MAS Single-Currency Stablecoin Framework: Issuer Rules, Reserves and Disclosures

A practical breakdown of Singapore's MAS SCS framework — covering reserve rules, redemption obligations, disclosure requirements, and what issuers must do to obtain the MAS-regulated label.

Singapore’s Monetary Authority of Singapore (MAS) finalised its policy framework for single-currency stablecoins (SCS) on 15 August 2023. The statutory amendments needed to implement that framework are now under consultation through P015-2026, published on 1 September 2026.

The framework introduces, for the first time, a structured licensing and conduct regime specifically for stablecoin issuers — separate from the existing digital payment token (DPT) rules under the Payment Services Act 2019 (PS Act).

For founders, legal counsel, and compliance officers evaluating Singapore as a stablecoin issuance jurisdiction, the framework has direct and practical implications. It sets specific thresholds that trigger licensing requirements, prescribes exactly what reserve assets can be held and how they must be managed, and introduces a recognised label — “MAS-regulated stablecoin” — that issuers can apply to obtain once all conditions are met.

This article walks through each component of the framework: who it applies to, what reserve and capital requirements look like in practice, what must be disclosed and when, and what the current implementation timeline means for entities considering Singapore-based issuance.

What Is the MAS Single-Currency Stablecoin Framework?

The MAS SCS framework sits within Singapore’s broader Payment Services Act ecosystem. Prior to its introduction, stablecoins were treated simply as digital payment tokens (DPTs) — a classification that addressed trading and custody services but did not specifically address the value-stabilisation mechanisms that make stablecoins distinct. The new framework fills that gap by introducing “Stablecoin Issuance Service” as a separately regulated activity under the PS Act.

The framework’s primary objective is value stability. MAS recognises that stablecoins, when properly backed and regulated, can function as a reliable medium of exchange for on-chain transactions. The SCS framework establishes the conditions under which that reliability can be verified and publicly labelled.

Scope and Applicability: Who Does It Cover?

The framework applies to single-currency stablecoins pegged to the Singapore Dollar (SGD) or any G10 currency — which includes the US Dollar, Euro, British Pound Sterling, Japanese Yen, Canadian Dollar, Australian Dollar, New Zealand Dollar, Norwegian Krone, Swedish Krona, and Swiss Franc — that are issued in Singapore.

Not every issuer falls within the mandatory scope. The key threshold and category rules are:

• Non-bank issuers above S$5 million circulation: Must obtain a Major Payment Institution (MPI) licence to conduct “Stablecoin Issuance Service” and comply with the full SCS framework.
• Non-bank issuers below S$5 million circulation: Exempt from SCS framework requirements, though they remain subject to general DPT rules.
• Bank issuers: Banks are exempt from obtaining a separate PS Act licence for stablecoin issuance, but reserve-backed stablecoins issued by banks may be considered under the SCS framework if the bank designs them to equivalent standards.
• Tokenised bank liabilities: Currently excluded from the SCS framework. MAS has reserved the right to impose additional requirements on these instruments in the future.

Stablecoins pegged to non-G10 currencies, multi-asset baskets, or issued outside Singapore remain under the existing DPT regime and are not prohibited. Eligibility for the MAS-regulated label is still centred on Singapore issuance. The September 2026 consultation proposes limited recognition of foreign-issued tokens supervised under comparable regimes, and of jointly issued Singapore/foreign tokens. That proposal is not yet law.

Reserve Asset Requirements

Reserve requirements are the cornerstone of the SCS framework. The rules are prescriptive across four dimensions: composition, valuation, segregation and custody, and independent attestation.

Composition

Reserve assets must be denominated in the same currency as the stablecoin’s peg. Permitted instruments are restricted to low-risk, highly liquid assets:

• Cash and cash equivalents
• Debt securities with a residual maturity of up to three months, issued by the government or central bank of the pegged currency
• Debt securities issued by organisations that are both governmental and international in character, with a minimum credit rating of “AA-“

Valuation

Reserve assets must be valued on a mark-to-market basis daily. At all times, the total value of reserve assets must be at least equivalent to the par value of all SCS in circulation — in other words, a 100% backing requirement with no fractional reserve approach permitted.

Segregation and Custody

Reserve assets must be held in segregated accounts on trust, entirely separate from the issuer’s own operational funds. Permitted custodians are:

• Financial institutions licensed by MAS in Singapore to provide custodial services
• Overseas-based custodians with a minimum credit rating of “A-” that maintain a Singapore branch regulated by MAS for custodial services

Independent Attestation and Audit

Issuers must obtain independent attestation of reserve assets on a monthly basis. Each attestation report must be disclosed on the issuer’s website and submitted to MAS. In addition, an annual independent audit of reserve assets is required, with the report submitted to MAS. This combination of monthly public disclosure and annual regulatory submission creates a continuous accountability mechanism.

Redemption at Par

SCS holders have a direct legal right to redeem their stablecoins at par value. Issuers must process redemption requests within five business days. Redemption must be available at any time — there is no restriction on when holders may submit a request.

Any redemption conditions an issuer wishes to impose must be reasonable and disclosed upfront. The five-business-day window is intended to give issuers enough time to liquidate reserve assets in an orderly manner, particularly under stress conditions, while still providing users with a reliable exit timeline.

In exceptional circumstances — such as periods of significant market stress — MAS may direct an issuer to liquidate reserve assets within a specific period to meet redemption demand. Under normal operating conditions, MAS expects redemption to be completed without unnecessary delay. The redemption obligation at this stage applies only to parties redeeming directly with the issuer, not through intermediaries.

It is also worth noting that MAS-regulated SCS are not deposits and do not qualify as insured deposits under Singapore’s deposit insurance framework.

Prudential Requirements: Capital and Solvency

Beyond reserve backing, the framework imposes standalone prudential requirements on SCS issuers designed to protect against insolvency and enable orderly wind-down if the business fails.

Base capital: An issuer must hold the higher of S$1 million or 50% of its annual operating expenses as base capital at all times.

Solvency buffer: In addition to base capital, issuers must hold liquid assets — including cash, cash equivalents, government debentures, negotiable certificates of deposit, and money market funds — valued at the higher of 50% of annual operating expenses or an amount the issuer independently assesses as sufficient to achieve recovery or an orderly wind-down. This assessment is subject to independent audit at least annually.

Business activity restrictions: An SCS issuer is prohibited from conducting activities that introduce additional risk to its balance sheet. Specifically, issuers may not:

• Invest in or extend loans to other companies
• Lend or stake the SCS or any other DPTs
• Trade DPTs
• Hold a stake in any other entity

These restrictions ring-fence the issuer entity. Related activities — such as DPT trading or investment — can still be conducted through a separate entity (for example, a sister company in which the SCS issuer holds no stake). The SCS issuer may, however, continue to carry out necessary operational activities such as custody of its own issued SCS and facilitating transfers to buyers.

MAS also proposes to prohibit issuers from paying interest or other benefits tied to holdings of MAS-regulated stablecoins. The policy intent is that regulated SCS function as payment instruments, not investment products.

Disclosure Obligations and Whitepaper Issuance

Transparency is a core pillar of the SCS framework. Issuers must provide users with sufficient information to understand the nature of the stablecoin, the risks involved, and their rights as holders. The primary vehicle for this is a mandatory whitepaper.

The whitepaper must include, at a minimum:

• General issuer information: Corporate details, governance structure, and ownership
• SCS operations: How the stablecoin functions, its value-stabilisation mechanism, and the technology stack it relies on
• Risk disclosures: A clear description of risks arising from using or holding the SCS
• Holder rights and obligations: Redemption rights, conditions attached to redemption, and any other legal obligations relevant to holders
• Reserve audit results: Published results of independent attestations and annual audits

The whitepaper is not a one-time document. Monthly reserve attestation reports must also be published on the issuer’s website and submitted to MAS. This means issuers must maintain a living disclosure programme rather than a static publication at launch.

AML/CFT and Technology Risk Obligations

SCS issuers are subject to the same anti-money laundering and countering the financing of terrorism (AML/CFT) standards that apply to DPT service providers and banks under Singapore law. These include customer due diligence (CDD), the travel rule for qualifying transfers, and screening obligations against sanctions and watchlists.

Technology and cyber risk management standards applicable to DPT service providers also apply to SCS issuers in full. For entities building compliance programmes from scratch, this is a substantive workstream that runs in parallel with the structural reserve and capital requirements. Issuers considering the Singapore pathway would benefit from integrating AML and compliance infrastructure at the application stage rather than retrofitting it after licensing.

Obligations for SCS Intermediaries

Entities that provide services around MAS-regulated SCS — without being issuers themselves — are treated as DPT service providers under the PS Act. This covers activities such as dealing in, facilitating the exchange of, or providing custody of SCS.

Key intermediary obligations include:

• Transfer timelines: DPT service providers must transmit MAS-regulated SCS from payer to payee within three business days — mirroring the domestic money transfer standard.
• Asset segregation: Intermediaries must segregate customers’ MAS-regulated SCS from their own assets. Commingling of one customer’s SCS with another customer’s assets in a pooled account is permitted, provided the pool remains separate from the intermediary’s own assets and customers are clearly informed of the arrangement and its risks.

The “MAS-Regulated Stablecoin” Label

The “MAS-regulated stablecoin” designation is not automatic. Issuers must apply to MAS for the label after demonstrating full compliance with the SCS framework. The label serves as a public signal that the stablecoin meets MAS’s value stability, reserve, capital, and disclosure standards — distinguishing it from stablecoins that operate only under the general DPT regime.

Misrepresenting a token as an “MAS-regulated stablecoin” without meeting the requirements carries penalties under the framework and can result in the issuer being placed on MAS’s Investor Alert List. This enforcement mechanism underscores that the label is a regulated claim, not a marketing description.

Implementation Status and Next Steps

MAS finalised the SCS framework in August 2023 and began implementing broader Payment Services Act amendments from April 2024 onwards, including enhanced DPT protection rules that took effect in October 2024. On 1 September 2026, MAS published consultation P015-2026 on proposed amendments to the Payment Services Act 2019 to give the SCS framework statutory force. The consultation closes on 16 October 2026. No commencement date has been announced.

MAS has encouraged prospective SCS issuers who want their stablecoins recognised as “MAS-regulated stablecoins” to engage proactively with the regulator ahead of the legislative implementation. For entities already holding or applying for a Major Payment Institution licence under the PS Act, the SCS requirements layer onto existing DPT obligations rather than replacing them.

What This Means for Prospective Issuers

For founders and legal counsel evaluating Singapore as a stablecoin issuance base, the SCS framework sets a clear — and demanding — baseline. The reserve, capital, and disclosure requirements are substantive. The business activity restrictions require careful corporate structuring, especially for groups that intend to combine stablecoin issuance with trading, lending, or investment activities in related entities.

Issuers targeting the MAS-regulated label should still structure issuance from Singapore. Cross-border or jointly issued structures should not be treated as available until the 2026 consultation is finalised.

From a licensing perspective, non-bank issuers crossing the S$5 million circulation threshold must hold an MPI licence. For entities that have not yet obtained payment services licensing in Singapore, this means the stablecoin issuance pathway runs through the MPI application process — which itself involves capital, fit-and-proper, AML programme, and technology risk requirements. Our Crypto and VASP licensing practice covers the full MPI application process for digital asset businesses, including stablecoin issuers. More broadly, entities evaluating where to incorporate and structure their issuing entity should consider a dedicated jurisdiction advisory engagement to map Singapore’s requirements against alternatives such as the UAE, EU (under MiCA), or Hong Kong.

Final Observations

The MAS SCS framework is one of the more detailed and operationally specific stablecoin regimes in Asia. Its requirements — 100% reserve backing in prescribed assets, daily mark-to-market valuation, monthly public attestations, par-value redemption within five business days, and strict business activity restrictions — leave little room for issuer discretion on the core stability mechanics.

What the framework does provide is regulatory clarity and a credible public label that can meaningfully differentiate a Singapore-issued stablecoin in the market. For issuers willing to meet the standard, the “MAS-regulated stablecoin” designation represents a verifiable trust signal in a market where user confidence in stablecoin backing remains a key concern.

The path to that designation requires concurrent work on corporate structure, MPI licensing, reserve infrastructure, AML and technology controls, and ongoing disclosure. Until the PS Act amendments commence, the MAS-regulated label is not an available licence class. Starting each of these workstreams in parallel — rather than sequentially — is generally the more efficient way to move from concept to compliant issuance in Singapore.