Notice – No.41 – Regulatory Framework for Dedicated Electronic Money Issuers

For boards and compliance teams, the notice shifts focus from general licensing compliance to demonstrable operational resilience, governance, incident response, continuity planning and oversight of critical service providers. Firms should first assess whether their activities, volumes or interconnectedness could bring them within scope, and document that assessment. Any entity expecting designation should prepare for deeper BoG engagement, enhanced reporting, recovery and exit planning, and board-level accountability for critical payment services.

Non-designated PSPs and e-money issuers may still be affected through dependency chains, outsourcing arrangements and market infrastructure access. Action items: map critical services and third-party dependencies; review resilience and cyber controls; test incident and continuity plans; confirm regulatory reporting and notification protocols; align governance and risk appetite; and engage legal/compliance on designation criteria. Because the excerpt does not list designations or deadlines, firms should monitor follow-up BoG communications and seek clarity on timelines.

The framework may raise near-term compliance costs but should reward well-governed providers through greater market confidence and clearer supervisory expectations.