NewPay IFSC Ltd, a payment solutions FinTech registered at GIFT City under the IFSCA framework, developed a cross-border remittance product designed to serve retail customers across India and the United Kingdom. Seeking

CS Professional · IFSCA - Regulations, Listing and Compliances · PYQS · June 2026
NewPay IFSC Ltd, a payment solutions FinTech registered at GIFT City under the IFSCA framework, developed a cross-border remittance product designed to serve retail customers across India and the United Kingdom. Seeking to pilot the product within the UK's regulatory perimeter, NewPay's Chief Executive, Brar, approached IFSCA requesting a formal referral to the Financial Conduct Authority (FCA) of the United Kingdom, relying on her understanding that a FinTech Bridge existed between IFSCA and the FCA. Simultaneously, a Singapore-based FinTech, PaySphere Pte Ltd., was referred to IFSCA by the Monetary Authority of Singapore (MAS) under an overseas regulatory referral mechanism, seeking GIFT City access for its digital lending solution. NewPay's legal team raised an internal query regarding whether the rights, obligations and testing conditions applicable to NewPay's outbound referral to the FCA would mirror those governing PaySphere's inbound referral from MAS or whether each engagement operated on independently negotiated terms. Analyse the legal basis governing NewPay's outbound referral to the FCA and PaySphere's inbound referral from MAS.

Answer & Explanation:

To support global collaboration and cross-border innovation, the IFSCA operates FinTech Bridges and Overseas Regulatory Referral Mechanisms. These frameworks help FinTech firms smoothly interact with foreign regulators when they wish to expand internationally or test cross-border financial solutions. A FinTech Bridge is a formal partnership between IFSCA and an overseas financial sector regulator. It allows FinTech firms in both jurisdictions to: Access to each other's regulatory ecosystems Share knowledge and best practices Explore opportunities for cross-border testing or expansion Receive regulatory support during international entry The Overseas Regulatory Referral Mechanism is a structured process through which IFSCA can refer an Indian/ IFSC-based FinTech to a foreign regulator or receive referrals from abroad for smoother regulatory engagement. Any applicant seeking to use these cross-border mechanisms will be governed strictly by the terms of the Memorandum of Understanding (MoU), or any collaboration, and Special arrangement that exists between IFSCA and the corresponding overseas Financial Sector Regulator(s). It means that each FinTech Bridge has its own rules, conditions, obligations, and benefits, depending on what was mutually agreed between the authorities. NewPay's legal team is correct in its suspicion: the rights and obligations of the two referrals will not mirror each other. Under the IFSCA framework, each FinTech Bridge is governed strictly by the independently negotiated terms of the specific MoU signed between IFSCA and the respective overseas regulator. Therefore, NewPay's outbound testing conditions in the UK will be dictated by the IFSCA-Financial Conduct Authority (FCA), UK arrangement, while PaySphere's inbound access to GIFT City will be governed by the IFSCA- Monetary Authority of Singapore (MAS) arrangement. There is no universal set of rules for FinTech Bridges; they are bespoke bilateral agreements.

Topics: IFSC Regulations

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