Legislative implementation and the state at 30 June 2026

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The August 2023 response stated that the detailed requirements, the legislative amendments and the transitional arrangements would be published at a date to be confirmed.¹ The amendments to the Payment Services Act and the Payment Services Regulations needed to create the stablecoin issuance service were drafted during 2024 and 2025. MAS encouraged prospective issuers to prepare early and treated the framework as settled policy in its engagement with applicants from the date of the response.

The practical effect of the delay was that the framework operated as a set of expectations enforced through licence conditions. Issuers that applied for or held MPI licences for e-money issuance in respect of a Singapore-dollar stablecoin were asked to meet the reserve, capital and redemption standards as conditions of their licence, pending the formal regime. The approach is familiar in Singapore, where MAS frequently implements a policy through supervisory expectations before the statute catches up. The industry treats the published response as binding.

Notes

Reed Smith, 23 August 2023 (above): MAS will publish the detailed regulatory requirements, legislative amendments and transitional arrangements "at a date to be confirmed". ↩

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of October 2026.

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I am Of Counsel with KGP Legal LLC in Singapore, where I work with a global client base of successful entrepreneurs and their families, independent asset managers, commodity trading houses and other commercial clients. I am a German and Swiss attorney-at-law, also admitted as a solicitor in England & Wales and in Hong Kong. I divide my time between Zug in Switzerland, Singapore and Hong Kong. Since 2017 I have advised international clients on more than 700 crypto and digital asset projects. I also have extensive experience in cross-border litigation and arbitration in Singapore, Hong Kong and other markets in South-East Asia and Greater China.

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