MAS Digital Payment Token (DPT) licensing — Documents required and templates
MAS Digital Payment Token (DPT) licensing is the regulatory approval a business needs from the Monetary Authority of Singapore before it can buy, sell, transfer or facilitate the exchange of cryptocurrencies and other digital payment tokens for customers in Singapore. This guide sets out the licence classes, the documents required, indicative timelines and the practical templates a wealth manager or fintech should prepare in 2026.
This article is general information and not legal advice. Raffles Corporate Services works with a panel of corporate and employment law firms.
What MAS Digital Payment Token (DPT) licensing covers
A digital payment token service is one of the payment services listed in the First Schedule to the Payment Services Act 2019. It captures dealing in DPTs, facilitating the exchange of DPTs, and (following later amendments) transferring DPTs, providing custodial wallet services and facilitating cross-border transfers. Section 6 of the Payment Services Act 2019 addresses the requirement to hold a licence before carrying on a business of providing a payment service in Singapore, so an operator cannot begin dealing in tokens until the licence is granted.
The regime is deliberately activity-based. Whether you run an exchange, an over-the-counter desk, a custodian or a token transfer rail, the same licensing gateway applies, and the Monetary Authority of Singapore assesses each applicant against anti-money-laundering, technology-risk and financial-soundness expectations.
Licence classes and who each is for
The Payment Services Act 2019 creates two institutional licence classes relevant to DPT businesses: the Standard Payment Institution (SPI) and the Major Payment Institution (MPI). The distinction turns on transaction volume. An SPI operates below the statutory thresholds (broadly S$3 million per month for any single payment service and S$6 million across two or more, with an e-money float cap), while an MPI has no volume cap but carries higher capital, audit and safeguarding obligations.
Most serious DPT operators apply directly for an MPI licence because token flows quickly exceed SPI thresholds. Base capital for an MPI is S$250,000, and MAS expects a security deposit and robust safeguarding of customer money and tokens. Family offices and fund managers that only deal in DPTs incidentally should take advice on whether their activity is caught at all.
Documents required for a DPT licence application
MAS expects a complete, well-evidenced application. The core pack includes: the online application form via the MAS portal; the company’s ACRA business profile and constitution; audited financial statements or opening projections; a detailed business plan with three-year financial forecasts; organisation and shareholding charts up to ultimate beneficial owners; fit-and-proper declarations for directors, the CEO and substantial shareholders; the compliance arrangement (AML/CFT policy, risk assessment and independent audit plan); technology-risk documentation; and evidence of base capital and the security deposit.
Practical templates worth preparing in advance are an enterprise-wide ML/TF risk assessment, a customer due-diligence and screening procedure, a travel-rule solution description, a business continuity plan and a board-approved outsourcing register. Our team maintains model versions of each so applicants are not drafting from a blank page.
Cost and timeline benchmarks
Budget realistically. The MAS application fee for a DPT payment service is S$10,000 per payment service applied for. Total first-year set-up, including legal, compliance build, external AML audit and technology attestations, commonly runs S$120,000 to S$350,000 depending on scope. Ongoing costs include an appointed compliance officer, annual audit and MAS periodic returns.
On timing, expect roughly 6 to 12 months from a complete submission to approval-in-principle, and sometimes longer where MAS raises multiple rounds of queries. A DPT business should not sign customer contracts or market services until the licence is in hand. For a related view of how licensed operators onboard with banks, see our companion guide on the MAS Payment Services Act licensing (MPI and SPI) document requirements.
Common mistakes and how to avoid them
The most frequent failures are a thin ML/TF risk assessment, a compliance officer who lacks Singapore experience, understated technology-risk controls, and marketing that begins before approval. MAS also scrutinises the source of funds for base capital and the substance of local management. Applicants who treat the compliance function as a box-ticking exercise are routinely sent back for rework.
Fund managers structuring token exposure alongside a fund vehicle should coordinate the licensing analysis with their fund manager framework; our note on the VCC Act 2018 permissible fund manager rules explains where the two regimes intersect. Foreign founders also need a Singapore operating entity first, which our guide to Singapore bank account opening for new companies supports.
Step-by-step process
- Confirm scope: map exactly which activities (dealing, exchange, custody, transfer) you will conduct against the First Schedule to the Payment Services Act 2019.
- Incorporate or confirm the Singapore operating entity and appoint local management, including a compliance officer with relevant experience.
- Build the compliance stack: enterprise ML/TF risk assessment, CDD and screening procedures, travel-rule solution, and technology-risk controls.
- Set aside base capital (S$250,000 for an MPI) and arrange the security deposit and safeguarding of customer money and tokens.
- Prepare and lodge the application via the MAS portal with the full document pack; pay the S$10,000 per-service application fee.
- Respond to MAS queries through review (typically 6 to 12 months) and complete any pre-conditions before approval.
- On grant, implement ongoing obligations: periodic returns, annual external AML audit and continuous monitoring.
FAQs
Do I need a DPT licence if I only accept crypto as payment for my own goods?
Generally no. Accepting DPTs as payment for your own products is not, by itself, providing a digital payment token service to third parties. But if you facilitate exchange, custody or transfer for customers, the licensing gateway is likely engaged and you should seek advice.
Can I operate under exemption while my application is pending?
Only if you fall within a specific transitional or statutory exemption. New entrants without an existing exemption must wait for the licence. Marketing or onboarding customers before approval is a common and serious compliance breach.
What is the minimum base capital for a DPT MPI licence?
The base capital for a Major Payment Institution is S$250,000, alongside a security deposit and MAS expectations on safeguarding customer money and tokens. An SPI has lower capital but is capped by transaction thresholds.
Need help with this? Call, SMS or WhatsApp +65 8501 7133, or email [email protected]. Raffles Corporate Services works with a panel of corporate and employment law firms; this article is general information, not legal advice.