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Opinion: Interest Ban. Wind-Down Plans. Multi-Jurisdictional Issuance. Singapore Has Published the Most Comprehensive Stablecoin Legislation in APAC.

Nicole
Nicole

28th September 2026

By Cyrus Tong

On September 1, 2026, the Monetary Authority of Singapore published consultation paper P015-2026, a set of proposed amendments to the Payment Services Act 2019 that would give legal force to Singapore’s Single-Currency Stablecoin framework for the first time.

This is not a new policy announcement. 

The MAS-SCS framework was finalised in August 2023. 

What September 1 represents is something more consequential: 

The translation of three years of regulatory policy into enforceable statutory law, with a protected designation, a new licence class, and four significant new policy proposals that respond directly to international regulatory developments since 2023.

The consultation closes October 16, 2026.

For every institution operating in Singapore’s digital payment ecosystem, that deadline is the last formal opportunity to shape legislation that will govern stablecoin issuance in one of Asia’s most strategically important financial centres for years to come. 

What the Draft Amendments Actually Do

The consultation package has two distinct components, and understanding the difference between them is essential for compliance planning.

The first is the legislative implementation of positions MAS already finalised in 2023. 

These are not new policy choices. 

They are the statutory form of what was already established in regulatory guidance. 

The draft amendments introduce statutory definitions of “stablecoin” and “MAS-regulated stablecoin.” 

They create a new licence class for stablecoin issuance, covering minting, circulation, reserve management, and redemption at par. 

They require reserve assets to equal at least the par value of all stablecoins in circulation at all times. 

They mandate redemption in the pegged currency within MAS-prescribed timeframes, and they establish that only licensed issuers may market themselves as “MAS-regulated stablecoin” issuers or describe their tokens using that protected label. 

Stablecoins that fall outside the framework are not prohibited.

But they will be reclassified as Digital Payment Tokens and subjected to the existing consumer protection safeguards that apply to DPTs, including measures to assess customer risk awareness, restrictions on trading incentives, prohibitions on credit card payments, and limits on financing and leverage.

For compliance functions, this binary is immediately operationally significant. 

The question of whether a stablecoin qualifies for MAS-SCS status or falls into the DPT category determines the entire compliance architecture, the disclosures required, the marketing restrictions that apply, and the regulatory relationship an issuer will have with MAS versus the existing DPT supervisory framework.

The framework applies to single-currency stablecoins issued in Singapore and pegged to the Singapore dollar or any G10 currency. 

This scope definition matters for institutions assessing whether products currently in market or in development will require a new MAS licence or can continue under existing payment service authorisations.

Banks and merchant banks wishing to issue MAS-regulated stablecoins must do so through a separate legal entity, a structural requirement that creates immediate corporate and compliance planning obligations for any institution with existing banking licences seeking to enter the stablecoin issuance market.

The Four New Policy Proposals and Why They Signal Global Convergence

The second component of the consultation package is more significant for forward-looking compliance planning. 

MAS is consulting for the first time on four policy areas that reflect how the global regulatory environment has evolved since 2023.

The first is multi-jurisdictional issuance. 

MAS has proposed allowing stablecoins jointly issued by a Singapore-based entity and a foreign issuer to qualify for MAS-SCS status, provided associated risks are adequately mitigated. 

This is a direct response to the cross-border stablecoin architecture that compliance professionals have been navigating since the GENIUS Act came into force, and it signals Singapore’s recognition that no major stablecoin can be purely domestic in its ambition or its regulatory footprint.

The second is recognition of foreign-issued stablecoins. 

MAS is consulting on whether stablecoins regulated under comparable overseas frameworks (MiCA, the GENIUS Act, the UK’s FCA regime) should receive recognition for use in cross-border wholesale transactions in Singapore. 

The criteria for comparability have not yet been specified, and determining them will be one of the most consequential outcomes of the consultation.

The third is the interest payment ban. 

Mirroring both MiCA and the GENIUS Act’s approach, MAS proposes prohibiting interest payments to MAS-regulated stablecoin holders, confirming that Singapore’s regulatory philosophy positions these instruments as payment tools rather than yield-bearing deposits. 

The fourth is operational resilience. 

MAS proposes mandatory stress testing, recovery plans, and orderly wind-down requirements for regulated issuers, a direct response to the systemic risk lessons of the 2022-2023 stablecoin failures and a clear signal that Singapore expects its regulated issuers to demonstrate institutional-grade operational governance, not just product compliance.

MAS has also signalled a selective, risk-based approach to licensing, expecting only a limited number of stablecoins to achieve regulatory approval, with evaluation criteria including financial soundness, operational track record, and business viability. 

This is not a framework designed to maximise the number of licensed issuers. 

It is a framework designed to identify the issuers that meet Singapore’s institutional standard.

My Take

I have spent over two decades building compliance frameworks in Singapore and across the APAC region. 

And the September 1 consultation paper is the most significant single regulatory step Singapore has taken in the stablecoin space. 

Not because it introduces new policy, but because it converts policy into law.

The distinction matters more than it might appear.

Regulatory guidance shapes behaviour. 

Statute governs it. 

And once the Payment Services Act amendments are enacted, the compliance obligations they create are enforceable, the protected designation has legal meaning, and the consequences of operating outside the framework are clearly defined.

What strikes me most about this consultation is the timing. 

It arrives alongside Circle’s $400 million acquisition of Tazapay, a deal awaiting MAS change-of-control approval. 

Alongside BLOOM, in which Visa, DBS, OCBC, UOB, and eight other institutions are building stablecoin settlement infrastructure under MAS supervision. 

Alongside Singapore’s first licensed stablecoin issuer, HKDAP and the HSBC product, already in active operation.

Singapore is not building its stablecoin regulatory architecture in anticipation of a market that might emerge.

It is building it around a market that is already operating.

And the institutions that engage with the October 16 consultation, that submit responses, that shape the subsidiary legislation on reserve composition and redemption timeframes, will be the ones whose compliance infrastructure most closely reflects the final framework when it becomes law.

The window to influence what you will eventually be required to comply with closes in four weeks.

About the author

Cyrus Tong, an award-winning compliance expert, is the Group Chief Compliance Officer of DCS Group.

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