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Timelines and outcomes

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MAS does not commit to a processing time for payment licence applications and states only that the time depends on the completeness of the application and the complexity of the business. In practice a well-prepared SPI application for DPT services has taken nine to fifteen months from submission to grant. An MPI application for an exchange or a stablecoin business has taken eighteen to thirty months, with in-principle approval often granted six to twelve months before the full licence. The in-principle approval is conditional. It allows the firm to complete its build-out, hire staff and obtain the independent assessment, but it does not permit the firm to commence the regulated activity unless it was already operating under a transitional exemption.

Refusal rates are not published, but the arithmetic of the first licensing round is telling. Of the roughly 170 firms that notified MAS in 2020, fewer than one in five eventually held a licence. Most of the remainder withdrew after MAS indicated that it would not approve the application in its current form.1 The withdrawal mechanism matters: MAS prefers that a weak applicant withdraws, because a formal rejection must be published and is a mark against the applicant and its controllers in every future application worldwide. An applicant that receives a letter indicating MAS's concerns should treat it as a request to withdraw unless the concerns can be resolved quickly and completely.

StageTypical durationWhat MAS is doing
Pre-application engagement1–3 monthsInformal discussion of the business model and licence class
Submission and completeness check1–2 monthsConfirmation that all documents are present
Substantive review and queries6–18 monthsRounds of written questions, interviews with management, review of policies
Independent assessment2–4 months (parallel)Review of the third-party report on AML and technology
In-principle approval—Conditional approval; firm completes build-out
Grant of licence3–9 months after IPAVerification that conditions are met; licence issued

Practice note

A founder who wants a Singapore DPT licence should budget twenty-four months and a seven-figure Singapore dollar sum for the application, including staff, advisers, systems and the independent assessment. The budget is lower if the firm already operates a licensed business elsewhere with policies and systems that can be adapted. It is higher if the business involves retail customers, because the consumer protection measures must be built before the licence is granted. The decision to apply should be taken only if the Singapore market or the Singapore brand is worth that cost, since a licence held for its reputational value alone will not survive the first MAS inspection.

Notes

  1. MAS, Parliamentary reply on digital payment token licensing, 2022, on the number of applicants, approvals, withdrawals and rejections; MAS Financial Institutions Directory for the current list of licensees. ↩

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.