A practical guide to Singapore's digital bank licence types — DFB and DWB — covering eligibility criteria, capital thresholds, deposit rules, and regulatory obligations under MAS.

Singapore’s digital bank licensing framework, introduced by the Monetary Authority of Singapore (MAS) in 2019, opened formal banking to non-bank entities for the first time. The framework created two distinct licence categories: the Digital Full Bank (DFB) and the Digital Wholesale Bank (DWB). Each carries its own eligibility criteria, capital thresholds, permitted activities, and customer-access rules.

This article is written for founders, legal counsel, and compliance officers who need a precise, current-state picture of what each licence type requires — from baseline eligibility through capital obligations and ongoing regulatory duties. It also covers what the existing licensees reveal about MAS’s evaluation priorities, and where the framework currently stands.

What Is a Digital Bank Licence in Singapore?

A digital bank licence allows a non-bank entity to operate a bank in Singapore without a physical branch network. All customer-facing services are delivered digitally — through web platforms and mobile applications. Unlike a traditional bank licence, this framework was specifically structured to enable technology and e-commerce companies to enter banking, provided they meet defined capital, governance, and operational standards set by MAS.

The framework sits within Singapore’s broader Banking Act. DFBs receive a full bank licence; DWBs receive a wholesale bank licence. In both cases, the same substantive obligations that apply to their traditional equivalents apply from the point of authorisation.

DFB vs DWB: Key Differences at a Glance

The two licence types differ primarily on customer scope and permitted deposit-taking. The table below summarises the structural differences:

Digital Full Bank (DFB): Eligibility, Capital, and Operating Phases

A DFB licence gives the holder the same banking powers as a traditional full bank in Singapore. It can take deposits from and provide the full suite of banking services to the public, including individual retail customers. Because retail deposits introduce systemic risk, MAS built a mandatory two-stage progression into the DFB framework rather than granting full powers at the point of authorisation.

Stage 1: Restricted DFB

Every new DFB begins as a Restricted DFB. This stage is explicitly not optional — all DFBs must pass through it, and MAS assesses each institution before approving any step up. MAS expects the restricted phase to last approximately one to two years at entry, with the full transition to a functioning DFB estimated at three to five years from the commencement of operations.

During the restricted phase, the following constraints apply:

• Minimum paid-up capital: S$15 million at entry.
• Aggregate deposit cap: S$50 million across all depositors.
• Individual deposit cap: S$75,000 per depositor.
• Depositor pool: Limited to shareholders, employees, related entities, and persons familiar with the DFB’s parent or major shareholders.
• Physical presence: No more than one physical place of business.

As the restricted DFB grows and demonstrates sound governance, MAS allows the deposit cap to increase. The paid-up capital requirement and the aggregate deposit cap scale together at a ratio of 1:4 — for every S$1 increase in paid-up capital, the aggregate deposit cap rises by S$4. This mechanism ties capital adequacy directly to deposit exposure.

During annual reviews, MAS assesses the restricted DFB on factors including:

• Strength of internal controls
• Frequency and type of compliance breaches
• Customer complaint volume and handling
• Sustainability of business performance
• Auditor’s assessment of financials and internal controls

Stage 2: Full Functioning DFB

Once the Restricted DFB has met all relevant milestones and is assessed to pose no significant supervisory concerns, MAS lifts all deposit caps. At that point, the bank is required to meet the minimum paid-up capital requirement of S$1.5 billion. MAS evaluates readiness based on the bank’s business and financial performance, loan quality, risk management maturity, and compliance track record.

A full functioning DFB can then provide the complete range of banking services to the public with no restrictions on the customer pool or deposit volumes.

Digital Wholesale Bank (DWB): Eligibility, Capital, and Permitted Activities

A DWB operates under a wholesale bank licence and is restricted to serving SMEs and corporate customers. There is no restricted phase for a DWB — the full capital and governance requirements apply from the moment the licence is activated.

Key structural features of a DWB:

• Minimum paid-up capital: S$100 million (required at the point of entry and on an ongoing basis).
• No deposit cap: Unlike the DFB’s restricted phase, there is no ceiling on the aggregate deposits a DWB can hold.
• Customer base: SMEs and corporate entities. Retail customers are generally not permitted. MAS may allow limited retail-facing activities on an exceptional basis if the applicant justifies the connection to its core wholesale banking services during the application stage.
• Business scope: Defined by the activities proposed in the original application. After two to three years, a DWB may apply to MAS for approval to expand its business scope.
• Corporate governance: At least five board directors, with a majority comprising independent directors. Where a single substantial shareholder holds more than 50% of shares, at least one-third of the board must be independent directors.
• Overseas expansion: Under the Banking Act, MAS approval is required before a DWB can open any branch, agency, or office outside Singapore.

DWBs are subject to the same regulatory requirements as existing wholesale banks. This includes risk-based capital adequacy requirements, liquidity requirements, technology risk obligations, and AML/CFT controls.

Eligibility Criteria That Apply to Both Licence Types

Whether applying for a DFB or DWB licence, all applicants must satisfy a common set of baseline criteria. For the purposes of this framework, the “applicant group” means the entity that will hold the digital bank licence and every one of its 20% controllers.

1. Technology or e-commerce track record
At least one entity in the applicant group must have three or more years of operating history in the technology or e-commerce field. This criterion excludes pure financial services firms without a credible technology or platform background.

2. Fit and proper standard
The following individuals and entities must satisfy the MAS Guidelines on Fit and Proper Criteria:

• The applicant group and their directors
• Substantial shareholders, and any controller holding 12% or more of issued shares or 12% or more of voting power in the proposed digital bank
• Directors and executive officers of the proposed digital bank

3. Capital commitment
Applicants must demonstrate the ability to meet the applicable minimum paid-up capital at the onset and maintain the minimum capital funds requirement on an ongoing basis. This is evidenced by a written confirmation from shareholders committing the required funds. For DFB applicants specifically, MAS expects a credible plan for building up to S$1.5 billion in capital, even if the entry threshold is S$15 million.

4. Incorporation and control requirements

• DWBs must be incorporated in Singapore.
• DFBs must be anchored in Singapore, controlled by Singaporeans, and headquartered in Singapore.

MAS assesses whether a DFB is “anchored in Singapore” based on the following factors:

• The DFB and its parent entity publicly identify Singapore as their home country
• The parent entity’s global head office is in Singapore
• Effective management of both the DFB and its parent entity is situated in Singapore
• If there is no parent entity, the shareholder with the largest shareholding and effective control is a Singaporean individual or entity meeting the above conditions

Changes to shareholding structure that affect Singaporean control can result in revocation of any in-principle approval already issued by MAS. This makes the control structure a live compliance concern, not merely an application-stage formality.

5. Shareholder commitments
Shareholders of the proposed digital bank must commit to providing a letter of responsibility and a letter of undertaking as MAS may require concerning the bank’s operations.

How MAS Evaluates Applications

Satisfying the eligibility criteria establishes baseline qualification. MAS then applies a merit-based selection assessment. Applications are evaluated on three primary dimensions:

• Value proposition: Whether the applicant has a clear proposition incorporating innovative use of technology to serve customer needs and reach under-served segments of the Singapore market.
• Prudence and sustainability: Whether the business model is financially sound and operationally sustainable. This includes a five-year financial projection with a demonstrated path to profitability, reviewed by an external independent expert.
• Contributions to Singapore’s financial centre: The applicant’s growth prospects and their broader contribution to Singapore’s position as a financial hub.

Applicants must also submit a credible exit plan — a documented set of scenarios and strategies for an orderly wind-down if the bank fails to sustain its operations. MAS treats this as a risk management requirement, not a formality.

Ongoing Regulatory Obligations

Once licensed, DFBs and DWBs are subject to the full regulatory framework applicable to their respective bank types. DFBs operate under the same obligations as existing full banks; DWBs under the same obligations as existing wholesale banks. These requirements are set out in the Banking Act and the associated MAS Notices and Guidelines.

Key ongoing obligations include:

• Capital adequacy: All digital banks must meet minimum paid-up capital requirements and risk-based capital adequacy requirements under MAS Notice 637 on an ongoing basis.
• AML and CFT: Digital banks must implement robust controls to detect and deter illicit financial flows. This includes risk assessment systems, customer due diligence procedures, and record-keeping frameworks aligned with MAS Notice 626.
• Technology risk management: Banks must adhere to MAS’s Technology Risk Management Guidelines, covering IT and cyber resilience, governance of technology risk, and incident response.
• Outsourcing: Any outsourcing of business functions must comply with the MAS Guidelines on Outsourcing, including a framework for assessing outsourcing risks and a documented approval process.
• Liquidity requirements: Risk-based liquidity requirements apply continuously alongside capital obligations.

Digital banks that intend to carry out capital markets activities or financial advisory services must also satisfy the relevant requirements under the Securities and Futures Act and the Financial Advisers Act respectively. These include product suitability obligations, custody requirements, and monthly statement disclosure rules.

For a detailed discussion of AML programme requirements and compliance frameworks applicable to Singapore financial institutions, see GSS Legal’s AML and Compliance services.

Current Licence Status and Existing Licensees

MAS issued four digital bank licences in December 2020 and is not currently granting new licences. The four licensees are:

• GXS Bank (Grab–Singtel consortium) — Digital Full Bank, licensed November 2021
• MariBank (Sea Limited) — Digital Full Bank, licensed December 2021
• ANEXT Bank (Ant Group) — Digital Wholesale Bank, licensed December 2021
• Green Link Digital Bank (Greenland Financial Holdings consortium) — Digital Wholesale Bank, licensed December 2021

A fifth digital bank, Trust Bank, operates as a digitally native bank but does so under the existing full bank licence held by Standard Chartered Bank — it did not require a separate digital bank licence under this framework.

As of FY2025, Green Link Digital Bank was the only licensed digital bank in Singapore to record a profit, at S$16.1 million. The DFBs and the other DWB continued to report operating losses, which is consistent with the capital-intensive build-out period MAS anticipated when designing the phased progression model. MAS indicated from the outset that it would assess a path to profitability rather than immediate profitability.

The framework remains closed to new applicants. Any future opening of new application rounds would require a fresh MAS policy decision and public announcement.

For organisations exploring financial institution licensing in Singapore across other regulated categories — including payment services, crypto and digital asset services, or fund management — the full range of GSS Legal’s licensing services covers the applicable frameworks. Organisations evaluating cross-jurisdictional strategies can also review jurisdiction-level guidance to compare Singapore’s requirements against other regulatory environments.

Summary: What Decision-Makers Need to Know

Singapore’s digital bank licensing framework is structured, demanding, and deliberately slow-moving. The DFB route requires Singaporean control, a phased capital build-up to S$1.5 billion, and a multi-year supervised progression before full public banking powers are granted. The DWB route requires S$100 million at entry, no phased restriction on deposits, but limits the institution to corporate and SME customers from the start.

MAS is not currently accepting new applications. Organisations monitoring the framework for future rounds — or assessing related Singapore financial licences in the payment services, digital asset, or capital markets space — should plan their regulatory strategy well in advance. The eligibility criteria, particularly the technology track record requirement, the Singaporean control rules for DFBs, and the capital commitment obligations, each require structural decisions that cannot be made at the application stage alone.