21/09/2026
On Friday 18 September, the National Assembly of St Kitts and Nevis passed the Payment Systems and Services Bill, 2026, a new legal framework for digital payments. Similar legislation has already been passed in Antigua and Barbuda, Dominica, Grenada and Saint Lucia, based on a regional framework developed by the Eastern Caribbean Central Bank (ECCB) with the governments of the Eastern Caribbean Currency Union.
A payment service is a way of moving money other than handing over cash: paying by card at a shop, withdrawing cash from an ATM, sending money by bank transfer or through a phone app, or keeping money in a mobile wallet to pay others. Electronic money is money stored on a phone or card that can be used to pay people and businesses other than the company that issued it. The payment system is the set of rules, institutions and technology that carries these payments from one account to another and makes sure they are completed.
The existing payment framework was developed before mobile wallets, electronic money and online bank transfers were in everyday use. The new framework provides for companies that are not banks or credit unions and that provide a payment service, such as a mobile wallet or a money transfer service, to be licensed by the ECCB. Under the model framework, banks and credit unions do not need a separate licence, but they must follow the same rules when they provide payment services.
A licence matters to customers because it means the provider is supervised by the ECCB. Under the model legislation, a licensed provider must display its licence at its place of business and on its website, and the ECCB must publish a register of licensed providers on its own website. Operating a payment service without a licence is an offence.
The framework sets out protections for customers. Under the model legislation published by the ECCB, a fee must be displayed before it is charged, and a fee that has not been displayed cannot be charged. The terms and conditions must be given before a customer signs up for the service. Any change to those terms requires 21 days’ notice in writing, unless the change is needed for security. Money kept in an electronic wallet must be held separately from the company’s own money, and the customer is entitled to withdraw it at full value on request. These protections cover individuals and businesses that use payment services.
There is also a set route for complaints. A complaint is made in writing to the provider, which must reply within seven days. If the reply does not resolve the matter, or no reply is received, the complaint can be taken to the ECCB within two months. The ECCB must respond within 21 days and can direct the provider to put the matter right or pay compensation. A complaint to the ECCB should explain what went wrong and what is being asked for, and include copies of the original complaint and of the provider’s reply, if one was received.
The protections apply once the legislation comes into force in each territory. Under the model legislation, providers already operating then have twelve months to comply.
This is separate from the ECCB’s Office of Financial Conduct, which opens at the end of September and begins accepting complaints about licensed financial institutions on 15 October.
ECAMC operates across the same eight territories of the currency union. Confidence in how money is paid, received and protected is part of the financial stability its work supports.
View more details on the ECCB’s website: https://www.eccb-centralbank.org/payment-system-and-services-bill
