Introduction
On 1 September 2026, the Monetary Authority of Singapore ("MAS") published its long-awaited Consultation Paper on Proposed Amendments to the Payment Services Act 2019 for Stablecoins Regulation (the "2026 Consultation") (see here). The 2026 Consultation will close on 16 October 2026.
The 2026 Consultation builds on MAS's previous Consultation Paper on Proposed Regulatory Approach for Stablecoin-Related Activities published in October 2022, which first proposed a regulatory framework for MAS-regulated single-currency pegged stablecoins ("MAS-SCS Framework"), and the corresponding Response to the 2022 Consultation published in August 2023 (collectively, the “2023 Framework”) (please refer to the 2022 consultation paper and 2023 response here).
The 2026 Consultation sets out (A) the draft legislative amendments to the Payment Services Act 2019 of Singapore (“PS Act”) to introduce the proposed regulatory framework for stablecoins in Singapore, and (B) several further proposals to the MAS-SCS Framework, to reflect market and regulatory developments.
This alert highlights the key features of the proposed amendments, and their practical implications for interested parties, including prospective stablecoin issuers and licence applicants, intermediaries, and existing or prospective digital payment token (“DPT”) service providers.
Overview of proposed stablecoin framework
MAS’s proposed framework is structured around a differentiated regulatory treatment for stablecoins, depending on factors such as how and where they are issued, whether they meet MAS’s value-stability requirements, and the extent to which they may pose risks to Singapore’s financial system. Stablecoins will generally continue to be treated as a subset of DPTs under the PS Act, unless they fall within the proposed MAS-regulated stablecoin framework or are recognised by MAS under the proposed foreign recognition framework.
The proposed framework distinguishes between the following categories:
1. MAS-regulated stablecoins:
MAS proposes to introduce a new and dedicated licence class for “stablecoin issuance”. Persons who wish to hold themselves out as an issuer of an MAS-regulated stablecoin, or otherwise hold out any stablecoin that they issue as an MAS-regulated stablecoin, must obtain a stablecoin issuance licence. Such issuers will also be required to comply with MAS’s requirements on value stability, reserve backing, redemption, prudential safeguards, AML/CFT, consumer protection and operational resilience.
2. Multi-jurisdictional issuance (“MJI”) arrangements:
The MAS proposes an approval framework for arrangements involving the concurrent issuance of the same fungible stablecoin by related or affiliate issuers in Singapore and one or more foreign jurisdictions, and for such issuers to hold out their stablecoins as being “MAS-regulated”. This represents a shift from MAS’s 2023 position as MAS had then considered not to allow such a multi-jurisdictional issuance approval framework, and is now revising its policy stance given developments in the stablecoin regulatory landscape since then. The MJI framework is subject to case-by-case exemptions and safeguards, which include substantive equivalence of the relevant foreign regulatory regime, robust reserve asset and reserve transferability arrangements, comparable issuance and redemption terms across jurisdictions, and other conditions aimed at addressing the risks specific to MJI structures.
3. Recognised foreign-regulated stablecoins:
MAS proposes a separate recognition framework for foreign-issued stablecoins which are already regulated under a foreign regime assessed by MAS to be substantively equivalent to the MAS-regulated stablecoin framework. Such stablecoins would not be treated as being “MAS-regulated” but may instead be held out as “recognised” foreign-issued stablecoins, subject to MAS’s recognition criteria and supervisory cooperation arrangements.
4. Non-MAS-regulated stablecoins:
Stablecoins that do not qualify as being “MAS-regulated” will generally continue to be treated as DPTs under the PS Act. Intermediaries that offer services relating to such stablecoins may therefore require the appropriate PS Act licence if their services would fall within scope of regulated DPT services.
5. Designated systemic stablecoins:
MAS proposes a framework for designating a stablecoin as being a systemic stablecoin. This would operate as an overlay and may apply to any stablecoin that poses systemic risks in Singapore, regardless of where it is issued or whether it is otherwise MAS-regulated or recognised. Any of the stablecoins described above may likewise be designated as a systemic stablecoin. Such designation would not itself confer MAS-regulated stablecoin status but may subject the issuer and relevant intermediaries to additional requirements or circulation restrictions.
We discuss these categories as well as other noteworthy highlights of the 2026 Consultation below.
Amendments to PS Act definitions
To facilitate the above-mentioned framework, amendments are being proposed to the PS Act definitions. In substance, MAS proposes to:
- introduce new definitions of the terms “stablecoin” and “MAS-regulated stablecoin” (among others);
- amend the definition of “digital payment token” such as to provide for stablecoins to be a subset of DPTs. Stablecoins that do not otherwise qualify as MAS-regulated or MAS-recognised stablecoins would therefore remain within the existing DPT regime; and
- amend the definition of “e-money” to exclude stablecoins.
MAS-regulated stablecoins
Conceptually, MAS-regulated stablecoins sit at the core of the proposed regime. Only licensed issuers may hold themselves out as issuers of MAS-regulated stablecoins and represent their tokens as being MAS-regulated.
Key ongoing requirements
The 2026 Consultation proposes the following key ongoing requirements in relation to MAS-regulated stablecoin issuers:
- Expanded ringfencing / business activity restrictions: MAS proposes to reinforce the ringfencing of MAS-regulated stablecoin issuance from other regulated or higher-risk business activities to mitigate contagion risks. MAS-regulated stablecoin issuers would generally be prohibited from conducting other regulated activities, including issuing non-MAS-regulated stablecoins, providing other payment services, or carrying on capital markets services.1
- Prohibition on paying interest: Issuers of MAS-regulated stablecoins will be prohibited from paying interest, returns or other benefits tied to holding the stablecoin, to reinforce its character as a payment instrument rather than an investment product.
- Safeguarding of customer monies: Issuers must safeguard monies received prior to stablecoin issuance, and monies due for redemption not yet paid out, broadly mirroring the protections applicable to e-money issuers.
- Stress testing and enhanced capital/liquidity powers: MAS proposes to require MAS-regulated stablecoin issuers to conduct regular stress testing, at least quarterly, to ensure that their reserve asset and redemption mechanisms remain robust under adverse market conditions. The results should be subject to appropriate governance oversight and reporting to MAS, and MAS may require issuers to maintain additional capital, liquid assets and/or reserve assets where appropriate.
- Recovery and orderly wind-down plans: MAS proposes to require MAS-regulated stablecoin issuers to put in place board-approved recovery and orderly wind-down plans, to be reviewed and submitted to MAS at least annually. Issuers would also be required to maintain financial resources to support an orderly wind-down, with the adequacy of such resources to be independently verified. MAS proposes to include licensed issuers of MAS-regulated stablecoins as pertinent financial institutions under the Financial Services and Markets Act 2022, with the intent to apply recovery and orderly wind-up requirements to non-systemic issuers.
- Traceability, freeze and burn capability: MAS proposes to require MAS-regulated stablecoin issuers to have the technical capability to trace, freeze and/or burn their stablecoins where necessary to address illicit activity.
- Use of customer monies and reserve income: MAS will continue to assess and seek industry views on whether MAS-regulated stablecoin issuers should be subject to restrictions on the use of customer monies and interest income generated from reserve assets to fund their business activities, consistent with the approach currently applicable to e-money issuers.
- Minimum proportion of reserve assets to be held in cash / bank deposits: MAS will continue to assess and seek industry views on whether MAS-regulated stablecoin issuers should be required to hold a prescribed minimum proportion of their reserve assets in cash or bank deposits. In this regard, MAS has noted comparative thresholds in the UK and EU frameworks, which range from 5% to 30% for non-systemic stablecoins and 40% to 60% for systemic stablecoins.
- Aggregate issuance and holding caps: MAS will continue to assess and seek industry views on whether to introduce quantitative limits for MAS-regulated stablecoins, including aggregate issuance limits applicable to individual issuers and/or limits on the amount that may be held by individual users. MAS notes that similar limits currently apply in the e-money context, and is considering whether comparable safeguards would be appropriate for stablecoin issuance.
- Additional AML/CFT safeguards: MAS will continue to assess and seek industry views on whether additional AML/CFT safeguards should be introduced, including requirements relating to holder identification, restrictions on transfers to or from unhosted wallets, and ongoing monitoring of stablecoins in circulation.
Exiting the MAS-SCS Framework
MAS-regulated stablecoin issuers who wish to exit the MAS-SCS Framework will be disallowed from conducting all issuance business, which would extend to activities relating to non-MAS-regulated stablecoins. MAS is also considering whether the former MAS-regulated entity must be wound up altogether, so as to avoid any public misapprehension that the stablecoin continues to be MAS-regulated.
It has also been suggested that MAS should have powers to require exiting stablecoin issuers to support orderly redemption of MAS-regulated stablecoins prior to winding up its business of issuing MAS-regulated stablecoins, and not to dispose of reserve assets for purposes other than fulfilling redemptions, until MAS is reasonably satisfied that there are no outstanding redemption requests from holders of MAS-regulated stablecoins.
MJI arrangements
An MJI arrangement involves the issuance of the same fungible stablecoin by related or affiliated entities operating in different jurisdictions and sharing the same reserve pool. MAS proposes to allow such stablecoins issued concurrently from Singapore and one or more foreign jurisdictions to be held out as being an MAS-regulated stablecoin, provided that the risks arising from such MJI arrangements are adequately addressed.
Licensing and baseline obligations
Under an MJI arrangement, the Singapore issuer, if approved by the MAS, would hold a stablecoin issuance licence and must comply with all the regulatory requirements under the MAS-SCS Framework, subject to two proposed exemptions to be granted by MAS on a case-by-case basis:
- Singapore incorporation requirement: The requirement for the issuer of a MAS-regulated stablecoin to be incorporated in Singapore may be exempted. Such an exemption, if granted, would allow the Singapore issuer to have one or more overseas-incorporated co-issuers.
- Reserve asset backing requirement: The Singapore issuer may be exempt from the requirement to hold reserve assets equal to or exceeding the full value of stablecoins in circulation. Instead, part of the reserve assets may be held by its co-issuers.
Proposed safeguards
To preserve the high degree of value stability of MAS-regulated stablecoins within an MJI arrangement, MAS has proposed the following safeguards:
- Foreign co-issuer’s regulatory regime must be substantively equivalent to MAS’s regulatory framework: Foreign co-issuers must be supervised under a stablecoin regulatory regime that MAS deems as substantively equivalent to the MAS-SCS Framework. MAS will also have regard to whether comprehensive bilateral arrangements exist between MAS and the foreign regulatory authority to facilitate information sharing and supervisory cooperation over the entities issuing the same fungible stablecoin.
- Reserve asset composition set by the stricter standard: With the policy intent to prevent regulatory arbitrage and minimise liquidity risk, the composition of reserve assets held by all issuing entities – Singapore and foreign alike – must satisfy whichever of the MAS-SCS Framework or the foreign regime imposes the stricter requirements.
- Additional reserve assets requirements:
- The value of reserve assets held across all issuing entities must at all times equal at least 100% of the par value of outstanding stablecoins in circulation.
- Reserve assets should be denominated in the currency of the stablecoin peg, must be held in segregated accounts on trust, and placed with financial institutions licensed for custodial services by a competent authority.
- The reserves held by the Singapore issuer relative to its offshore counterparts must be risk-proportionate, and the Singapore issuer must demonstrate to MAS that it can mitigate the risks arising from reserves being split across jurisdictions.
- The rights of all stablecoin holders must be comparable across all issuing entities (e.g. redemption fees and redemption timelines). If there are differences in the regulatory frameworks, the issuer should meet the stricter of the regulatory requirements.
- Robust recovery and orderly wind-up plans:
- MAS has proposed that issuers under the MJI framework must maintain robust recovery plans that explicitly address cross-jurisdictional implementation and coordination, including where (i) the issuer ceases to be a MAS-regulated stablecoin issuer; (ii) the issuer or the foreign co-issuer continues the issuance business; and (iii) the stablecoins in circulation remain fungible.
- In line with the requirements associated with exiting the MAS-SCS Framework discussed above, MAS is also considering whether it is necessary for an issuer to be required to wind up its entity to avoid public confusion that its stablecoin is still MAS-regulated.
- In any event, an MAS-regulated stablecoin issuer under an MJI arrangement who exits the MAS-SCS framework would be expected to ensure that there are no outstanding redemption requests from existing holders of MAS-regulated stablecoins prior to exiting the MAS-SCS framework.
Recognition of foreign-regulated stablecoins
An MAS-recognised stablecoin differs from a stablecoin issued under the aforementioned MJI framework, in that the former would not be regarded as an MAS-regulated stablecoin, but would not be completely unregulated under the proposed amended MAS-SCS Framework. MAS expects to recognise a limited number of such stablecoins on a case-by-case basis.
To be a MAS-recognised stablecoin, MAS must be satisfied that such stablecoins are well-regulated by the foreign regulatory authority for value stability on an ongoing basis. MAS has proposed that both the foreign issuer and the relevant stablecoin must fulfil conditions such as:
- Foreign issuers must be supervised under a stablecoin regulatory regime that MAS deems as substantively equivalent to the MAS-SCS Framework.
- There must be supervisory cooperation and information sharing between MAS and the counterpart foreign regulatory authority.
Non-MAS-regulated stablecoins
As an incremental change under the 2026 Consultation, the MAS is also proposing to draw a clearer line between MAS-regulated and non-MAS-regulated stablecoins, and to reduce the risk of retail customers mistakenly assuming that unregulated tokens carry any assurance of value stability. MAS proposes to impose additional requirements on licensed DPT service providers that offer non-MAS-regulated stablecoins to their customers. Notably, this will also capture any non-MAS-regulated DPT that purports to maintain a stable value, even where its issuer does not describe it as a "stablecoin".
Under the proposals, licensed DPT service providers will be required to:
- Enhance disclosures on reserve assets. Retail customers must be given clear information on the assets (if any) backing the token. For algorithmic stablecoins, this means disclosing that the token has no backing assets. Where a non-MAS-regulated stablecoin publicly discloses its reserve composition on an ongoing basis, DPT service providers must provide clear references to that information.
- Give clear risk warnings. Retail customers must be told that the token is not regulated by MAS for value stability and may not maintain its promised value.
- Avoid using the term "stablecoin" in marketing. Where such tokens are marketed to retail customers, DPT service providers must not describe them as "stablecoins".
Designated systemic stablecoins
MAS may designate a stablecoin – irrespective of where it is issued or whether it or its issuer is otherwise regulated under the MAS-SCS Framework – as systemic where such designation is necessary to prevent systemic risk events, disruption to users of the stablecoin, or disruption to, or loss of public confidence in, Singapore’s financial system. In assessing whether designation is warranted, MAS proposes to consider non-exhaustive factors including the size of the stablecoin, its interconnectedness with Singapore’s payment and broader financial systems, and the availability of substitutes. MAS may also withdraw a designation where the relevant circumstances no longer warrant it.
Once designated, the issuer may be subject to requirements equivalent to, or more stringent than, those applicable to MAS-regulated stablecoin issuers. These may include requirements relating to reserve assets, redemption rights, prudential safeguards, disclosures, governance, recovery and resolution planning, reporting and audit.
MAS would also be empowered to restrict the circulation of a non-compliant designated systemic stablecoin in Singapore, including by directing licensed DPT service providers to cease offering or delist the stablecoin, or to prevent customers from further accumulating it.
MAS further proposes to require stablecoin issuers and licensed stablecoin intermediaries to provide information on stablecoins circulating in Singapore, including information relating to issuance, redemption and intermediary arrangements. This obligation is proposed to apply broadly to tokens that seek to maintain value against a reference asset or basket of assets, even where they are not marketed as “stablecoins”.
Other key features
Some additional noteworthy features of the proposed framework include:
- Retail protection for non-MAS-regulated "stablecoins": Licensed DPT service providers offering tokens that purport to maintain a stable value, but are not MAS-regulated stablecoins, may be subject to proposed enhanced retail-facing safeguards. These may include disclosures on reserve assets, clear warnings that the tokens are not MAS-regulated for value stability and may not maintain their value, and restrictions on marketing such tokens to retail customers as “stablecoins”.
- Bank/merchant bank issuance structure: MAS proposes that banks and merchant banks issue MAS-regulated stablecoins through a separate licensed non-bank entity, in order to ringfence stablecoin issuance from banking activities, mitigate contagion risk and support reserve segregation. Wholesale banks and merchant banks would remain subject to existing depositor-scope restrictions, which may limit their ability to issue Singapore dollar stablecoins for broad retail circulation.
Summary table
This table summarises, at a high level, the proposed treatment of the principal stablecoin arrangements discussed above.
Practical implications
The 2026 Consultation is significant for market participants involved in the issuance, distribution or use of stablecoins in Singapore. Clients should assess the proposed regime against their current and planned business models, group structures, reserve arrangements, customer-facing materials and operational capabilities.
In particular:
- Prospective MAS-regulated stablecoin issuers should assess whether they can meet the proposed licensing and ongoing compliance requirements, including reserve backing, redemption, prudential safeguards, AML/CFT controls, safeguarding of customer monies, stress testing, recovery and orderly wind-down planning, and traceability, freeze and burn capabilities.
- Business model and ringfencing considerations will be important, as MAS-regulated stablecoin issuers would generally be restricted from conducting other regulated or higher-risk activities alongside stablecoin issuance, subject to exceptions for incidental activities.
- Stablecoin groups with cross-border issuance structures should consider whether their arrangements could fall within the proposed MJI framework, and whether they can satisfy MAS’s proposed safeguards relating to foreign regulatory equivalence, reserve asset arrangements, and comparable issuance and redemption terms.
- Banks and merchant banks considering stablecoin issuance should assess the legal, regulatory and operational implications of MAS’s proposal for MAS-regulated stablecoins to be issued through a separate licensed non-bank entity, including implications for capitalisation, governance, intra-group arrangements and reserve asset segregation.
- Foreign issuers and intermediaries distributing widely used stablecoins in Singapore should consider whether such stablecoins may be exposed to the proposed systemic designation framework, particularly where they have material circulation in Singapore, significant interconnectedness with Singapore’s payment or financial systems, or limited substitutability.
- Licensed DPT service providers offering tokens that purport to maintain a stable value but are not MAS-regulated stablecoins should review their platform disclosures, risk warnings, terms of service and marketing materials to ensure that such tokens are not presented to retail customers as having MAS-regulated value stability.
Conclusion
The 2026 Consultation represents a momentous step towards a fully operational stablecoin regime in Singapore. While MAS has retained certain core features of the 2023 Framework, the 2026 proposals would materially expand the regulatory expectations for stablecoin issuers and intermediaries, particularly in relation to cross-border issuance, consumer protection, financial stability safeguards and systemic risk oversight.
The proposals remain subject to consultation and have not yet been finalised. Interested market participants should consider whether to provide feedback to MAS by 16 October 2026.
1. However, an MAS-regulated stablecoin issuance licence would cover incidental activities. Under a proposed new paragraph 2(m) under Part 2 of the First Schedule to the PS Act, licensed issuers of MAS-regulated stablecoins would be able to provide services incidental to their stablecoin issuance activity without requiring a separate licence. This is intended to accommodate activities such as minting, putting into circulation the MAS-regulated stablecoins, managing reserve assets and redeeming the MAS-regulated stablecoins at par.
2. Namely, (i) the requirement on the issuer being incorporated in Singapore, and (ii) the reserve asset backing requirement under which Singapore issuer must itself hold reserve assets equal to or exceeding the value of stablecoins in circulation.
