Singapore
A demanding, well-run regime under the Payment Services Act. Respected globally, and deliberately hard to enter.
Who regulates this
Monetary Authority of SingaporeMAS
Digital Payment Token services under the Payment Services Act 2019, as amended by the Payment Services (Amendment) Act.
Licences and permissions
Major Payment Institution — DPT service
Dealing in, or facilitating exchange of, digital payment tokens above the transaction thresholds.
The category most exchanges land in. Approval rates are low and diligence is deep.
Standard Payment Institution
The same services below prescribed monthly transaction thresholds.
A lighter tier, but the thresholds are restrictive for any real venue.
What it takes
Capital
S$250,000 base capital for a Major Payment Institution, plus a security deposit, and segregation and safeguarding obligations for customer assets.
Timeline
Twelve to eighteen months is the realistic expectation. MAS engages substantively and iterates on the file.
Substance
A Singapore-incorporated company, resident executive directors, a permanent office and a compliance function with real authority.
Where a software vendor sits
MAS regulates the service provider. Technology vendors sit outside the licensing perimeter but squarely inside MAS's outsourcing and technology risk-management guidelines, which are specific and prescriptive about what a licensed firm must be able to demonstrate about its providers.
What catches people out
Retail access is deliberately constrained — restrictions on credit-card funding, incentives and retail marketing are policy, not oversight, and they shape what a consumer-facing product can even look like.
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