As enacted

Commentary · As enacted

Singapore’s proposed stablecoin framework: Global trends and key implications for industry

The text

Singapore’s

Proposed

Stablecoin

Framework: Global

Trends and Key

Implications for

Industry

7 September 2026

LEGAL

UPDATE

INTRODUCTION

THE PROPOSED SINGAPORE STABLECOIN

FRAMEWORK

GLOBAL DEVELOPMENTS AND COMPARATIVE

OBSERVATIONS

IMPLICATIONS FOR MAS-REGULATED

STABLECOIN ISSUERS AND APPLICANTS

IMPLICATIONS FOR FOREIGN ISSUERS SEEKING

RECOGNITION

IMPLICATIONS FOR LICENSED MPIS PROVIDING

DPT SERVICES AND DPT LICENCE APPLICANTS

IMPLICATIONS FOR FIAT PAYMENT AND

PAYOUT PROVIDERS WITHOUT A DPT LICENCE

CONCLUSION

In this

Guide

On 1 September 2026, the Monetary Authority of

Singapore (“MAS”) published its Consultation on

Proposed Amendments to the Payment Services Act for Stablecoin Regulation (the “Consultation

Paper”), setting out proposed amendments to the

Payment Services Act (“PS Act”) to implement

Singapore’s regulatory framework for stablecoins and further develop the MAS-regulated single currency stablecoin framework first finalised in 2023 (the “MAS-SCS Framework”).

The Consultation Paper comes at a significant time for stablecoin regulation globally. Regulatory frameworks are now in force or under development across a number of major financial centres, although there is no uniform model. Some jurisdictions have established dedicated issuer regimes; others regulate stablecoins within broader payments, electronic-money or cryptoasset frameworks; and several provide for additional requirements where a stablecoin becomes systemically important.

MAS’s proposals incorporate elements of these approaches, while also addressing the cross-border nature of stablecoin issuance through proposed frameworks for multi-jurisdictional issuance and recognition of foreign-regulated stablecoins. MAS has indicated that it intends to take a selective and risk-based approach to authorising stablecoin issuance licences and recognising foreign-issued stablecoins.

In this bulletin, we consider:

the principal elements of MAS’s proposed stablecoin framework;

the relationship between Singapore’s proposals and emerging approaches in other major jurisdictions;

the implications for prospective MAS-regulated stablecoin issuers and applicants;

the proposed recognition framework for foreign-issued stablecoins;

the implications for licensed major payment institutions (“MPIs”) providing digital payment token (“DPT”) services and DPT licence applicants; and

the position of fiat payment and payout providers that do not themselves provide DPT services.

Introduction

On 1 September 2026, the Monetary Authority of Singapore (“MAS”)

published its Consultation on Proposed Amendments to the Payment

Services Act for Stablecoin Regulation (the “Consultation Paper”), setting out proposed amendments to the Payment Services Act (“PS Act”) to implement Singapore’s regulatory framework for stablecoins and further develop the MAS-regulated single currency stablecoin framework first finalised in 2023 (the “MAS-SCS Framework”).

Against this backdrop, ACCESS Singapore and the Global FinTech

Institute (“GFI”) will convene an online industry roundtable on Wednesday,

9 September 2026, from 4.00 p.m. to 6.00 p.m. (GMT+8) to discuss the

Consultation Paper and gather industry views for a consolidated response to MAS. The roundtable will include participants from across the stablecoin ecosystem, including Circle, Tether, Paxos and StraitsX, as well as

Banking Circle. Grace Chong, our Head of Financial Services Regulation, will be one of the moderators. Register for the industry roundtable here.

others regulate stablecoins within broader payments, electronic-money or cryptoasset frameworks; and several provide for additional requirements where a stablecoin becomes systemically important.

In this Update, we consider:

•

the principal elements of MAS’s proposed stablecoin framework;

•

the relationship between Singapore’s proposals and emerging approaches in other major jurisdictions;

•

the implications for prospective MAS-regulated stablecoin issuers and applicants;

•

the proposed recognition framework for foreign-issued stablecoins;

•

the implications for licensed major payment institutions (“MPIs”)

providing digital payment token (“DPT”) services and DPT licence applicants; and

•

the position of fiat payment and payout providers that do not themselves provide DPT services.

1. The proposed Singapore stablecoin framework

1.1 A dedicated stablecoin issuance licence

MAS proposes a new licence class for the issuance of MAS-regulated stablecoins. Only a licensed issuer would be permitted to hold itself, or a stablecoin issued by it, out as “MAS-regulated”. MAS-recognised foreign stablecoins would constitute a separate category.

For MAS-regulated stablecoins, issuance would encompass the principal activities involved in operating the stablecoin, including minting and putting it into circulation, managing reserve assets and redeeming it at par.

The proposed framework would require full reserve backing, redemption at par within prescribed timeframes and safeguarding of customer monies pending issuance or redemption. The draft legislation would also require

MAS to be satisfied as to matters including the characteristics of the stablecoin, the applicant’s fitness and propriety and financial condition, and the public interest.

1.2 Ring-fencing of the issuance business

An MAS-regulated stablecoin issuer would generally not be permitted to conduct other regulated activities, including issuing non-MAS-regulated stablecoins or providing other payment, capital markets or banking services.

A limited exception is proposed for DPT services relating to the issuer’s own MAS-regulated stablecoin where those services are incidental to its issuance business. For example, the issuer may arrange for transmission or safeguard its own MAS-regulated stablecoin without requiring a separate

DPT service licence.

The proposed framework therefore contemplates a relatively distinct issuing entity rather than stablecoin issuance being added to a broader suite of regulated activities. Existing financial groups considering entry into the MAS-SCS Framework will need to consider the allocation of governance, treasury, technology and compliance functions accordingly.

5 1.3 Reserve liquidity, safeguarding and recovery

The Consultation Paper places increased emphasis on the liquidity and resilience of reserve arrangements.

In addition to full reserve backing, MAS is considering a minimum proportion of reserves being maintained in cash or bank deposits, quarterly stress testing and powers to impose additional liquidity or risk-based capital requirements where vulnerabilities are identified. Recovery and orderly wind-down plans are also proposed.

The proposals therefore extend beyond nominal reserve coverage. Issuers may need to demonstrate that reserve assets remain sufficiently liquid and accessible to meet redemption obligations under stressed conditions, including having regard to concentration, custody and banking counterparty risks.

MAS also proposes immediate safeguarding of monies received pending issuance and monies due to holders pending completion of redemption.

1.4 Restrictions on yield and use of reserve income

MAS proposes to prohibit interest, returns or other benefits attributable to the holding or balance of an MAS-regulated stablecoin. The prohibition is intended to distinguish an MAS-regulated stablecoin as a payment instrument or medium of exchange from an investment or savings product.

MAS is separately considering restrictions on the use of customer monies and income generated from those monies for on-lending or material financing of the issuer’s business. MAS recognises that reserve income may contribute to the financial and operational viability of stablecoin issuance and is seeking views on whether such a restriction is necessary and, if so, how such restrictions should be calibrated.

The calibration of these requirements is likely to be commercially significant. More restrictive requirements concerning reserve composition and the use of reserve income may affect the economics of issuance even where the headline requirement of full reserve backing remains unchanged.

1.5 AML/CFT and technological controls

MAS proposes to require issuers to have the technical capability to trace, freeze and/or burn stablecoins found to be used for or in support of illicit activities.

MAS is separately considering whether further targeted measures may be necessary, including verified identification of every holder of an MAS-

regulated stablecoin, restrictions on the use of unhosted wallets and ongoing monitoring of stablecoins in circulation.

Depending on the final requirements, applicants proposing permissionless transfers, self-hosted wallets or circulation across multiple blockchain networks may therefore need to consider whether the underlying architecture can support the controls ultimately expected by MAS.

1.6 Designated systematic stablecoins

MAS proposes a separate framework under which stablecoins may be designated as systemic. The framework could apply regardless of whether the stablecoin is issued in or outside Singapore and whether it is otherwise regulated under the MAS-SCS Framework.

Relevant factors would include the amount in circulation, interconnectedness with payment systems, use within the broader financial system and substitutability. MAS identifies use in merchant payments, capital markets settlement, trade finance and cross-border settlement as potentially relevant considerations.

MAS would also have powers to restrict the circulation of a non-compliant systemic stablecoin, including by directing regulated DPT service providers to cease offering or delist the stablecoin or restrict further accumulation by customers.

1.7 Multi-jurisdictional issuance and foreign recognition

MAS proposes two distinct mechanisms to address stablecoins with a cross-border dimension.

Under the proposed multi-jurisdictional issuance (“MJI”) framework, related entities in Singapore and overseas may issue the same fungible stablecoin.

The Singapore issuer would require a stablecoin issuance licence, while the foreign co-issuer would need to be subject to a framework that MAS considers substantively equivalent. The proposals address matters including reserve allocation and rebalancing, comparable issuance and redemption arrangements and coordinated recovery planning.

MAS proposes that the combined reserve assets of the issuing entities must equal at least 100% of the par value of outstanding stablecoins, satisfy the stricter of the applicable Singapore or foreign reserve requirements, and be appropriately segregated and custodied. The amount of reserves held by the Singapore issuer would be risk-proportionate, supported by arrangements such as reserve rebalancing or stablecoin attribution models.

Separately, MAS proposes a recognition framework for stablecoins issued overseas. Recognition would be available selectively and on a case-by-

case basis where MAS is satisfied that the stablecoin is well regulated for value stability, including that the relevant foreign framework is substantively equivalent and appropriate supervisory cooperation and information-sharing arrangements are in place.

Recognition would not amount to direct regulation by MAS. It would instead distinguish qualifying foreign-regulated stablecoins from other non-MAS-regulated stablecoins.

2. Global developments and comparative observations

While stablecoin frameworks are developing rapidly across major financial centres, there is no single regulatory model. The approaches adopted in

Singapore, Hong Kong, the United States, the European Union, the United

Kingdom, Japan, Australia, the UAE and Switzerland differ in their legal architecture and the types of entities through which stablecoin issuance may be undertaken.

There is nevertheless increasing convergence on the substantive protections expected of stablecoins intended to function as payment instruments, particularly in relation to reserve backing, redemption, liquidity, safeguarding, governance and AML/CFT. The principal differences concern how those requirements are implemented, the treatment of foreign-issued stablecoins and the point at which additional prudential requirements apply.

2.1 Different regulatory routes to similar prudential objectives

Singapore, Hong Kong and the United States have adopted or proposed regimes specifically directed at stablecoin issuers. Hong Kong’s

Stablecoins Ordinance has been in force since 1 August 2025 and requires issuers of fiat-referenced stablecoins within scope to be licensed by the

Hong Kong Monetary Authority (“HKMA”). The HKMA has indicated that it intends to maintain a high licensing bar and initially grant only a handful of licences.

The US GENIUS Act, signed into law in July 2025, similarly establishes a statutory framework for the regulation of payment stablecoins and permitted payment stablecoin issuers, although supervision may operate through different federal and state channels.

Other jurisdictions have incorporated stablecoins into broader regulatory categories. Under the European Union’s Markets in Crypto-Assets

Regulation (“MiCA”), stable-value tokens may be regulated as asset-referenced tokens (“ARTs”) or e-money tokens (“EMTs”), with issuers subject to the relevant authorisation requirements. Japan regulates fiat-linked stablecoins as electronic payment instruments and separately regulates intermediaries handling them. Its framework has continued to

develop, including through a new registration regime for electronic payment instrument and cryptoasset service intermediaries introduced in June 2026.

Australia and the UAE illustrate approaches more directly connected with payments regulation. Australia is modernising its payments framework and has proposed a graduated regime for stored-value facilities, including stablecoin issuers and wallets holding customer funds. At the same time,

ASIC considers that certain stablecoins may already constitute non-cash payment facilities under existing financial services legislation.

The UAE’s Payment Token Services Regulation, in force since August 2024, regulates payment token issuance, conversion, custody and transfer as digital payment services, with specific licensing or registration pathways applying to different types of payment-token activity.

Switzerland has historically applied existing financial-market legislation to stablecoin arrangements according to their structure and economic function. Proposed reforms would introduce more specific payment-institution and crypto-institution categories, with payment instrument institutions permitted to issue a specified form of stablecoin. The proposed reforms are not yet the existing regime.

Selected approaches to stablecoin regulation

Approach

Illustrative jurisdictions

Key features

Dedicated /

issuer-focused regime

Singapore,

Hong Kong,

United

States

Regulation is centred on the stablecoin issuer, with specific requirements concerning reserve backing, redemption, prudential safeguards, governance and ongoing supervision. Singapore proposes a dedicated stablecoin issuance licence for

MAS-regulated stablecoins;

Hong

Kong’s licensing regime for issuers of fiat-referenced stablecoins has been in force since August 2025; and the US

GENIUS

Act establishes a statutory framework for permitted payment stablecoin issuers, with federal or state supervision depending on the issuer.

Cryptoasset

/ electronic-European

Union, Japan

Regulation is based on the statutory characterisation of the stablecoin. Under MiCA, stable-

Approach

Illustrative jurisdictions

Key features money classification value tokens are regulated principally as asset-referenced tokens or e-money tokens, with corresponding requirements applying to their issuers. In

Japan, fiat-linked stablecoins meeting the statutory criteria fall within the “electronic payment instrument”

framework, with separate registration requirements applying to intermediaries that handle such instruments.

Payments /

stored-value framework

Australia,

UAE

Stablecoin activity is addressed within a broader framework for payments, stored value or payment-token services.

Australia’s proposed payments reforms would bring stablecoin issuers within a graduated regime for stored-value facilities, while ASIC considers that certain stablecoins may already constitute non-cash payment facilities.

In the

UAE, the

Payment

Token

Services

Regulation regulates payment-token issuance, conversion, custody and transfer as digital payment services.

Existing financial regulation with further reform proposed

Switzerland

Stablecoins are currently assessed under existing financial-market legislation according to their legal structure and economic function. FINMA notes that stablecoin holders’

claims will commonly constitute deposits for banking-law purposes, although certain structures using bank default guarantees may avoid a banking licence for the issuer.

Legislative reforms have been

Approach

Illustrative jurisdictions

Key features proposed to introduce a more specific framework for payment institutions and stablecoin issuance.

Additional systemic layer

Singapore,

United

Kingdom,

European

Union

Additional prudential, supervisory or resolution requirements may apply where a stablecoin becomes sufficiently significant to raise broader financial-stability concerns. Singapore proposes a designation regime for systemic stablecoins; the UK is developing an additional Bank of England regime for systemic stablecoin issuers; and MiCA subjects significant asset-referenced and e-money tokens to additional requirements and enhanced EBA supervision.

2.2 Increasing focus on liquidity and payment functionality

A further point of convergence is the increasing focus on the quality and liquidity of reserve assets, rather than full backing in nominal terms alone.

The Singapore proposals reflect this through the proposed minimum cash or bank-deposit component, quarterly stress testing and potential additional liquidity requirements. Similar concerns concerning the availability and resilience of backing assets arise across the Hong Kong, US and EU frameworks.

The United Kingdom illustrates the same issue from a financial-stability perspective. The FCA published its final rules for qualifying stablecoin issuance in June 2026, ahead of commencement of the new regulatory regime. Under that framework, the FCA will regulate UK-issued qualifying stablecoins. Where a stablecoin is widely used in payments and recognised as systemic by HM Treasury, its issuance will be subject to joint regulation by the FCA and Bank of England. The Bank published its policy statement and draft Code of Practice for systemic stablecoins in June 2026, with the systemic rules still being finalised.

This increasing focus on reserve liquidity may have direct commercial implications. The relevant question for an issuer is not simply whether reserves equal the amount of stablecoins in circulation, but also what assets may constitute those reserves, how readily they can be realised under stress and the extent to which income generated from them may be retained or deployed.

There is also an increasing tendency to regulate stablecoins by reference to their payment function. This is apparent in the US concept of a “payment stablecoin”, Japan’s electronic payment instrument framework, Australia’s proposed stored-value treatment and the UAE’s payment-token regime.

The UAE, for example, requires redemption at par and prohibits interest or benefits linked to the period for which the token is held.

MAS’s proposed restrictions on holder returns are consistent with this broader distinction between a stable payment instrument and an investment or savings product.

2.3 Regulation becomes more differentiated as stablecoins increase in scale

Several jurisdictions also distinguish between ordinary regulated issuance and stablecoins whose scale or use gives rise to broader financial-stability concerns.

The United Kingdom provides for additional Bank of England oversight where a stablecoin becomes systemic in payments. MiCA similarly provides a separate regime for ARTs and EMTs classified as significant, including additional requirements and direct EBA supervisory responsibilities.

MAS’s proposed systemic stablecoin framework applies the same underlying principle, although the criteria and regulatory consequences differ. Importantly, MAS’s designation powers are not confined to locally issued or MAS-regulated stablecoins.

The result is an increasingly graduated regulatory model. Compliance with the requirements applicable at issuance may not represent the final regulatory position of a stablecoin. Additional prudential, governance, operational or resolution requirements may arise as its circulation, use and interconnectedness increase.

For issuers contemplating significant payment, settlement or financial-market use cases, regulatory scalability should therefore be considered alongside commercial and technological scalability.

12 2.4 Cross-border treatment remains less harmonised

There is considerably less consistency in the treatment of stablecoins issued, distributed or redeemed across multiple jurisdictions.

Most regimes remain organised around a locally regulated issuer or intermediary. Different approaches are then taken to foreign-issued stablecoins, including local intermediary requirements, restrictions on distribution or reliance on the regulatory status of the foreign issuer.

Japan, for example, has specific requirements applicable to foreign electronic payment instruments and also takes account of regulatory equivalence in aspects of its cross-border framework.

MAS’s proposed recognition framework addresses the issue more expressly through an assessment of the foreign regulatory regime and supervisory cooperation. Its proposed MJI framework goes further by contemplating concurrent issuance of the same fungible stablecoin by related entities in Singapore and overseas, supported by coordinated reserve, redemption and recovery arrangements.

These are among the more distinctive aspects of the Singapore proposals.

If implemented, a stablecoin available in Singapore could be an MAS-regulated stablecoin, an MAS-recognised foreign stablecoin or another stablecoin treated as a DPT, with a further systemic overlay potentially applying depending on its scale and use.

The comparative position therefore suggests increasing convergence on the prudential characteristics expected of regulated payment stablecoins, but continuing diversity in the legal architecture through which those requirements are imposed, particularly for cross-border issuance.

3. Implications for MAS-regulated stablecoin issuers and applicants

Prospective issuers should expect the licensing process to involve a substantive assessment not only of the proposed stablecoin and the applicant’s financial position, but also of whether the business can be operated on a sound and sustainable basis. MAS has indicated that it intends to adopt a selective and risk-based approach to licensing, taking into account matters including financial soundness, business viability and operational track record.

Entity and governance arrangements will be an important preliminary consideration. Given the proposed restrictions on an issuer conducting other regulated activities, groups already carrying on payment, DPT, banking or capital markets businesses will need to consider the appropriate issuing entity and the allocation of governance, technology, compliance, treasury and reserve-management functions. Applicants should also

consider whether outsourced or group functions provide the issuing entity with sufficient operational control and oversight to discharge its own regulatory obligations.

Risk management is likely to form a significant part of application readiness. MAS expects issuers to maintain an effective risk management framework addressing all material risks arising from their functions and activities, including operational, fraud, cyber, compliance, ML/TF and financial-stability risks. Applicants should therefore be prepared to demonstrate how material risks have been identified, assessed and allocated within the organisation, the controls and limits established to manage those risks, the governance and escalation arrangements applicable to them, and how the framework will be reviewed as the stablecoin business develops.

Reserve and liquidity risk management will require considerably more than demonstrating 100% reserve backing. Applicants should be prepared to address reserve composition and liquidity, banking and custody counterparties, concentration and counterparty risks, redemption forecasting and contingency funding. MAS also proposes quarterly stress testing covering both idiosyncratic and systemic shocks, with results reviewed at board level and shared with MAS, and powers to impose additional capital, liquidity or reserve buffers where material vulnerabilities are identified.

Operational resilience and recovery planning should similarly be developed before licensing rather than treated as a post-authorisation exercise.

Applicants will need to consider how critical issuance and redemption functions would continue during operational disruption, reserve or banking stress, significant redemption activity and other severe but plausible events. Recovery and orderly wind-down plans should identify relevant trigger scenarios, actions, resources and timelines, and assess whether sufficient liquid resources would remain available to support an orderly exit.

Technology and financial crime controls may also affect the design of the product itself. Applicants should assess whether the proposed blockchain and wallet architecture can support tracing, freezing and burning capabilities and, depending on MAS’s final requirements, any further controls relating to holder identification, unhosted wallets and ongoing transaction monitoring. This will be particularly relevant where the stablecoin is intended to circulate permissionlessly, across multiple blockchain networks or through third-party wallet infrastructure.

For global issuers, an additional structural question will be whether

Singapore is intended to operate as a standalone issuing jurisdiction or as part of an MJI arrangement. An MJI model would require consideration of the foreign co-issuer’s regulatory status, allocation and rebalancing of reserves across jurisdictions, comparable issuance and redemption terms, and coordinated risk management, recovery and wind-down arrangements.

MAS specifically contemplates risk-proportionate allocation of reserves and mechanisms such as reserve rebalancing or stablecoin attribution models.

4. Implications for foreign issuers seeking recognition

The proposed recognition framework provides a potential route for foreign-issued stablecoins to obtain a differentiated regulatory status in Singapore without the issuer itself becoming an MAS-regulated stablecoin issuer.

MAS's rationale is to distinguish stablecoins that are well regulated for value stability in another jurisdiction from stablecoins that are not subject to comparable regulatory safeguards. Recognition would be limited, granted on a case-by-case basis and available only where MAS is satisfied that the stablecoin remains well regulated for value stability on an ongoing basis.

Recognition should be distinguished from an MAS stablecoin issuance licence. A recognised foreign-issued stablecoin would remain issued and supervised under its home regulatory regime. MAS intends the status and concessions accorded to MAS-regulated stablecoins and recognised foreign-issued stablecoins to remain sufficiently distinct so that customers can differentiate between a stablecoin directly regulated and supervised by

MAS and one recognised by MAS as meeting substantively equivalent baseline standards but supervised by its home regulator.

Home regulatory status will therefore be a threshold consideration. It will not be sufficient for an issuer merely to hold a licence or authorisation overseas. MAS proposes to assess whether the issuer and stablecoin are regulated under a foreign framework that is substantively equivalent to the

MAS-SCS Framework. Foreign issuers considering recognition should therefore assess the extent to which their home regime addresses the principal value-stability safeguards under the Singapore framework, including reserve backing, reserve quality and safeguarding, redemption and relevant prudential requirements. The precise conditions for recognition have not yet been prescribed and are intended to be set out in subsidiary legislation.

Supervisory cooperation will be equally important. MAS proposes to require supervisory cooperation and information-sharing arrangements with the relevant foreign competent authority. Recognition may therefore depend on matters outside the issuer's direct control, including the regulatory framework in its home jurisdiction and whether the necessary arrangements can be established between MAS and the home regulator.

An issuer considering recognition

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Singapore’s proposed stablecoin framework: Global trends and key implications for industry

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Year: 2026
Current version: As enacted

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Law-firm commentary · Singapore’s proposed stablecoin framework: Global trends and key implications for industry, As enacted. Reader record updated on 10 Sep 2026.

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