaid or stored-value carve-out. Regulated financial advice needs a financial advice provider licence. Client money needs no licence and still carries duties.
FMC Act market services licence: derivatives issuer for retail forward FX (s 41), a wallet float capable of being a debt security (s 8(1)(a)), advice, and client money duties without any licence.
- ✓Derivatives issuer licence for retail forward FX (s 41)
- ✓Wallet float capable of being a debt security (s 8(1)(a))
- ✓No prepaid or stored-value carve-out in section 8
- ✓Financial advice provider licence for regulated advice
- ✓Client money duties without a licence (ss 431V to 431ZJ)
- ✓NZ$10,695 incl GST · NZ$178.25 an hour · around six weeks
Costs and timelines are confirmed for your case before any work begins. Three further statutes get read and then mostly set aside. The Retail Payment System Act 2022 regulates designated retail payment networks and creates no licence, authorisation or registration for a payment service provider. The Financial Market Infrastructures Act 2021, in force since 1 March 2024, lets the Minister designate a systemically important payment system on the Reserve Bank's recommendation under sections 20 and 22(2); designation is discretionary and application-based, and nothing requires a payment system to hold anything. The Deposit Takers Act 2023 draws its perimeter at the business of borrowing and lending money under section 5(1), which leaves issuing means of payment, remittance and wallet float outside it. A float that pays interest or is on-lent is a different question and gets its own advice.
No capital, fees measured in hundreds, and a register you can be struck off.
The attraction is real and it is narrow. New Zealand had 5,361,300 residents at 31 March 2026, so nobody comes here for the domestic market. They come because the entry cost is close to nothing, and the country then asks a hard question about whether the business is actually here.
No minimum capital, own funds, net tangible assets, bond, guarantee or insurance figure appears in the FSP Act 2008 or in the Financial Service Providers (Registration) Regulations 2020. Section 13 asks only that the applicant is not disqualified under section 14.No figure in the Act.
NZ$300 plus GST to apply, an FMA levy of NZ$600 plus GST on registration and NZ$11.30 plus GST per criminal history check. The yearly bill for a Class 7 provider is NZ$75 plus GST and a levy of NZ$660 plus GST.NZ$300 plus a NZ$600 levy.
Section 10(d) of the Companies Act 1993 wants one director who lives in New Zealand, or who lives in an enforcement country and is a director of a company incorporated there. Regulation 12 of the 1994 regulations prescribes one such country: Australia.New Zealand, or Australia (reg 12).
Regulation 17(2) of the 2020 regulations puts a provider in business twelve months or more below the threshold at fewer than 10 New Zealand residents and less than NZ$10,000. The first-year tests in regulations 15(2) and 16(2) use five residents and NZ$5,000.10 residents or NZ$10,000 (reg 17).
The Reserve Bank widened the Exchange Settlement Account System criteria in March 2025 and announced the second and final phase, open to all other interested entities, on 23 September 2025. Payment service providers are named among those who may apply.Payment providers may apply since 2025.
The Mastercard and Visa Interchange Fee Network Standard 2025 of 17 July 2025 sets domestic caps from 1 December 2025: debit at 0.00% card-present, 0.20% contactless, 0.60% online; credit at 0.30% and 0.70%. The interbank network is not designated, because the Minister did not accept the Commerce Commission's 2024 recommendation.Standard 2025, from 1 December 2025.
How New Zealand differs from the licensing regimes around it.
Singapore, the United Kingdom and Australia all license payments. New Zealand registers them, and the difference in entry cost is the whole argument. Figures for the other three come from MAS, legislation.gov.uk and ASIC; their tax rates are not in the source set behind this page, so they are confirmed for your structure rather than quoted from memory.
| Feature | New Zealand | Other jurisdictions |
|---|---|---|
| Authorisation | FSPR registration - expressly not a licence | A licence from MAS, the FCA or ASIC |
| Minimum capital | None in the FSP Act 2008 or the 2020 regulations | EUR 350,000 UK e-money · S$100,000-250,000 Singapore |
| Decision clock | None in the Act · FMA referral adds 10 working days | 3 months in the UK · 150 days at ASIC |
| Where payments sit | Three statutes and no payments licence | A dedicated regime in Singapore and the UK · the AFS licence in Australia |
| Country | License type | Taxation | Requirements |
|---|---|---|---|
New Zealand | FSPR registration (Companies Office) | 28% · GST 15%, financial services exempt | No capital · resident director · dispute scheme |
Australia | AFS licence (ASIC) | Confirmed per structure | Capital not confirmed · 150 days to a decision |
Singapore | SPI / MPI licence (MAS) | Confirmed per structure | Base capital S$100,000-250,000 · security on top |
United Kingdom | Authorised EMI (FCA) | Confirmed per structure | Initial capital EUR 350,000 · decision in 3 months |
New Zealand
Australia
Singapore
United KingdomRequirements for the FSPR registration.Requirements for the FSPR registration.
Three statutes and one set of regulations do the work: the FSP Act 2008 for the register, the AML/CFT Act 2009 for the programme, the Companies Act 1993 for the entity and the FMC Act 2013 for the perimeter. The checklist below is what a passing file contains.
Reflects the Financial Service Providers (Registration and Dispute Resolution) Act 2008, the Financial Service Providers (Registration) Regulations 2020, the AML/CFT Act 2009, the Companies Act 1993 with its 1994 regulations, and the Financial Markets Conduct Act 2013, as of 2026. No capital, bond, guarantee or insurance requirement appears in the FSP Act or the 2020 regulations, and neither prints a decision period.FSP Act 2008; FSP (Registration) Regulations 2020; AML/CFT Act 2009; Companies Act 1993 and its 1994 regulations; FMC Act 2013, as of 2026.
From first call to the register.
Which paragraphs of section 5 the business touches, and whether the product crosses into the FMC Act - derivatives, a debt security, regulated advice or client money.Section 5 services; FMC Act tested.
New Zealand company incorporated, registered office and address for service set, and the section 10(d) director appointed in New Zealand or in Australia.Formed, office set, director appointed.
AML/CFT risk assessment and written programme built, compliance officer appointed as an employee, and membership of an approved dispute resolution scheme arranged.AML programme, officer, dispute scheme.
Application filed with the NZ$300 fee and the NZ$600 FMA levy, criminal history checks run in two to five working days, and the file written so it never reads as an offshore shell.Filed with fee and levy; checks run.
Bank accounts opened, client money arrangements live, and the annual calendar running at NZ$75 plus GST and the levy for your class.Accounts opened, annual calendar running.
There is no statutory clock, so the risk here is not delay in the ordinary sense. It is a referral. Where the Registrar refers an application to the Financial Markets Authority under section 15B, the Authority must allow at least ten working days for submissions before directing a rejection, and a deregistration notice under section 18B runs at least twenty. Banking is the other variable, and the honest position is that no official source sets a standard for how long a New Zealand account takes to open for a non-resident-owned payments firm. We plan for it rather than promise it.
Run from our Oceania desk.

The company incorporated with a registered office and an address for service, and the section 10(d) director in place - resident in New Zealand, or resident in Australia and on the board of an Australian company under regulation 12.Incorporation, registered office, s 10(d) director.
Each service mapped to its paragraph of section 5, the application and the criminal history checks filed with the fee and the levy, and an approved dispute resolution scheme joined before the first retail client.Services mapped, application and checks filed.
Risk assessment first, then the written programme, the controls and a compliance officer who is an employee, with the supervisor identified as the Department of Internal Affairs or, under section 130, the Financial Markets Authority.Risk assessment, programme, supervisor identified.
Accounts opened with the business explained to the bank rather than around it, and, where client money is held, the trust account and records that sections 431ZA to 431ZH require.Accounts opened, trust account where needed.







Taxation of payment companies in New Zealand.
Company income tax at 28% and GST at 15%, with financial services exempt. That exemption sounds like relief and works out as a cost, because an exempt supplier recovers no input GST on what it buys.
Inland Revenue prints 28% for most companies, with 17.5% for Māori authorities. The rate on that page has not moved since 1 April 2024.17.5% for Māori authorities.
Interest, loans, bank fees, securities and exchanging currency are exempt supplies. The consequence to model early: an exempt supplier cannot recover input GST on its own costs.Financial services are exempt.
Inland Revenue splits the advice-type charges. Initial planning, monitoring, evaluation and replanning fees are taxable; implementation, administration and switching fees are exempt. Product pricing is mapped against that line before launch.Exempt supplies recover nothing.
Non-resident withholding tax is 30% on dividends where no double tax agreement applies, and 15% on interest and on royalties.Withholding without a treaty.
IR291, the payer's guide of March 2026, records that a fully imputed dividend to a non-resident investor with a non-portfolio interest - a voting interest of 10% or more - is not liable for non-resident withholding tax. Smaller holders get relief through the supplementary dividend and the foreign investor tax credit.Holders of 10% or more.
The safe-harbour threshold is 60% for New Zealand taxpayers owned or controlled by non-residents and 75% for New Zealand owned groups with certain offshore investments. The rules apply once non-residents acting together own half the company or more.75% for outbound groups.
*Figures as of 2026 per Inland Revenue, including IR291 of March 2026 and the thin-capitalisation page last updated 27 May 2026. Treaty and regime positions are assessed per structure.
Experienced lawyers and international consultants.
We provide end-to-end support, from company registration and the application file to regulatory interaction and compliance oversight - with an individualized approach to each client.
Builds the application itself: New Zealand company, AML/KYC policy pack, capital structure and tax registrations. His document sets are the reason reviews finish in months, not years.
First point of contact for international founders. Runs the whole setup remotely, across time zones and languages - from the first call to a live, registered business.
Active across our channels.
Launch your payment project in New Zealand with expert support.
Full-service assistance - from company formation to the FSPR registration, the AML/CFT programme, dispute resolution membership, banking and ongoing compliance.
Get a consultation →Is New Zealand the right fit for your project?
Our legal team will analyze your case at no cost and provide a written legal opinion: which jurisdiction, licence scope, or route fits your business.
The New Zealand payment registration, answered.
What licence does a payment business need in New Zealand?+
None, because none exists. A payments business registers on the Financial Service Providers Register under section 11 of the FSP Act 2008 for each service it provides, joins an approved dispute resolution scheme under section 48(1) and complies with the AML/CFT Act 2009 as a reporting entity. The Companies Office states the limit of that plainly: being registered as a financial service provider does not mean that you are licensed or regulated in New Zealand.
How much capital is required?+
None. No minimum capital, own funds, net tangible assets, bond, guarantee or insurance figure appears anywhere in the FSP Act 2008 or in the Financial Service Providers (Registration) Regulations 2020. Section 13 asks only that the applicant is not disqualified under section 14 and holds any licence another enactment requires. What stands in for capital is dispute resolution membership, anti-money-laundering supervision, directors' duties under the Companies Act 1993 and, where client money is held, the trust and segregation duties of sections 431V to 431ZJ of the FMC Act 2013.
What does registration cost?+
NZ$300 plus GST for the application, an FMA levy of NZ$600 plus GST on registration and NZ$11.30 plus GST for each criminal history check. Every year after that, NZ$75 plus GST for the annual confirmation plus the FMA levy for your class: NZ$660 plus GST for a Class 7 provider, NZ$3,600 plus GST for a regulated client money or property service, NZ$18,200 plus GST for a derivatives issuer.
How long does registration take?+
The Act sets no decision period, and none is published. Criminal history checks take between two and five working days. Where the Registrar refers an application to the Financial Markets Authority under section 15B, the Authority must give at least ten working days for submissions before it can direct a rejection. Plan on three to six months from first call, most of it spent on the company, the AML programme and the bank account rather than on the registration itself.
Can a company register in New Zealand and serve customers everywhere else?+
That is the plan the law was amended to stop, and it is the first thing we test. Sections 15A and 18A let the Financial Markets Authority block a registration, or direct that one be removed, where registration would create "a false or misleading appearance" about the extent to which the applicant "provides, or will provide, financial services in New Zealand", provides them "from a place of business in New Zealand", or "is, or will be, regulated by New Zealand law". The procedure is in sections 15B and 18B: at least ten working days of submissions before a rejection, at least twenty before deregistration, and an appeal to the High Court under section 42. A registration that exists to be quoted in marketing is the exact fact pattern those sections describe.
When does the model need an FMA licence instead?+
At four points. Selling forward or non-deliverable foreign exchange to retail customers makes the firm a derivatives issuer, and section 41 of the FMC Act 2013 requires a licence for a regulated offer. A redeemable wallet balance can answer section 8(1)(a), a right to be repaid money owing by a person, and section 8 contains no prepaid or stored-value exclusion, so the answer turns on whether a Schedule 1 exclusion reaches the product, which is settled case by case rather than read off the page. Regulated financial advice, as section 431D describes it, needs a financial advice provider licence. Holding client money needs no licence and still carries the duties of subpart 5B of Part 6.
Do I need a New Zealand resident director?+
One director must live in New Zealand, or live in an enforcement country and be a director of a body corporate incorporated there, under section 10(d) of the Companies Act 1993. Regulation 12 of the Companies Act 1993 Regulations 1994 prescribes a single enforcement country: Australia. Other directors face no residency rule, since the FSP Act tests disqualification under section 14 rather than residence. The company also needs a registered office and an address for service in New Zealand.
Is opening a New Zealand bank account difficult?+
Yes, and an official source says so. The Department of Internal Affairs wrote in August 2023 that many money remitters in New Zealand have experienced difficulties opening, or maintaining, bank accounts to enable them to transact their money remittance services. It also recorded that some remitters use accounts obtained or operated without telling the bank what the account is for, and said it does not endorse that practice. No official source sets a standard or a timeframe for account opening, so we sequence the work around it and plan for it rather than promise a date.
Does the Reserve Bank regulate a payments firm?+
In the ordinary case, no. A payments firm is not a registered bank and not a licensed deposit taker: the Deposit Takers Act 2023 draws its perimeter at the business of borrowing and lending money under section 5(1). Under the Financial Market Infrastructures Act 2021 the Minister may designate a systemically important payment system on the Reserve Bank's recommendation, which is discretionary rather than compulsory. What did change is access: the Reserve Bank widened Exchange Settlement Account System criteria in March 2025 and opened the final phase on 23 September 2025, with payment service providers named among the entities that may apply.
Why New Zealand rather than Singapore or the United Kingdom?+
Price at the front door. New Zealand asks no capital at all and NZ$300 plus GST to register, against initial capital of EUR 350,000 for a UK authorised e-money institution and base capital of S$100,000 to S$250,000 in Singapore, with a security deposit on top for a major payment institution. What you give up is the badge: the register is not a licence, and the Financial Markets Authority can strike off a registration that trades on the country's name. The United Kingdom answers within three months by statute and Singapore scales its licence tiers with transaction volume, so both are the better home for a firm that needs to say it is supervised. For a business with real New Zealand or Australian operations, this is the cheapest serious base of the three.
Which licence?+
None - FSPR registration under s 11.
Capital?+
None in the Act or the regulations.
Cost?+
NZ$300 + GST, plus a NZ$600 FMA levy.
How long?+
No statutory clock; 3-6 months realistic.
Offshore-only model?+
Sections 15A and 18A can block or strike it off.
When is a licence needed?+
Derivatives, a debt security, advice (FMC Act).
Resident director?+
One, in New Zealand or Australia.
Bank account?+
Hard, and the DIA says so. We plan for it.
Taxes?+
28%, GST 15% with financial services exempt.
vs Singapore / UK?+
Cheaper to enter; no licence to point at.
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