Singapore has one reputation for strict crypto licensing and another for enthusiastic tokenisation trials. Both rest on real instruments, but different ones. A general counsel or allocator needs to know which applies to a given activity, and whether it is law today, guidance, a proposal or a pilot. This post sorts the Monetary Authority of Singapore (MAS) material into those categories, as at 29 September 2026. It describes published rules and is not legal, tax or investment advice.

The base layer: the Payment Services Act

The Payment Services Act 2019 came into force on 28 January 2020. It licenses payment services by activity, and it brought digital payment token (DPT) services inside MAS's perimeter. A digital payment token is, in practice, a cryptocurrency, and MAS currently treats stablecoins as a subset of them.

What is licensed, and since when

The MAS release of 2 April 2024 announced that the Payment Services (Amendment) Act 2021 would take effect in stages from 4 April 2024. It widened the regulated DPT activities to cover custody, and the facilitation of token transmission and exchange even where the provider never comes into possession of the money or tokens. Firms already carrying on these activities had to notify MAS within 30 days and apply for a licence within six months if they wanted to continue on a temporary basis while MAS reviewed the application.

The same release said the amended Payment Services Regulations on safeguarding customer assets would take effect six months from 4 April 2024. They require customer assets to be segregated and placed in a trust account for customers' benefit, and MAS's own guidelines cite Regulation 18B on segregation. That requirement is a regulation, not a suggestion.

Consumer protection: where the law stops and the guidelines start

Most of the detail that reads like rules is in Guidelines PS-G03, issued on 2 April 2024 and revised on 19 September 2024 under section 101 of the Act. They describe themselves as general guidance that does not replace or override legislation, though MAS says the degree to which a provider observes their spirit is a consideration when supervising it.

Providers should keep at least 90% of customers' assets in cold wallets. They should not entice a retail customer to lend or stake assets, or carry out such a transaction for one. They should run a risk awareness assessment for individual retail customers, and should not extend credit, leverage or DPT derivatives to retail customers or accept their payments by Singapore-issued credit or charge card. The safeguarding chapters took effect on 4 October 2024 and the retail-access chapters on 19 June 2025.

Two points matter to an institution. First, "retail customer" is defined by exclusion: accredited investors who have opted in, institutional investors, other DPT providers and regulated foreign equivalents are outside it. Second, the retail lending and staking limit lives in the guidelines. The July 2023 MAS release announced it as a restriction and said guidelines would follow, and PS-G03 words it as "should not". Read it as a supervisory expectation unless your counsel finds a binding rule behind it.

Firms serving only overseas customers: the Financial Services and Markets Act

The Payment Services Act licenses services provided in Singapore. Firms based in Singapore that served only customers elsewhere were the gap the Financial Services and Markets Act 2022 (FSMA) closed. It added a licence for digital token service providers, and Part 9 came into force on 30 June 2025. That is law.

MAS's response to feedback of 30 May 2025 defines the target: individuals, partnerships or Singapore corporations operating from a place of business in Singapore, or formed or incorporated there, that provide digital token services outside Singapore. It set out what changed on the commencement date.

  • MAS said it would grant a licence only in "extremely limited circumstances", judging among other things whether the applicant has a business model that makes economic sense and valid reasons for not serving Singapore.
  • There was no transitional arrangement. A provider needing a licence had to suspend or cease that business by 30 June 2025, and contravening the licensing requirement is an offence carrying the penalties in section 137(6).
  • MAS committed to at least four weeks' notice of commencement, which respondents said was too short to prepare an application.

MAS's clarification of 6 June 2025 set out the scope. Providers offering only utility or governance tokens fall outside the licensing requirement. Providers serving customers in Singapore stay under the Payment Services Act, the Securities and Futures Act or the Financial Advisers Act. MAS said it "has set the bar high for licensing and will generally not issue a licence", and that it was aware of a very small number of affected providers.

Stablecoins: a framework announced in 2023 and still not law

MAS finalised its single-currency stablecoin framework on 15 August 2023. It covers stablecoins pegged to the Singapore dollar or a G10 currency and issued in Singapore. It has no statutory force yet: the legislation to give it effect is only now in draft.

What MAS settled in August 2023

The response document lists the requirements an issuer would meet to label its coin "MAS-regulated".

  • Reserves denominated in the peg currency and held as cash, cash equivalents or debt securities with up to three months' residual maturity, issued by the relevant government or central bank, or by governmental international organisations rated at least AA-.
  • Reserves at least equal to par value at all times, marked to market daily, held in segregated accounts on trust.
  • Monthly independent attestation, published on the issuer's website, and an annual audit.
  • A direct legal claim to redeem at par, honoured within five business days.
  • Base capital of the higher of S$1 million or 50% of annual operating expenses, plus liquid assets.
  • A ban on lending, staking and other non-issuance services in the issuing entity.

What the September 2026 draft changes

On 1 September 2026 MAS opened consultation P015-2026 on draft amendments to the Payment Services Act, closing on 16 October 2026. Everything below is a proposal. The paper says MAS will consult on the subsidiary legislation later.

  • A new "stablecoin issuance" licence class, and a bar on anyone without it holding themselves out as an issuer of a MAS-regulated stablecoin.
  • A prohibition on paying holders interest, return or any other benefit attributable to holding the coin.
  • Stress testing at least quarterly, and a question on whether issuers should be allowed to use interest earned on reserves to fund their business.
  • A reversal on multi-jurisdictional issuance. The 2023 response ruled it out at the onset; the draft would let a Singapore issuer and foreign co-issuers share a coin through case-by-case exemptions, provided the foreign regime is substantively equivalent and the reserves meet the stricter of the two standards.
  • Recognition of a limited number of foreign-regulated stablecoins, case by case, with a status MAS wants kept clearly distinct from "MAS-regulated".
  • Powers to designate a stablecoin as systemic and, if its issuer fails MAS's requirements, to restrict its circulation in Singapore, including by directing licensed providers to delist it.
  • Banks issuing a MAS-regulated stablecoin through a separate non-bank entity. Banks may still issue tokenised deposits, with MAS guidance to follow.

Who has been recognised

No one. The paper describes the issuance licence as a new class and the recognition route as a proposal, and it expects only a limited number of stablecoins to be authorised or recognised once the regime is in place. No MAS list of licensed or recognised stablecoin issuers was found. Until the amended Act commences, MAS treats stablecoins as digital payment tokens; under the draft, an entity in Singapore issuing a stablecoin that is not MAS-regulated would need a major payment institution licence as a DPT service provider. A coin described as a "MAS-regulated stablecoin" today has no such legal status, and MAS said in 2023 that anyone misrepresenting a token this way may be subject to penalties. For other jurisdictions sorted by the same statuses, see what regulators actually permitted. On why the interest ban matters commercially, see how stablecoin issuers make money.

Tokenisation: Project Guardian and what sits around it

Project Guardian is a pilot programme, not a regime. MAS launched it on 31 May 2022, with DBS, J.P. Morgan and Marketnode in the first pilot. That pilot went live on 2 November 2022: DBS, J.P. Morgan and SBI Digital Asset Holdings conducted a live cross-currency trade in tokenised Singapore dollar and yen deposits, and a simulated exercise in tokenised Singapore and Japanese government bonds, through permissioned liquidity pools. On 27 June 2024 MAS said it had worked with 24 financial institutions, set out workstreams in fixed income, foreign exchange, and asset and wealth management, and announced GFMA, ICMA and ISDA joining.

The published outputs are frameworks written by industry groups. On 4 November 2024 MAS announced the Guardian Fixed Income Framework and the Guardian Funds Framework, and said more than 40 institutions in seven jurisdictions had run over 15 trials in six currencies. The fixed income framework was updated in November 2025 with a delivery-versus-payment guide and lessons on custody, covered in our piece on permissioned DeFi.

The fixed income framework's disclaimer says the content is not regulatory, financial or legal advice, that examples are for illustration, and that the views are those of the lead contributors and not a consensus. An institution that follows a Guardian framework is following industry practice that MAS has hosted, not complying with a rule.

The binding layer for tokenised securities is the existing one. On 14 November 2025 MAS published a Guide on the Tokenisation of Capital Markets Products, explaining how securities law applies to issuing, offering and facilitating tokenised products. The guide says it does not replace or override legislation, and it applies the principle of "same activity, same risk, same regulatory outcome": a tokenised bond or fund unit is regulated by its economic substance, as the product it represents. The pilots test infrastructure; the licensing and offering questions follow the underlying instrument. For the operating side of that, see from pilot to production.

Two settlement initiatives are announced and not yet products. MAS launched BLOOM on 16 October 2025 to enable settlement in tokenised bank liabilities and well-regulated stablecoins, and invited banks, financial institutions and settlement network operators to run trials. In a speech on 13 November 2025, MAS said it would trial issuing tokenised MAS Bills to primary dealers, settled with central bank digital currency, and release more details in 2026. No published details were found as at 29 September 2026.

What is unresolved

  • Commencement of the stablecoin regime. The consultation closes on 16 October 2026 and the subsidiary legislation is still to be consulted on, so no start date exists.
  • Foreign equivalence. The conditions for recognising a foreign-regulated stablecoin will be set out in subsidiary legislation, and MAS is still asking what should make a foreign regime substantively equivalent, so the practical route for a non-Singapore issuer is unknown.
  • Retail warnings on other coins. MAS is only "considering" enhanced disclosures, risk warnings and a bar on marketing non-MAS-regulated coins to retail customers as "stablecoins".
  • Tokenised deposits. Banks may issue them, and guidance is promised "in due course".
  • Whether any FSMA licence is ever granted. MAS's own wording suggests few or none, and no published count was found.

The four statuses side by side

  • In force: the Payment Services Act 2019 and its 2021 amendments (in stages from 4 April 2024), the safeguarding regulations (from 4 October 2024), and FSMA Part 9 (30 June 2025).
  • Guidance: PS-G03 and the Guide on the Tokenisation of Capital Markets Products.
  • Consulted on: the stablecoin amendments (P015-2026, closing 16 October 2026), which would give the 2023 framework legal effect.
  • Pilot, industry framework or announcement: Project Guardian and its frameworks, BLOOM, and the tokenised MAS Bills trial announced in a speech.