Singapore Compliance Report

Generated 2026-10-28

Comprehensive Framework

Regulatory Overview

Regulatory Status: Dedicated crypto/VA legislation, licensing regime, active enforcement
Key Regulator(s): Accounting and Corporate Regulatory Authority, Monetary Authority of Singapore
Risk Level: low
Primary Legislation: An applicant for a Payment Services Act licence must be registered with the Acco, Act 2 of 2019, The Securities and Futures Act 2001 governs digital tokens that are capital mark, The Payment Services Act 2019 is the main Singapore statute for cryptocurrency s, The Financial Advisers Act 2001 applies to a person giving financial advice in S, MAS requires a Payment Services Act licence applicant to show that the applicant, Under the Payment Services Act 2019, a standard payment institution must have mi, Section 13 of the Payment Services Act 2019 sets out the exemptions from the lic, A person carrying on a regulated activity under the Securities and Futures Act i, Payment Services Act 2019 s.6(5, A Payment Services Act licence applicant must have a permanent place of business, Under MAS Guidelines PS-G01 paras 5.4 and 5.5, Payment Services Act licensees mu, The claim that the Ministry of Law oversees AML/CFT for entities not licensed by, Part 9 of the Financial Services and Markets Act 2022 (No. 18 of 2022) licenses
Travel Rule: Adopted — Threshold: Implemented
Tax Reporting: No capital gains tax; income tax if trading is a business; GST does not apply to DPT-for-fiat exchange. Under IRAS's e-Tax Guide on digital tokens (30 January 2026), a gain on disposal of payment tokens is taxable income when the disposal is revenue in nature under the badges of trade, for example when the taxpayer is a trader in payment tokens (para 5.7, Annex A); a company that mines is regarded as carrying on a business of mining and is taxed on disposal of the mined tokens.. IRAS weighs the intention at the point of purchase of a payment token, through the badges of trade, to decide whether a later disposal is trading and the gain revenue in nature; for a trader in payment tokens, IRAS accepts first-in-first-out or weighted average cost, in line with FRS 2 Inventories, but not last-in-first-out (e-Tax Guide, 30 January 2026, para 5.7 and Annex A).. IRAS treats the use of payment tokens to pay for goods or services as barter trade: a business that receives payment tokens is taxed on the value of the goods or services it provided, and where the contract fixes a number of tokens rather than a fiat amount, the taxable income is the value of those tokens when the income accrues (e-Tax Guide, 30 January 2026, paras 5.1–5.2, Annex A).. Wages paid to an employee in payment tokens are taxable employment income, measured on the value of the employment services performed when the income accrues; where the tokens are subject to a moratorium, they are taxable when the moratorium is lifted (IRAS e-Tax Guide, 30 January 2026, Annex A, scenario B).

Key Facts

aml Monetary Authority of Singapore (MAS): Oversees financial services, including digital assets, under the Virtual Financial Assets Act (VFAA) 2020. Website: https://www.mas.gov.sg Singapore's national AML/CFT effort is led by the AML/CFT Steering Committee, comprising the Permanent Secretary of the Ministry of Home Affairs, the Second Permanent Secretary of the Ministry of Finance and the Managing Director of MAS. Virtual Financial Assets Act (VFAA) 2020: Provides the legal framework for regulating VASPs. Section 3 defines a VASP, and Section 5 mandates registration for activities like exchange, token issuance, or custodial services. Money Laundering Prevention Act (MLPA): Enforces AML obligations across financial sectors, including digital assets under Sections 2–4. Transactions exceeding SGD 10 million annually, or Cross-border transactions involving foreign currencies or jurisdictions. Submit an online registration application through MAS’s portal. Provide detailed documentation: business plan, risk management framework, internal controls, and compliance policies.
general On 27 June 2025 MAS imposed composition penalties totalling S$960,000 on five Major Payment Institutions licensed for cross-border money transfer, for breaches of AML/CFT Notice PSN01. On 4 July 2025 MAS imposed composition penalties totalling S$27.45 million on nine financial institutions (six banks, two capital markets services licensees and a licensed trust company) for AML/CFT breaches linked to the August 2023 money laundering case. MAS's fifth Enforcement Report, covering 1 July 2023 to 31 December 2024, records 163 cases opened across all sectors, including 19 for carrying on regulated activities without a licence and 16 for money laundering-related control breaches; it describes pursuing manipulative conduct in the securities markets as one of MAS's evergreen enforcement priorities. MAS Notice PSN02 (Amendment) dated 30 June 2025 took effect on 1 July 2025, amending the AML/CFT notice for digital payment token service providers, which was reissued on 2 April 2024 with effect from 4 April 2024 and covers risk assessment, customer due diligence, wire transfers, record keeping and suspicious transaction reporting. Under MAS's Guide to Digital Token Offerings (last updated 26 May 2020), offers or issues of digital tokens are regulated under the Securities and Futures Act where the tokens are capital markets products, which include securities, units in a collective investment scheme, derivatives contracts and spot foreign exchange contracts for leveraged foreign exchange trading (para 2.1). CMS licensing is required for activities like dealing in securities, including security tokens. MAS operates the FinTech Regulatory Sandbox, which lets financial institutions and FinTech firms test innovative financial products or services in a live environment for a defined period with specific MAS legal and regulatory requirements relaxed; it is offered as Sandbox, Sandbox Express and Sandbox Plus and applies to financial services generally rather than to digital assets specifically. Digital Payment Token (DPT) Services Licensing Under the Payment Services Act 2019, a digital payment token service covers buying or selling digital payment tokens, providing a platform for persons to exchange them, transmitting or arranging their transmission, providing custodian wallet services for them, and actively facilitating their buying or selling without possessing monies or tokens.
licensing MAS licenses payment service providers, including DPT service providers, under the Payment Services Act 2019 (standard payment institution, major payment institution and money-changing licences), imposes AML/CFT requirements on DPT licensees through Notice PSN02, and requires DPT licensees to comply with Notice FSM-N13 on technology risk management from 6 November 2024. An applicant for a Payment Services Act licence must be registered with the Accounting and Corporate Regulatory Authority (ACRA) and meet MAS governance and ownership requirements in Appendix 1 of MAS Guidelines PS-G01 (para 3.1.1). The Payment Services Act 2019 (Act 2 of 2019) licenses digital payment token services through standard and major payment institution licences; it commenced on 28 January 2020, and Act 1 of 2021 widened its DPT scope with effect from 4 April 2024. The Securities and Futures Act 2001 governs digital tokens that are capital markets products, and a person carrying on a regulated activity in such tokens must hold a capital markets services licence granted under section 86 unless exempt. MAS Notice PSN02, issued 2 April 2024 under section 16 of the Financial Services and Markets Act 2022 and in force from 4 April 2024, sets the AML/CFT requirements for Payment Services Act licensees providing a digital payment token service; its latest amendment, dated 30 June 2025, took effect on 1 July 2025. MAS published its Technology Risk Management Guidelines (now listed as Guidelines on Risk Management Practices – Technology Risk) on 18 January 2021; they set non-binding technology risk principles for financial institutions, including payment institutions, covering technology risk governance, IT resilience, data and infrastructure security and cyber security operations. Crypto service providers in Singapore are licensed under the Payment Services Act 2019; as of 14 October 2026 the MAS directory lists 38 major payment institutions for DPT services and no standard payment institutions. Base capital is S$250,000 for an MPI and S$100,000 for an SPI, which is capped at S$3 million monthly for one service or S$6 million for two or more. Providing custodial services for digital payment tokens became a regulated DPT service under the Payment Services Act from 4 April 2024; regulations requiring DPT service providers to segregate customer assets in a trust account took effect six months later. All 38 DPT licensees in the MAS Financial Institutions Directory hold major payment institution licences, which require S$100,000 or S$200,000 security.
securities Under s.2(1) of the Securities and Futures Act 2001, capital markets products are securities, units in a collective investment scheme, derivatives contracts, spot FX contracts for leveraged FX trading and other products MAS prescribes; a digital token in any of these classes is regulated under the SFA. The Securities and Futures Act 2001 (Act 42 of 2001) regulates Singapore capital markets; its current consolidated text is the 2020 Revised Edition, in operation from 31 December 2021, and it applies to digital tokens that are capital markets products. Monetary Authority of Singapore (MAS): Responsible for overseeing financial services, including digital asset securities. Website: https://www.mas.gov.sg Dealing in securities, collective investment schemes, exchange-traded derivatives contracts, over-the-counter derivatives contracts. Advising on investment products including collective investment schemes and securities. Applications for a capital markets services licence are made on Form 1 and must be submitted online through MAS's eLicensing system; the Financial Institutions Directory is a public register of licensed institutions, not an application portal. In assessing a capital markets services licence application, MAS considers the applicant's business model, plans and projections and their risks, and the strength of its internal risk management and compliance systems. MAS expects to take up to six months to review a complete application for a capital markets services licence from an applicant meeting all admission criteria; incomplete or complex applications can take longer.
stablecoin Stablecoins outside the MAS single-currency stablecoin framework are not prohibited and remain under the digital payment token regime of the Payment Services Act 2019; the 1 Sep 2026 consultation proposes amending PS Act s.2(1) to state that stablecoins fall within digital payment tokens. Single-currency stablecoins pegged to the Singapore dollar or a G10 currency and issued in Singapore can be labelled "MAS-regulated stablecoins" if their issuer meets the 2023 framework. The licence, first planned as an MPI licence, is now a proposed "stablecoin issuance" class (Sep 2026). The framework is MAS policy and is not yet law: the Payment Services Act 2019 amendments to implement it were put to consultation on 1 Sep 2026 (comments closed 16 Oct 2026). Stablecoins outside the MAS single-currency framework (pegged to other currencies or assets, or issued outside Singapore) are not prohibited and remain under the DPT regime; a token that is a capital markets product falls under the SFA. MAS proposed in 2026 to recognise some foreign-issued stablecoins. Under the MAS single-currency stablecoin framework finalised on 15 August 2023, reserve assets must equal at least par value of stablecoins in circulation at all times, valued daily, in the peg currency, as cash, cash equivalents or debt securities of up to three months' residual maturity. The framework is MAS policy and is not yet law: the Payment Services Act 2019 amendments to implement it were put to consultation on 1 Sep 2026 (comments closed 16 Oct 2026). Under the MAS single-currency stablecoin framework, reserves must be independently attested monthly, published online and filed with MAS, and audited annually; custodians are MAS-licensed or A- rated overseas custodians with an MAS-regulated Singapore branch. The framework is MAS policy and is not yet law: the Payment Services Act 2019 amendments to implement it were put to consultation on 1 Sep 2026 (comments closed 16 Oct 2026). MAS's 1 Sep 2026 consultation proposes a new "stablecoin issuance" licence class under the Payment Services Act 2019 for issuers of MAS-regulated stablecoins, replacing the 2023 plan to licence them as Major Payment Institutions; Singapore issuers of other stablecoins would need an MPI licence. Issuers of MAS-regulated stablecoins must hold base capital of the higher of S$1 million or 50% of annual operating expenses, and liquid assets worth the higher of 50% of annual operating expenses or their assessed recovery or wind-down cost. The framework is MAS policy and is not yet law: the Payment Services Act 2019 amendments to implement it were put to consultation on 1 Sep 2026 (comments closed 16 Oct 2026). Issuers of MAS-regulated stablecoins may not lend, stake, deal in other DPTs or hold stakes in other entities. The 2026 consultation proposes barring other regulated activities except DPT services incidental to their own coin. The framework covers only stablecoins issued in Singapore. The framework is MAS policy and is not yet law: the Payment Services Act 2019 amendments to implement it were put to consultation on 1 Sep 2026 (comments closed 16 Oct 2026).
status Singapore regulates crypto through the Monetary Authority of Singapore under three statutes by activity: the Payment Services Act 2019 licenses digital payment token services (scope widened from 4 April 2024; 38 Major Payment Institutions list DPT service in the MAS Financial Institutions Directory on 14 October 2026); Part 9 of the Financial Services and Markets Act 2022 has required Singapore digital token service providers serving only overseas customers to be licensed since 30 June 2025, and MAS will generally not issue such a licence; and the Securities and Futures Act 2001 covers tokens that are capital markets products. The stablecoin framework MAS finalised on 15 August 2023 is not yet legislated: MAS consulted on Payment Services Act amendments on 1 September 2026, with comments due by 16 October 2026.
tax No capital gains tax; income tax if trading is a business; GST does not apply to DPT-for-fiat exchange Under IRAS's e-Tax Guide on digital tokens (30 January 2026), a gain on disposal of payment tokens is taxable income when the disposal is revenue in nature under the badges of trade, for example when the taxpayer is a trader in payment tokens (para 5.7, Annex A); a company that mines is regarded as carrying on a business of mining and is taxed on disposal of the mined tokens. IRAS weighs the intention at the point of purchase of a payment token, through the badges of trade, to decide whether a later disposal is trading and the gain revenue in nature; for a trader in payment tokens, IRAS accepts first-in-first-out or weighted average cost, in line with FRS 2 Inventories, but not last-in-first-out (e-Tax Guide, 30 January 2026, para 5.7 and Annex A). IRAS treats the use of payment tokens to pay for goods or services as barter trade: a business that receives payment tokens is taxed on the value of the goods or services it provided, and where the contract fixes a number of tokens rather than a fiat amount, the taxable income is the value of those tokens when the income accrues (e-Tax Guide, 30 January 2026, paras 5.1–5.2, Annex A). Wages paid to an employee in payment tokens are taxable employment income, measured on the value of the employment services performed when the income accrues; where the tokens are subject to a moratorium, they are taxable when the moratorium is lifted (IRAS e-Tax Guide, 30 January 2026, Annex A, scenario B). Capital Gains: Singapore generally does not impose capital gains tax. Therefore, individuals who buy and sell digital tokens for long-term investment purposes are generally not taxed on any gains arising from the disposal of these tokens. Trading as a Business: If an individual engages in frequent or systematic trading of digital tokens to the extent that it constitutes a trade or business, the profits will be taxable as income. IRAS taxes a company that mines payment tokens as carrying on a business of mining, on its profits when the mined tokens are disposed of, with mining expenses deductible from commencement of business; fees received for providing mining services to customers are taxable (e-Tax Guide on digital tokens, 30 January 2026, Annex A, scenarios D and E). The guide does not address staking rewards.
travel rule Singapore applies the travel rule to DPT value transfers through MAS Notice PSN02 ¶13: transfers above S$1,500 must carry full originator information (¶13.6), and transfers at or below S$1,500 carry names plus account or reference numbers (¶13.4). Under MAS Notice PSN02 ¶13, an ordering DPT service provider must identify the originator, include originator and beneficiary information with each value transfer, and must not execute or arrange the transfer if it cannot comply (¶13.11). MAS Notice PSN02 ¶13 applies to all DPT value transfers: at or below S$1,500 the message must carry originator and beneficiary names and account or unique reference numbers (¶13.4); above S$1,500 the originator must also be verified and further originator information included (¶13.6). For DPT value transfers above S$1,500, MAS Notice PSN02 ¶13.6 requires the originator name and account or unique reference number plus any one of: residential or registered address, an identification or registration number, or date and place of birth or incorporation. MAS Notice PSN02 ¶13.4(c)–(d) requires the beneficiary name and the beneficiary account number, or a unique transaction reference number where no account exists, to accompany every DPT value transfer. MAS Notice PSN02 ¶13.9 requires all originator and beneficiary information collected by the ordering institution to be immediately and securely submitted to the beneficiary institution; where technical limitations stop the information travelling, the intermediary institution must keep it for at least five years (¶13.18). The travel rule for Singapore DPT service providers is set out in MAS Notice PSN02 ¶13 (Value Transfers), in the version dated 2 April 2024 and last revised 30 June 2025. The travel rule has bound Singapore DPT service providers since 28 January 2020, when MAS Notice PSN02 (dated 5 December 2019, value transfers at ¶13) took effect; the current notice applies to every Payment Services Act licensee carrying on a DPT service business (¶1.1).

Sources

This report is AI-generated from publicly available regulatory sources. Last updated: 2026-10-14. View full profile