AG

Licensing, Authorisation & Market Access

Antigua and Barbuda's payments-licensing framework has been formally re-architected through the Payment Systems and Services Act, 2025, No. 13 of 2025, which repeals the Payment System Act, 2007, No. 15 of 2007, and establishes a new licensing basis for payment service providers and payment-system operators under the Central Bank. This is a confirmed-tier, directly sourced statutory development, drawn from the Act's own repeal clause.

The critical operative detail is the Act's commencement mechanism: section 1(2) provides that the Act comes into operation on a date appointed by the Minister by Notice published in the Gazette. No such commencement notice has been located as of this cycle, meaning the Act's substantive licensing provisions, though enacted, have not yet taken legal effect. In the interim, entities already carrying on payment-system business in Antigua and Barbuda continue to operate under the 2007 Act's licensing regime, since a repeal that is itself subject to a date-appointed commencement clause does not displace the prior regime until that date arrives. This produces a live divergence between the published statute book, which now shows the 2025 Act as enacted law, and the operative licensing regime actually governing market participants today, which remains the 2007 framework.

Once commencement occurs, the Act provides a 12-month transitional compliance window for existing businesses, during which payment service providers and system operators already active under the legacy regime must come into compliance with the new Central Bank licensing framework. This transitional design is a standard feature of repeal-and-replace payments legislation and signals that the drafters anticipated the need for continuity of service during the changeover rather than an abrupt licensing cliff-edge.

The bank-versus-non-bank distinction matters here only to the extent that the new Act is understood to apply to both categories of payment-services participant; no differential treatment between bank-operated and non-bank payment service providers under the new licensing regime was identified from the sourced provisions, so the Act should be read as establishing a common licensing gateway administered by the Central Bank for both categories, pending commencement.

Outlook

The single most important development to track for Antigua and Barbuda's payments-licensing environment is the Minister's Gazette commencement notice. Until it is published, market participants face continued application of the 2007 licensing framework notwithstanding the 2025 Act's enactment, and any assessment of current regulatory status for a payment service provider or payment-system operator in Antigua and Barbuda must account for this gap between enactment and legal effect. Once commencement occurs, the 12-month transitional window will itself become a tracked milestone, as existing businesses work through re-licensing under the Central Bank's new framework.

Conduct, Safeguarding & Financial Promotions

Antigua and Barbuda's conduct-of-business landscape for the financial sector has been strengthened through the Banking (Amendment) Act 2025, No. 14 of 2025, which inserts a market-conduct-supervision regime applicable to financial services and financial products offered by a licensed financial institution. The provision carries a notable disapplication clause: it applies notwithstanding anything contained in the general Consumer Protection Act 2025, meaning the Banking Act's sector-specific conduct regime takes precedence over the general consumer-protection statute for licensed financial institutions, rather than operating alongside it as a supplementary layer. This is confirmed-tier, directly sourced from the Act's own text.

The practical effect of this disapplication clause is to create two parallel conduct-and-consumer-protection tracks in Antigua and Barbuda: a general track under the Consumer Protection Act 2025 for consumers of goods and services broadly, and a sector-specific track under the Banking Act's new Part VIIA for consumers of financial services and products from licensed financial institutions. For payment service providers that are also licensed financial institutions, this means conduct obligations will likely be administered under the Banking Act's framework rather than the general consumer-protection statute, though the precise scope of which payment-sector entities fall within the "licensed financial institution" definition for this purpose was not separately confirmed this cycle.

This conduct-supervision development sits alongside, but is analytically distinct from, the Central Bank's new information-gathering powers under the same Part VIIA, which allow it to request books, records, video footage and other documents from licensed financial institutions. Together, these provisions give the Central Bank both the substantive conduct standard to enforce and the investigatory tools to enforce it, a pairing that is structurally significant for how market-conduct supervision will actually operate in practice once exercised.

No separate financial-promotions-specific rule distinct from the general market-conduct provisions was identified this cycle for Antigua and Barbuda's payments sector.

Outlook

The disapplication of the general Consumer Protection Act 2025 in favour of the Banking Act's sector-specific regime is now in force for licensed financial institutions, and the degree to which this produces visibly different conduct outcomes, for example in complaint-handling, disclosure, or fee-transparency practice, for payments customers relative to the general consumer-protection track is the item to watch in coming cycles. Clarifying exactly which categories of payment-services participants fall within the Banking Act's "licensed financial institution" definition, as distinct from entities that may instead or additionally be licensed under the still-uncommenced Payment Systems and Services Act 2025, would sharpen this picture considerably once available.

Stablecoins & Digital Money

The most significant digital-money development touching Antigua and Barbuda this cycle originates at the regional, currency-union level rather than from domestic legislation. The Eastern Caribbean Central Bank's Monetary Council, at its 112th meeting on 13 February 2026, suspended the DCash 2.0 project, the successor to the original DCash central-bank-digital-currency pilot that had itself ended in January 2024. In place of continuing the DCash successor programme, the Monetary Council is now prioritising development of a regional Fast Payment System and participation in the CARICOM Payments and Settlement System, CAPSS, integration effort. This is a probable-confidence development, corroborated across two secondary regional sources, though no primary ECCB communique text was directly retrieved this cycle.

As a member of the Eastern Caribbean Currency Union, Antigua and Barbuda is directly affected by this region-wide strategic reset, even though the decision itself was taken at the currency-union level rather than by any Antigua-and-Barbuda-specific authority. The practical significance is a shift in digital-payments-infrastructure strategy away from a proprietary CBDC-wallet model, which DCash and its planned successor represented, and toward upgraded interoperability between existing bank-operated payment rails across the currency union and the wider CARICOM region. This is best read as a structural reset in regional digital-payments strategy rather than an Antigua-and-Barbuda-specific regulatory event, since no AG-specific stablecoin or digital-money legislation or regulatory action was identified this cycle.

No domestic Antigua and Barbuda stablecoin-specific statute, reserve-asset requirement, or redemption-rights framework was identified this cycle; digital-money regulatory development affecting the jurisdiction currently flows through this regional ECCB channel rather than through standalone domestic legislation.

Outlook

The ECCB's pivot from DCash 2.0 toward a regional Fast Payment System and CAPSS participation is a multi-year undertaking with a currently uncertain completion horizon; its practical effect on Antigua and Barbuda's payments landscape will depend on how quickly the Fast Payment System and CAPSS integration actually deliver improved bank-rail interoperability relative to the proprietary CBDC-wallet approach they are replacing. This is a development to track at the regional ECCB level going forward, since further Antigua-and-Barbuda-specific digital-money developments are more likely to arrive as downstream implementation of this regional strategy than as independent domestic initiatives.

Consumer Protection & APP Fraud

Consumer protection for financial-services and payments customers in Antigua and Barbuda has been reshaped this cycle by the Banking (Amendment) Act 2025's market-conduct-supervision provisions, which apply to financial services and financial products offered by a licensed financial institution notwithstanding anything contained in the general Consumer Protection Act 2025. This disapplication clause is confirmed-tier and directly sourced from the Act's own text, and it establishes that, for licensed financial institutions, the sector-specific Banking Act regime governs rather than the general consumer-protection statute.

The consequence for payments customers specifically is that where a payment service provider is also a licensed financial institution, its conduct toward consumers, including fee transparency, disclosure, and complaint-handling, falls to be assessed under the Banking Act's Part VIIA framework rather than the general Consumer Protection Act 2025. This is a structurally significant distinction because it means two different consumer-protection standards could, in principle, apply across Antigua and Barbuda's broader economy: the general standard for most consumer transactions, and the sector-specific Banking Act standard for financial-services consumers. No APP-fraud-specific (authorised-push-payment fraud) provision distinct from the general market-conduct framework was identified this cycle for Antigua and Barbuda.

This development should be read alongside the Central Bank's parallel new information-gathering powers under the same Part VIIA, which allow it to request records and documents from licensed institutions; these powers give the Central Bank a practical mechanism for investigating potential consumer-conduct breaches once the sector-specific standard is in place, even though no specific enforcement action under the new provisions was identified this cycle.

Outlook

The practical operation of the Banking Act's sector-specific consumer-protection carve-out, relative to the general Consumer Protection Act 2025, is the item to watch for Antigua and Barbuda's payments customers going forward. Whether the Central Bank begins to exercise its new information-gathering powers specifically in relation to consumer-conduct matters, as distinct from prudential or market-conduct matters more broadly, would be a significant signal of how actively this new consumer-protection track is being supervised in practice.

AML/CFT & Financial Crime

This module's content is sourced from financial-crime-adjacent monitoring and is reported here for completeness within the payments spine rather than as independent analysis: the intelligence is attributed to that monitoring feed and readers are directed there for the primary treatment. The substance of the signal is that Antigua and Barbuda's Parliament has been presented with the Automatic Exchange of Financial Account Information (Amendment) Bill 2026, which would extend the jurisdiction's Common Reporting Standard reporting scope to include e-money products and central bank digital currencies. Reporting places this within the House on 28 September 2026 for second and third readings, with the Bill reported to have reached the Senate around 12 October 2026, ahead of a compliance evaluation described as due in 2027.

From a payments-industry perspective, the material point is that e-money issuers and operators handling digital-currency-adjacent products in or from Antigua and Barbuda could become newly subject to automatic-exchange account-reporting duties if the Bill is enacted in its current reported form. No primary legislative text, gazette notice, or confirmation of Senate passage has been retrieved, so the scope, final wording and commencement date of any such duty cannot yet be stated with confidence, and the development is accordingly treated as probable rather than confirmed.

Outlook

The item to track is whether the Bill is enacted and gazetted, and what commencement date is attached; that would convert a probable, reported development into a confirmed compliance timeline for in-scope payments and e-money institutions. Until then, this remains a flagged development rather than a settled new obligation.