Last updated
Singapore regulates crypto as digital payment token (DPT) services under the Payment Services Act. If you buy, sell, exchange, transfer or hold tokens for customers, you need a MAS licence. Base capital is S$100,000 for a standard payment institution and S$250,000 for a major one. Checked .
SingaporeCompanySetupGuide.com is an independent guide, not MAS, ACRA or a law firm. Providers may pay us for requests from our forms. A crypto firm should take legal advice before it builds.
What counts as a DPT service?
MAS lists five activities inside the digital payment token service:
- Buying or selling digital payment tokens.
- Providing a platform that lets people exchange tokens.
- Transmitting, or arranging the transmission of, tokens.
- Providing custodian wallet services for tokens.
- Actively facilitating the buying or selling of tokens without holding the money or the tokens.
What changed in the April rules?
MAS widened the net from . It now regulates:
- Custodial services for tokens.
- Facilitating the transmission or exchange of tokens between accounts.
- Facilitating cross-border money transfer between countries.
Firms already active in these areas had to notify MAS within 30 days and apply for a licence within six months. An auditor's attestation report was due within nine months. A firm that missed the deadlines had to stop the activity. MAS also set user protection rules: customer assets are segregated and held on trust, records are kept and security controls are in place. Retail customers cannot be offered lending or staking of their tokens.
What changed on 30 June?
From , Part 9 of the Financial Services and Markets Act applies to digital token service providers. MAS said providers serving only customers outside Singapore need a licence, and that it will generally not issue one. The reasons given were money-laundering risk and supervisory limits. MAS added that it knew of a very small number of such providers and had contacted them about winding down. If your plan is a Singapore shell serving offshore users only, this is the wrong place.
Which licence class fits?
Two payment institution classes can hold a DPT service. A small crypto start-up usually begins as a standard payment institution, with S$100,000 base capital. A bigger exchange or custodian that passes the MAS volume limits moves to the major class, which asks for S$250,000 and a deposit of S$100,000 or S$200,000. Thresholds, directors and the deposit rule are laid out on payment institution licence.
Can you market to the public?
MAS guideline PS-G02, published , says DPT service providers should not promote their services to the general public in Singapore. MAS has warned that token trading is highly risky and not suitable for the public. That affects ads, sponsored content and influencer deals. Take the rule into your business plan.
How do you set up the company first?
- Reserve a name (S$15) and register the company (S$300). ACRA fees total S$315.
- Appoint directors who meet the MAS rules, and a company secretary.
- Set up the registered address.
- Fund the company to meet base capital plus a buffer.
- Prepare the MAS application under guideline PS-G01.
See company registration, private limited company and, for overseas founders, register a company as a foreigner.
What about bank accounts?
You need an operating account and likely a bank relationship for safeguarding. Banks decide for themselves who they take on. Read business bank account before you plan your flow of funds.
Which costs does this guide leave out?
MAS gives no application fee or processing time on the pages read. Audit, compliance staff, custody systems, legal advice and insurance are your own numbers. We have no verified source for them, so none are quoted.
Which SSIC code fits?
Choose it on Bizfile. The MAS and ACRA pages read here do not name a code for crypto services, so none is given. See SSIC code.
Where does a provider help?
A provider can register the company, supply the address and prepare bank documents. The MAS licence, the custody design and the compliance function are yours. Send the quote form and we pass your request to suitable providers.
Sources
- MAS, types of payment services: https://www.mas.gov.sg/regulation/payments/licensing-for-payment-service-providers/types-of-payment-services (DPT activities)
- MAS, licensing for payment service providers: https://www.mas.gov.sg/regulation/payments/licensing-for-payment-service-providers (capital, thresholds, deposit)
- MAS, expanded scope of regulated payment services: MAS media release (April changes, user protection)
- MAS, regime for digital token service providers: MAS media release (offshore-only providers)
- MAS, PS-G02: https://www.mas.gov.sg/regulation/guidelines/ps-g02-guidelines-on-provision-of-digital-payment-token-services-to-the-public (no promotion to the public)
