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Singapore III: Regulation — PSA, SFA, FSMA/DTSP, Stablecoins, Tokenisation

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Singapore regulates digital assets through three statutes that were written at different times for different purposes and that now overlap on the same business models. The Payment Services Act 2019 captures the payments and exchange layer, while the Securities and Futures Act 2001 captures tokens that behave like investments. Part 9 of the Financial Services and Markets Act 2022 closes the gap for firms that sit in Singapore while serving the rest of the world. A founder who reads only one of the three will usually get the answer wrong, because the Monetary Authority of Singapore (MAS) applies them cumulatively to the activity and never to the label the firm has chosen for itself.

This Part sets out the three regimes in the order in which a Singapore adviser actually works through them. It starts with the Payment Services Act, because almost every crypto business touches a digital payment token service and because the licensing categories of that Act govern the practical questions of capital, custody and conduct. It then turns to the securities perimeter, where the question is whether a token is a capital markets product and what follows if it is. The third regime, the digital token service provider licence under the Financial Services and Markets Act, came into force on 30 June 2025. It reshaped the population of Singapore crypto firms more sharply than any earlier measure.

Three further chapters deal with areas where the general regimes meet specific policy. The first is the single-currency stablecoin framework announced in August 2023 and its legislative implementation. The second is the tokenisation of securities and funds under Project Guardian and its successors. The third is the regulatory treatment of staking, lending, decentralised finance and non-fungible tokens. The Part closes with the licensing process as it is experienced from the applicant's side, including the route by which a Swiss group obtains a Singapore licence and a Singapore group a Swiss one.

Throughout, the comparison with Switzerland is made where it helps the decision. The Swiss reader will recognise the activity-based perimeter and the technology-neutral slogan, but should expect three differences at once. Singapore licenses the firm under a single integrated regulator, which has no equivalent of the self-regulatory organisation route for AML-only supervision. Since 2022 it has also deliberately kept retail participation in speculative tokens small. The law is stated as at 30 June 2026.

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.

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 Hong Kong, our parallel site HongkongIQ.com offers the same practical guidance. For crypto and digital assets, dltreg.com covers legal, tax and fiduciary services. For legal, tax and fiduciary services in Switzerland, see helveticaregister.com.