MAS Stablecoin Framework: PS Act Amendments, 16 October Deadline

The label “MAS-regulated stablecoin” is about to become a statutory gate. On 1 September 2026 the Monetary Authority of Singapore (MAS) published a consultation on legislative amendments to the Payment Services Act 2019 that would give the MAS stablecoin framework legal effect. The consultation invites feedback by 16 October 2026; responding is not a mandatory filing obligation for issuers or payment service providers. Read the wrong side of the line and a firm can spend a year building to requirements that never apply to it, or market a token as regulated when nothing in the statute yet permits that claim.

Singapore has had a single-currency stablecoin (SCS) policy on paper since 2023. What it has not had is the legislation that turns those policy positions into obligations an issuer can be licensed against and held to. This consultation is the drafting step: it proposes how issuers qualify to be MAS-regulated, what a “MAS-regulated stablecoin” is allowed to say about itself, and how everything that fails to qualify is treated instead. It also reopens several questions the 2023 response left closed, most visibly whether a stablecoin issued jointly out of Singapore and abroad can carry the Singapore label.

The consultation directly affects two audiences: firms that want to issue a MAS-regulated stablecoin, and payment service providers that already hold, or plan to hold, a licence for digital payment token (DPT) services. The distinction between those two is the whole game, and it is the first thing to get right.

Related reading: MiCAR token classification and reporting obligations

The dates that bind the MAS stablecoin timeline

Because this is a deadline-driven consultation, the calendar is the part to pin first. The consultation includes proposed amendments implementing positions finalised in 2023 as well as policy changes and additional requirements proposed in 2026.

• 26 October 2022: MAS first consulted on its proposed framework to regulate stablecoins for value stability.
• 15 August 2023: MAS published its response to that consultation and finalised the single-currency stablecoin framework.
• 1 September 2026: MAS published the consultation on legislative amendments to the Payment Services Act 2019 to implement the framework, together with new policy proposals.
• 16 October 2026: the consultation closes.
• Later, date not set: MAS has signalled that the detailed quantitative requirements will sit in subsidiary legislation, to be consulted on separately.

The gap between the third and fifth entries is the point most easily missed. Responding to this consultation shapes the primary-law amendments. MAS has indicated that accompanying subsidiary legislation will be consulted on separately. Firms should therefore distinguish the parameters already set out in the 2023 framework and the 2026 draft amendments from implementation detail that remains for the later subsidiary-legislation consultation. A firm that reads only the media release and waits for the detailed rules should expect at least a further consultation on the accompanying subsidiary legislation before those requirements are finalised.

What the MAS stablecoin framework already settled in 2023

The framework that these amendments implement was not written this year. MAS set its core parameters in the 15 August 2023 response to feedback, and the 2026 consultation carries them forward without reopening them. Treating the September 2026 paper as a blank slate is the first misreading to avoid; the core 2023 requirements remain the starting point, while the 2026 consultation also proposes changes to parts of the framework as well as additional requirements.

The framework applies to single-currency stablecoins pegged to the Singapore Dollar or to any G10 currency, that are issued in Singapore. A token pegged to a basket, or to a currency outside that set, falls outside the SCS perimeter and is handled as a digital payment token instead. Within that perimeter, the 2023 framework fixed four things an issuer must satisfy to be recognised: reserve backing, capital, redemption at par, and disclosure.

On reserves, the framework requires reserve assets to be held at all times at a value equal to at least 100% of the par value of the stablecoins in circulation, with independent checks on a monthly basis and an audit each year. For non-bank SCS issuers subject to the 2023 framework, MAS set a base-capital requirement of the higher of S$1 million or 50% of annual operating expenses. On redemption, holders must be able to redeem at par value within five business days of a redemption request. On disclosure, the issuer must publish information, including on the value-stabilising mechanism and the audit results, so that a holder can see what backs the coin.

One carve-out from 2023 matters for smaller players and is easy to overstate: under the 2023 framework, a non-bank SCS issuer with SCS in circulation not exceeding S$5 million was outside the regulated SCS-issuer requirements. That is a relief from the regulated-issuer obligations, and it comes with a cost that firms sometimes miss. An exempted issuer is not a MAS-regulated stablecoin issuer, so it cannot describe its token as a “MAS-regulated stablecoin”. The exemption keeps a small issuer out of the heavy obligations, and out of the label that carries commercial value.

Because the 2023 positions are policy rather than enacted law, none of these requirements binds anyone yet. That is precisely why the 1 September consultation exists. The framework will become enforceable only when the relevant Payment Services Act amendments and subsidiary legislation take effect. Until the proposed amendments take effect, a firm’s obligations under the current Payment Services Act depend on the payment services it actually provides or solicits; the current Act does not yet contain a stablecoin-issuance licence.

Two tiers, one label: regulated SCS and digital payment tokens

Only issuers licensed under the proposed MAS-SCS framework may use the “MAS-regulated stablecoin” status for themselves and qualifying coins. Stablecoins outside that status continue to fall within the DPT framework except where another treatment under the proposed amendments applies.

Calling a token a “stablecoin” does nothing to move it across that line. A US dollar token from an issuer with no MAS licence is a DPT in Singapore, subject to the DPT rules, whatever its marketing says. The label is the regulated object here, and misusing it is the exposure. This is where a design that looks like a naming convention turns into a licensing perimeter.

The DPT framework carries its own substantive requirements. Non-MAS-regulated stablecoins continue to fall within the DPT framework and the consumer-protection safeguards applicable to DPT services. MAS is also consulting on additional consumer-protection safeguards for non-MAS-regulated stablecoins. For the boundary questions that decide which regime a token sits in, our note on crypto-asset versus financial-instrument classification shows how a parallel line is drawn in the EU.

The reserve, capital and redemption spine

For an issuer that does want the label, the consultation puts the 2023 spine into statutory language. The three load-bearing obligations are the reserve, the capital floor, and the redemption promise, and each one carries an operational trap.

The reserve requirement is a full-backing rule; fractional reserves do not satisfy it. Reserve assets equal to at least the par value of coins in circulation must be held at all times, in segregated arrangements, with attestation and audit. The trap is reading 100% backing as depositor protection. The 2023 framework couples segregated reserve assets with a holder’s legal claim against the issuer for redemption at par; MAS-regulated SCS should not be described as equivalent to insured bank deposits. The EU took the same instinct in a different direction for e-money tokens; our summary of the EBA statement on asset-referenced and e-money tokens sets out how reserve composition and own-funds interact under MiCA.

The capital floor is a formula linked to operating expenses. Base capital is the higher of S$1 million or 50% of annual operating expenses, which means a growing issuer’s capital requirement rises as the cost base grows, uncapped by the opening S$1 million figure. A firm modelling this off the S$1 million alone will under-provision the moment its operating expenses pass S$2 million a year.

Redemption at par marks the outer limit within five business days, the deadline a firm must meet in a stress scenario as reliably as on any other day. The redemption obligation is also what ties the reserve and capital requirements together: the reserve is what a redemption draws on, and the wind-down planning discussed below is what keeps redemption working when an issuer is failing.

The 2026 additions: an interest ban, stress testing and wind-down plans

Alongside implementing the 2023 spine, the consultation proposes to add requirements that were not in the original framework, aimed at ongoing financial stability beyond what the day-one authorisation criteria already cover. Three stand out.

First, an interest prohibition. MAS proposes that issuers be barred from paying interest, returns or other benefits attributable to the holding of a MAS-regulated stablecoin. The intent is to keep a regulated stablecoin functioning as a settlement instrument, with yield uses excluded. Where the boundary of that prohibition falls, for example how it treats rewards or benefits routed through a third party instead of the issuer directly, is exactly the kind of question a consultation response can usefully probe with a concrete example.

Second, stress testing. The consultation proposes a stress-testing requirement for MAS-regulated stablecoin issuers.

Third, recovery and orderly wind-down. Issuers would be required to have plans in place for recovery and for an orderly wind-down. This is the provision that reframes a stablecoin issuer as an entity built to wind down, as well as built to operate. For anyone who has read resolution planning in the banking world, the logic is familiar: the state that matters is the failing balance sheet, and the plan has to exist before it is needed.

Multi-jurisdictional issuance reverses the Singapore-only line

The most significant policy shift in the consultation is on jointly issued stablecoins. In 2023 the framework was built around tokens issued in Singapore by a Singapore issuer. MAS now proposes to allow a stablecoin jointly issued by a Singapore issuer and a foreign issuer to be regulated under the MAS-SCS framework, and labelled as a “MAS-regulated stablecoin”, provided the risks are sufficiently mitigated.

I read this as MAS responding to how large stablecoins are actually built. A single token that circulates across several markets is often issued through more than one legal entity, and a strictly domestic framework would either exclude those tokens or impose an artificial structure on firms that operate across borders. The condition to watch is the reserve question: once issuance spans two jurisdictions, “who holds the reserves, and against which slice of global circulation” stops being a formality. A response that engages seriously with reserve allocation, rebalancing between issuers, and how supervisors on both sides coordinate is more useful to MAS than one that simply welcomes the flexibility. Cross-border supervisory cooperation of this kind is not new territory for MAS; our coverage of the HKMA-MAS cross-border banking supervision arrangement shows the machinery it already runs with a neighbouring regulator.

Recognising foreign-issued stablecoins for wholesale use

The consultation also opens a door that the 2023 framework kept shut: recognition of a limited number of foreign-issued stablecoins that are regulated under a comparable foreign framework. MAS frames the proposed recognition regime around cross-border wholesale use cases.

The operative words are “limited” and “comparable”. The route amounts to selective recognition by MAS, based on MAS’s assessment of the foreign regulatory framework and the conditions ultimately specified in the legislation. For a foreign issuer, the practical read is that the route runs through MAS’s comparability judgement, and the near-term use case is wholesale settlement rather than a Singapore retail launch. The distinction between a recognised foreign stablecoin and a home-grown MAS-regulated one is worth stating plainly: recognition lets a foreign token be used here under conditions, but it does not turn that token into a MAS-regulated stablecoin.

Safeguarding customer monies before a coin exists

The last strand of the consumer-protection proposals is the one that reaches furthest back in the issuance process. MAS proposes to apply safeguards similar to those that already apply to existing Payment Services Act licensees, including a requirement to safeguard customer monies received before the corresponding stablecoins have been issued.

That timing detail is the substance. The risk MAS is addressing is the window between a customer paying in and the token being minted, when the customer has handed over value but holds nothing yet. MAS proposes safeguards for customer monies received before the corresponding stablecoins have been issued. Firms should verify the precise segregation, custody and insolvency-treatment requirements against the governing legislative and subsidiary-legislation text before implementation. Firms that hold an e-money or payments licence elsewhere will recognise the pattern; our guide to how PSD3 treats payment institutions and electronic money covers the same safeguarding logic in the EU context.

Where Singapore sits next to MiCA and the GENIUS Act

MAS says openly that it took recent international developments and best practices into account, and the two obvious reference points are the EU and the United States. The European Union has regulated e-money tokens and asset-referenced tokens under its Markets in Crypto-Assets Regulation since 2024. The United States enacted its first federal payment-stablecoin law, the GENIUS Act, in July 2025, requiring full reserve backing and, like the MAS proposal, restricting yield to holders.

The convergence is real but partial, and overstating it is a trap. The regimes share some prudential themes but are not interchangeable. MAS limits its SCS framework to SGD- and G10-pegged SCS; MiCA separately regulates asset-referenced tokens and e-money tokens, while the GENIUS Act establishes a distinct US payment-stablecoin issuer regime. A firm operating across these markets should assume it needs to satisfy each regime on its own terms; holding a MiCA or GENIUS Act permission does not substitute for MAS recognition. The direction of travel in the EU is itself still moving, as our note on the European Commission’s MiCAR review consultation sets out.

Preparing a response before 16 October

For a firm that will be affected, the useful work between now and 16 October is identifying the specific provisions that change the firm’s build and saying something MAS can act on, a concrete position, not a general endorsement.

An intending issuer should map its planned token against the SCS perimeter first: is the peg SGD or a G10 currency, and is issuance genuinely in Singapore or split across entities. If it is split, the multi-jurisdictional proposal is the section to engage, with concrete comment on reserve allocation and cross-border supervision. A DPT service provider should focus on the other side: which of its listed tokens are non-MAS-regulated stablecoins, and what the proposed additional retail safeguards would cost to implement. A foreign issuer eyeing Singapore should test the recognition route against its home regime and be candid about where comparability is strong and where it falls short.

Frequently Asked Questions

Does the S$5 million exemption still keep a small issuer out of the framework entirely?

The 2023 framework exempts a non-bank SCS issuer with stablecoins in circulation not exceeding S$5 million from the full requirements. The exemption removes the regulated-issuer obligations, but it also removes access to the “MAS-regulated stablecoin” label, and an exempted token is handled as a digital payment token. The consultation is the moment to check whether the amendments preserve that exemption in the form a small issuer relied on.

Is an algorithmic or basket-pegged stablecoin covered by this framework?

The framework is built for single-currency stablecoins pegged to the Singapore Dollar or a G10 currency. A token pegged to a basket, to another asset, or maintained algorithmically without qualifying reserves sits outside the SCS perimeter and is treated as a digital payment token with no access to the MAS-regulated label.

Can a foreign US dollar stablecoin be sold to Singapore retail customers under this consultation?

The proposed recognition regime is framed narrowly: a limited set of foreign-issued stablecoins for cross-border wholesale use, conditioned on a comparable foreign framework and supervisory cooperation. MAS has framed the proposed recognition route around cross-border wholesale use cases. Absent recognition, a foreign token remains a digital payment token in Singapore and is subject to the DPT consumer-access measures.

Does the interest prohibition catch rewards or cashback paid by a third party rather than the issuer?

MAS proposes to prohibit interest, returns or other benefits attributable to holding a MAS-regulated stablecoin. The consultation text is where the perimeter of “attributable” is set, including how it treats benefits routed through a party other than the issuer. A firm relying on a rewards model should raise that boundary in its response with a concrete example, instead of assuming an answer.

For a jointly issued stablecoin, are reserves counted once or twice?

Full backing has to hold against total circulation, so a multi-jurisdictional token cannot count the same reserves twice across its issuers. How reserves are allocated between a Singapore issuer and a foreign co-issuer, and how they are rebalanced as circulation shifts between markets, is one of the open questions the multi-jurisdictional proposal puts to consultation.

When do these requirements actually become binding?

The 16 October date closes the consultation on the primary-law amendments; it does not make the requirements binding on that day. The proposed requirements will become binding only when the relevant Payment Services Act amendments and subsidiary legislation take effect. Until then, firms must assess their obligations under the current Payment Services Act according to the payment services they actually provide or solicit.

What happens to an existing DPT licensee that already lists tokens marketed as stablecoins?

Those tokens remain digital payment tokens unless their issuer is licensed under the SCS framework. The licensee keeps its applicable DPT obligations, and should watch the consultation for the proposed additional retail safeguards for licensed DPT service providers offering non-MAS-regulated stablecoins.

Related Articles

• EBA MiCA Statement on ARTs and EMTs: how the EU sets reserve and own-funds requirements for asset-referenced and e-money tokens.
• MiCAR Token Classification and Reporting Obligations: the EU test for sorting tokens into ART, EMT and utility categories and what each must report.
• HKMA-MAS Cross-Border Banking Supervision: the supervisory-cooperation machinery MAS runs with a neighbouring regulator.
• ESMA Crypto-Asset and Financial-Instrument Classification: where the EU draws the boundary between a crypto-asset and a regulated instrument.
• Japan FSA Crypto-Asset Cybersecurity Countermeasures: how another Asian regulator sets operational expectations for crypto-asset service providers.
• PSD3 for Payment Institutions and Electronic Money: the EU safeguarding logic that parallels the MAS customer-monies proposal.

Key Takeaways

• Comments on the MAS legislative-amendment consultation close on 16 October 2026.
• The consultation implements the framework MAS finalised on 15 August 2023, while MAS has indicated that accompanying subsidiary legislation will be consulted on separately at a later date.
• Only qualifying issuers may use the “MAS-regulated stablecoin” label; other stablecoins remain within the DPT framework except where a different treatment under the proposed amendments applies.
• The framework covers single-currency stablecoins pegged to the Singapore Dollar or a G10 currency and issued in Singapore; base capital is the higher of S$1 million or 50% of annual operating expenses, reserves must equal at least 100% of par value, and redemption at par is due within five business days.
• New for 2026: a prohibition on paying interest on regulated stablecoins, a stress-testing requirement, and mandatory recovery and orderly wind-down plans.
• Multi-jurisdictional issuance would be allowed for the first time, reversing the 2023 Singapore-only position, provided reserve and supervisory risks are sufficiently mitigated.
• A limited recognition route for foreign-issued stablecoins under comparable frameworks is proposed for cross-border wholesale use cases.
• The proposed requirements will become binding only when the relevant Payment Services Act amendments and subsidiary legislation take effect; existing Singapore requirements continue to apply in the meantime according to the activities a firm carries on.

Sources and References

• Monetary Authority of Singapore, “MAS Consults on Legislative Amendments to Implement Stablecoin Regulatory Framework” (media release, 1 September 2026): https://www.mas.gov.sg/news/media-releases/2026/mas-consults-on-legislative-amendments-to-implement-stablecoin-regulatory-framework
• Monetary Authority of Singapore, “MAS Finalises Stablecoin Regulatory Framework” (media release, 15 August 2023): https://www.mas.gov.sg/news/media-releases/2023/mas-finalises-stablecoin-regulatory-framework
• Monetary Authority of Singapore, Consultations index (for the September 2026 consultation paper and response link): https://www.mas.gov.sg/publications/consultations
• Payment Services Act 2019 (Singapore), Singapore Statutes Online: https://sso.agc.gov.sg/Act/PSA2019
• Gibson Dunn, “Singapore Publishes Draft Legislation to Implement Its Stablecoin Framework” (analysis of the September 2026 consultation): https://www.gibsondunn.com/singapore-publishes-draft-legislation-to-implement-its-stablecoin-framework/
• Congressional Research Service, “Stablecoin Legislation: An Overview of the GENIUS Act of 2025 (P.L. 119-27)”: https://www.congress.gov/crs-product/IN12553

The response window, and what comes after it

The near-term action is narrow and dated. A firm that will issue, distribute or list stablecoins in Singapore should decide which of these proposals changes its build, and file that on the record by 16 October 2026. The multi-jurisdictional and foreign-recognition proposals are the ones where a well-argued response has the most room to shape the outcome, because they are genuinely unsettled, unlike the questions carried forward from 2023.

After that, the work moves to the subsidiary legislation, where the reserve, capital and redemption mechanics get their operative numbers. Firms that responded to this round with concrete build detail will be reading that next consultation with a map already drawn. The date to hold is 16 October; the document to produce is a comment that names the provision and the change it forces.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.