Same Region. Different Rules Across APAC.

Part 4 of an 8-part series on beneficiary needs and preferences, region by region: APAC

India's UPI handles roughly 49% of the world's real-time payment volume. A few thousand miles away, China requires banks to verify and report personal transfers abroad over roughly $1,000. Same region. Radically different rules.

This is Part 4 of our Regional Payments Series. Every region so far has shown some gap between what's possible and what's preferred — but APAC has the widest gap of any region in this series, because it isn't really one payments landscape at all. It's dozens, sitting side by side, with almost nothing standardizing them.

What's Required Across APAC

Unlike Europe, there's no APAC equivalent of PSD2 or SEPA — no shared directive, no common instant-payment mandate, no regional non-discrimination rule. Each market regulates independently, and the practical requirements vary enormously.

• Capital controls and FX approval: China tightened its foreign exchange rules again on January 1, 2026. Banks handling personal transfers of more than roughly RMB 5,000 (about $1,000) sent overseas must now verify and report them, and retain records for up to 10 years — a level of scrutiny that applies regardless of how digitized the domestic side of the transaction is. China is simultaneously one of the most cashless societies on earth and one of the hardest markets to move money out of.

• Local licensing required: China, India, and Thailand all gate foreign payment providers behind a local license, and none of the gates are optional. In China, any payment service provider — domestic or foreign — offering cross-border payment services to Chinese users needs a Payment Services Permit from the People's Bank of China, per the regulation that took effect in May 2024. Foreign PSPs can't operate independently; in practice, they route through a licensed local partner. (Domestically, Alipay and WeChat Pay handle over 90% of China's mobile payments, with China UnionPay as the dominant card network — but these are acceptance tools for collecting payments from Chinese consumers, not mechanisms a company would use to pay out to a beneficiary.) In India, any non-bank entity issuing prepaid cards must be a company incorporated in India, authorized by the RBI under the Payment and Settlement Systems Act. Even cross-border-funded cards require the issuer to be a registered "Indian Agent" under RBI's Money Transfer Service Scheme, working with a foreign correspondent bank — a foreign company can't simply mail a card directly to an Indian beneficiary. Thailand tells the same story with real consequences attached: under the Payment Systems Act 2018, the Bank of Thailand required e-money services to obtain a local e-money license. PayPal missed the original May 2020 deadline, and starting March 7, 2021, Thai users lost the ability to send, receive, or hold a balance in PayPal at all. PayPal didn't fully resolve it until 2022, relaunching as a BOT-licensed local entity ("PayPal Thailand") with restructured terms — Thai-baht-only domestic transactions, no more transfers to foreign bank accounts, and mandatory VAT collection. Vietnam, Indonesia, and the Philippines run comparable e-money licensing regimes; this is the standard pattern across Southeast Asia, not a one-off.

• No unified framework: India's UPI operates under the Reserve Bank of India and the National Payments Corporation of India. China's cross-border renminbi flows run through the State Administration of Foreign Exchange and the People's Bank of China. Thailand's PromptPay answers to the Bank of Thailand. There is no single rulebook — a company operating across even three or four APAC markets is really operating under three or four separate regulatory regimes.

• Local ID requirements: every real-time rail in the region ties to a local identifier. UPI requires a linked Indian bank account and mobile number. PromptPay uses a Thai national ID or mobile number. Indonesia's BI-FAST, the Philippines' InstaPay, and Vietnam's VietQR each have their own account and identity requirements. There's no portable format that works across all of them.

What's Actually Preferred Across APAC

This is where APAC pulls ahead of every other region in this series. Real-time payment infrastructure here isn't just advanced — in India's case, it's the largest in the world by a wide margin.

• Real-time rails dominate: UPI alone carries close to half of all real-time payment transaction volume globally, more than triple Brazil's Pix by share, according to the IMF and ACI Worldwide. Thailand's PromptPay has more than 90 million registrations, in a country of roughly 72 million people — not a data error. PromptPay registration is per identifier-to-account link, not per person: a single bank account can carry both a citizen ID and up to three linked mobile numbers, businesses register separately using a corporate tax ID, and foreign residents can register using a Thai tax ID. One industry analysis of Thailand's rollout put it plainly: the country reached full adult coverage with registrations still exceeding population, attributing the gap to "some entities and multiple registrations." PromptPay also processes over 74 million transactions a day.

• Regional interoperability: these systems are increasingly linked to each other rather than staying siloed. ASEAN's Regional Payment Connectivity initiative had 29 active bilateral cross-border linkages as of December 2025, connecting systems like Singapore's PayNow, Thailand's PromptPay, Malaysia's DuitNow, Indonesia's QRIS, and the Philippines' QR Ph. A UPI-PayNow link ties India directly into that Southeast Asian network for lower-cost remittances. A multilateral hub-and-spoke model, Project Nexus, is now in development through the BIS Innovation Hub to replace the current patchwork of bilateral links entirely.

• Provider landscape: Airwallex, founded in Australia with deep roots in the region, along with Wise and Payoneer, cover most of APAC reasonably well — Payoneer in particular has a large, established base among Indian and Southeast Asian freelancers. China is the exception worth naming specifically: PingPong has built its entire business around it, holding more than 60 payment licenses globally including the PBOC permit itself, and specializing in exactly this corridor — collecting marketplace revenue in USD, EUR, or GBP and paying it out directly in RMB to Chinese accounts, for both e-commerce sellers and B2B suppliers.

The Takeaway

Every region in this series has shown some daylight between what's possible and what's preferred. APAC has the widest gap by far, and it runs in both directions at once: the world's single largest instant-payment system sits in the same region as some of its tightest capital controls, with no shared regulatory framework connecting any of it. A strategy built for "APAC" as a single market will be wrong for most of the countries in it.

Are you treating APAC as one market, or building for how different its rules actually are?