Phase four: consolidation, 2025–2026

Read the PDF edition (1 page)

By 2025 both hubs had decided what they wanted to be. Singapore wanted institutional tokenisation, regulated stablecoins and a small number of well-capitalised DPT licensees serving a protected retail market. It also wanted the offshore-only token businesses gone. The DTSP regime's commencement on 30 June 2025 without a transitional period achieved the last of these within weeks and sent a number of trading firms and token issuers to Dubai, Hong Kong and, in some cases, Zug.¹ Project Guardian moved from pilots towards commercial frameworks for tokenised funds and fixed income. The consumer-access measures took full effect on 19 June 2025. Singapore committed to CARF in November 2024 with first exchanges expected in 2027 or 2028.

Switzerland wanted to remain the place where the infrastructure was built and where a serious crypto business could obtain a bank account and, if needed, a banking licence. The SNB extended Project Helvetia in June 2025 to at least mid-2027 and added settlement in traditional central bank money through a link to the SIC system. Switzerland thereby became the only country with both wholesale CBDC and RTGS-linked settlement of tokenised assets in production.² Parliament approved the CARF multilateral agreement on 26 September 2025 and the amended AEOI Act entered into force on 1 January 2026, but the suspension of the partner-state decree in November 2025 means that data collection starts no earlier than 1 January 2027 with first exchanges in 2028 (see Part C, Chapter VI and Part G, Chapter VII).³ The AML reform that created a federal transparency register and extended due-diligence duties to advisers moved through Parliament, while the Federal Council continued work on a stablecoin regime. Part C, Chapter VI gives the state of each item on 30 June 2026.

Notes

MAS, "Response to feedback received on proposed regulatory approach, regulations, notices and guidelines for digital token service providers", 30 May 2025; MAS, media release of 6 June 2025. ↩
Swiss National Bank, press release of 30 June 2025. ↩
State Secretariat for International Finance, "CARF FAQ Update". ↩

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.

English

Contact

Dr Alexander Ressos, TEP

Of Counsel, KGP Legal LLC

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.

I operate across the key financial centres in South-East Asia, the Middle East and Switzerland, with a particular focus on asset protection, international tax and estate planning, as well as trusts, company administration and other fiduciary services. My philosophy is to serve as a trusted advisor working closely with my clients and to help them achieve their commercial objectives.

All Singapore law advice is provided through KGP Legal LLC, an established and duly licensed firm of Singapore advocates and solicitors.

KGP Legal LLC is a medium-sized law firm in Singapore that is capable of providing the full range of legal services and corporate administration work. Please contact me directly at [email protected] if you need any further information.

Get in touch →

Articles and Insights

Setting up or expanding in Singapore?

SingaporeIQ is edited by Dr Alexander Ressos, an international business lawyer with more than 15 years of local experience in Singapore as a permanent resident, a Singapore registered foreign lawyer and managing partner of a Singapore foreign law practice. In addition to significant experience in cross-border investments and transactions, UHNWI private client work and sanctions/export controls, Dr Ressos has extensive experience in cross-border business and in crypto and digital-asset projects in Singapore, drawn from more than 700 projects since 2017.

If you are planning a company incorporation, an investment, a holding structure or a market entry through Singapore, you can reach Dr Ressos directly at [email protected]. Singapore law advice is provided by KGP Legal LLC, a licensed firm of Singapore advocates and solicitors. Dr Ressos and his team facilitate the full range of Singapore legal, compliance and company administration services, including company incorporation, corporate transactions, commercial contracts, crypto and digital assets, financial regulatory work and dispute resolution, including litigation in the Singapore courts. For legal, tax and fiduciary services in Switzerland, see helveticaregister.com.