Singapore's Proposed Stablecoin Rules: What the MAS Consultation Means for Issuers, Exchanges, and Banks

Key takeaways

• MAS proposes a dedicated stablecoin issuance license under the Payment Services Act. Holding a token out as a "MAS-regulated stablecoin" without one, or falsely claiming a token or entity is MAS-regulated, would become a criminal offense, with fines of up to SGD 250,000 and a further fine up to SGD 25,000 for each day a continuing offense persists after conviction.
• Issuers would have to hold reserves equal to at least 100% of par value at all times, redeem at par within MAS-prescribed timeframes, and would be barred from paying interest, return, or any benefit tied to holding a stablecoin.
• Issuers would need the technical capability to trace, freeze, and burn stablecoins found to be used for illicit activity, on top of existing AML/CFT duties such as customer due diligence, the travel rule, and screening.
• MAS could designate any stablecoin (domestic or foreign, MAS-regulated or not, including algorithmic tokens) as a Designated Systemic Stablecoin, with power to restrict its circulation in Singapore.
• MAS would allow the same fungible stablecoin to be issued from Singapore and one or more foreign jurisdictions, and would recognize a limited number of well-regulated foreign stablecoins, a shift from its 2023 position.
• The duties reach non-regulated tokens and banks: DPT service providers offering non-MAS-regulated "stablecoins" to retail customers may face enhanced reserve disclosure, risk warnings, and marketing limits, and banks may only issue a MAS-regulated stablecoin through a separate non-bank entity.
• The consultation closes on October 16, 2026. Thresholds, timeframes, and detailed rules will follow in subsidiary legislation MAS will consult on separately.

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On September 1, 2026, the Monetary Authority of Singapore (MAS) proposed amendments to the Payment Services Act 2019 that would give stablecoins a statutory framework and add requirements developed since MAS set out its stablecoin approach in 2023. The consultation is open until October 16, 2026. The proposal sets the terms on which a token can be held out as a "MAS-regulated stablecoin," and it creates a parallel set of duties for stablecoins that are not MAS-regulated but still circulate in Singapore — which is what pulls exchanges, payment firms, and banks into scope alongside issuers.

What is MAS proposing?

The amendments create a new stablecoin issuance license, alongside the existing money-changing, standard payment institution, and major payment institution licenses. Only a licensee could hold a token out as a "MAS-regulated stablecoin." Doing so without a license, or falsely representing that a token or entity is MAS-regulated, would be a criminal offense carrying fines up to SGD 250,000, with a further fine up to SGD 25,000 for every day or part of a day a continuing offense persists after conviction.

The draft adds statutory definitions for "stablecoin," "MAS-regulated stablecoin," and "MAS-regulated stablecoin issuer." The definition of "stablecoin" is wider than the previous MAS single-currency stablecoin (SCS) framework, and tracks the Financial Stability Board's approach: it will include any token whose "issuer maintains or purports to maintain its value by reference to a single currency or asset, or a pool or basket of currencies or assets." The draft places stablecoins within the Digital Payment Token (DPT) category and carves fiat-pegged stablecoins out of the definition of "e-money," settling a question first raised in the 2019 consultation.

The starting point: The 2023 SCS framework

In 2023, MAS set out its regulatory approach for single-currency stablecoins pegged to a single currency. The requirements include full reserve backing, redemption at par, and disclosures; and such tokens are accorded a "MAS-regulated stablecoin" label to help users tell regulated tokens from unregulated ones. This framework was not written into a legislative instrument — this consultation now moves it into primary legislation and layers new requirements on top.

What changes for stablecoin issuers?

Reserves, redemption, and interest

Core obligations track the 2023 framework: reserves at least equal to the par value of all stablecoins in circulation at all times, and redemption within MAS-prescribed timeframes. The consultation also adds several items:

• Issuers would be prohibited from paying interest, return, or any benefit to holders tied to holding a stablecoin.
• MAS is considering a minimum proportion of reserves held in cash or bank deposits and is seeking views on the thresholds.
• MAS is also seeking feedback on possible caps on holdings and on aggregate issuance limits. Reserves would need to be held separately for different stablecoins.

Consumer protection and contagion

Issuers would have to safeguard money received before a stablecoin is issued, and money due for redemption but not yet paid, to ring-fence customer funds in insolvency. MAS is also consulting on whether to restrict issuers from using customer money, and interest earned on it, to materially finance their business. To limit contagion risk, issuers would not be allowed to conduct other regulated activities beyond issuing a MAS-regulated stablecoin.

Risk management, stress testing, and resolution

Issuers would need risk management frameworks covering operational, compliance, and financial stability risks. The consultation proposes stress testing of reserve assets and redemption mechanisms at least quarterly, with results shared with MAS, and powers for MAS to impose additional liquidity or capital requirements where testing reveals critical vulnerabilities.

Issuers would need recovery and orderly wind-down plans, reviewed and approved at board level at least annually, with financial resources independently verified. An issuer whose license is revoked, lapses, or is surrendered would have to cease all issuance, and MAS could prohibit an exiting issuer from disposing of reserve assets until it is satisfied there are no outstanding redemption requests.

Trace, freeze, and burn

Beyond existing anti-money laundering (AML) and countering the financing of terrorism (CFT) obligations (customer due diligence, the Travel Rule, and screening), issuers would need the technical capability to trace, freeze, and burn stablecoins found to be used for illicit activity. MAS says it is also assessing further measures used in other jurisdictions, including verified identification of every holder, restrictions on the use of unhosted wallets, and ongoing monitoring of stablecoins in circulation.

What changes for exchanges, payment firms, and other DPT service providers?

Two parts of the proposal reach firms that only intermediate stablecoins rather than issue them.

The first is the Designated Systemic Stablecoin framework. It has three parts:

• Reporting obligations on issuers and licensed intermediaries about stablecoins circulating in Singapore.
• A power for MAS to designate a stablecoin as systemic where needed to prevent systemic risk or in the public interest.
• Once designated, requirements include those in the SCS framework, plus enhanced governance, recovery, and resolution standards drawn from Financial Stability Board recommendations, some of which MAS will consult on separately.

Designation could reach any stablecoin regardless of where it is issued or whether it is MAS-regulated, and would turn on the token's size, its interconnectedness with Singapore's payment and financial systems, and its substitutability. Where a designated systemic stablecoin is non-compliant, MAS could direct DPT intermediaries to stop offering it, delist it, and prevent further accumulation.

The second is a set of retail-facing duties. DPT service providers offering non-MAS-regulated "stablecoins" to retail customers may have to provide enhanced disclosure of reserve assets and clear risk warnings, and may be barred from marketing such tokens using the term "stablecoin."

What changes for banks?

Banks and merchant banks that want to issue a MAS-regulated stablecoin would have to do so through a separate non-bank entity licensed as an issuer. MAS has also said that tokenized deposits will be addressed in separate guidance to be issued at a later date.

How does Singapore compare with other jurisdictions?

Full reserve backing and redemption at par are now common across major frameworks, as is a prohibition on paying interest to holders: Singapore's proposal, the US GENIUS Act, and the EU's Markets in Crypto Assets Regulation (MiCA) all include these requirements. The frameworks differ most on systemic risk and cross-border stablecoins.

Systemic risk

MiCA sets thresholds for "significant" tokens and caps large non-EU-currency tokens used widely as a means of exchange, requiring an issuer to stop issuing if activity exceeds 1 million transactions and EUR 200 million per day. The GENIUS Act uses a USD 10 billion threshold to divide state and federal oversight. Singapore proposes a discretionary designation power that can reach any stablecoin circulating locally, including foreign ones.

Cross-border treatment

Japan has introduced a route for foreign stablecoins to be distributed domestically through registered intermediaries. Singapore proposes both multi-jurisdictional issuance and a recognition track, each conditioned on substantive equivalence and supervisory cooperation: reserves across all issuing entities would need to equal at least 100% of global par value, the foreign issuer would need to be supervised under a substantively equivalent regime, and there would need to be comparable terms of issuance and redemption across jurisdictions. MiCA requires authorization within the EU and offers no third-country equivalence or passporting regime for foreign stablecoins.

Issuer eligibility

Japan limits issuance to three routes: banks, funds transfer service providers, and specified trust companies. Hong Kong requires a licensed issuer with at least HKD 25 million in paid-up capital. The US permits bank subsidiaries and approved federal or state issuers. The EU requires an authorized credit institution or e-money institution for e-money tokens.

What should compliance teams do now?

For prospective or existing issuers, the proposal points to a clear set of build priorities: a reserve, safeguarding, and redemption model that holds to 100% at all times and pays par on demand; board-level risk management with at least quarterly stress testing and recovery and wind-down plans; and trace, freeze, and burn capability designed into the token and custody stack rather than added later.

For exchanges, payment firms, and other DPT service providers, the reporting net under the systemic stablecoin framework is the item to watch. Firms that only intermediate stablecoins may still have to report volume and redemption data and act on directions to delist or stop circulating a designated coin. Retail-facing disclosures and marketing language for non-MAS-regulated stablecoins would also need review.

Banks that intend to issue stablecoins will need to work out how to structure the issuing entity within the group to keep contagion risk contained.

What lies ahead?

Much of the detail will arrive through subsidiary legislation MAS will consult on separately: thresholds, timeframes, the trace-freeze-burn notice, recognition conditions, disclosure requirements, and resolution requirements, along with the separate framework for tokenized deposits.

How TRM Labs supports stablecoin compliance

Meeting these obligations depends on visibility into stablecoin flows across chains. TRM Labs provides blockchain intelligence that financial institutions and crypto businesses use to screen wallets, monitor transactions, and identify illicit activity involving stablecoins, with coverage of 185+ blockchains and 840+ cross-chain bridges, and wallet screening across 300M+ sources. That onchain visibility underpins the AML and reserve-transparency expectations MAS and other regulators are setting for stablecoins.