A person carrying on a business of providing digital payment token services in Singapore needs a licence under the Payment Services Act 2019 unless an exemption applies, and the correct licence class depends on transaction volume and the types of services offered.
Raffles Corporate Services works with a panel of corporate and employment law firms; this article is general information, not legal advice.
What is a DPT licence?
A Digital Payment Token (DPT) service, as defined in the First Schedule to the Payment Services Act 2019, covers dealing in digital payment tokens and facilitating the exchange of such tokens. Anyone carrying on this business in Singapore must be licensed unless they fall within a prescribed exemption, such as group treasury arrangements or activities the Monetary Authority of Singapore (MAS) has separately excluded by notice.
Who needs to apply?
Exchanges, custodial wallet providers, over-the-counter token desks and certain payment gateways that route digital payment tokens on behalf of customers typically fall within scope. Businesses that merely accept payment in fiat currency, or that use blockchain infrastructure without dealing in tokens as a service to third parties, are usually outside scope, but this line is fact-specific and worth confirming before committing to a business model.
Licence classes and thresholds
Section 6 of the Payment Services Act 2019 provides for three licence classes: money-changing, standard payment institution (SPI) and major payment institution (MPI). The class that applies to a DPT business depends on average monthly transaction value:
- Standard Payment Institution: average monthly transaction value up to S$3 million (single payment service) or S$6 million (combined), and does not hold more than S$5 million in customer e-money or equivalent at any time.
- Major Payment Institution: transaction volumes above the SPI thresholds, or where the applicant chooses to apply directly at MPI level.
Base capital requirements are S$100,000 for an SPI and S$250,000 for an MPI, with a security deposit or additional base capital layered on for DPT-specific risk.
Eligibility and requirements
Section 5(1) of the Payment Services Act 2019 requires a person to hold a licence before carrying on a business of providing a payment service, and licences are granted under section 6. Applicants must show a Singapore-incorporated entity (or registered branch), at least one executive director or CEO resident in Singapore, fit-and-proper directors and shareholders, and a permanent place of business in Singapore. MAS also expects a documented AML/CFT framework calibrated to DPT-specific risks such as source-of-funds verification for token transfers and travel-rule compliance for cross-border transactions.
Cost and timeline
Budget S$15,000 to S$40,000 in professional fees for a well-prepared SPI application (higher for MPI, given the deeper AML/CFT documentation), plus the statutory fees payable to MAS. Processing typically runs 6 to 12 months from a complete submission, longer if MAS raises queries on the AML/CFT framework or beneficial ownership structure.
Step-by-step process
- Confirm scope: map the proposed activities against the First Schedule DPT service definitions.
- Incorporate or restructure the Singapore entity, appoint a Singapore-resident director and secure a permanent place of business.
- Draft the AML/CFT policy, risk assessment and business plan.
- Lodge the application through MAS’s licensing portal with supporting documents on directors, shareholders and the compliance function.
- Respond to MAS queries and, where relevant, attend a licensing interview.
- On approval, complete pre-commencement conditions before going live.
Common mistakes and gotchas
Applicants frequently underestimate the AML/CFT documentation MAS expects for DPT-specific risks, submit generic policies copied from payment businesses that do not deal in tokens, or delay appointing a Singapore-resident compliance officer until after lodging the application. Each of these tends to add months to the review.
Related guides
For a comparison of licence types across the broader payment services regime, see our MAS Digital Payment Token (DPT) licensing: common mistakes and rejection reasons. Fund structures that hold digital assets alongside other strategies are increasingly set up as Variable Capital Companies; see Choose VCFM or A/I LFMC for a VCC Strategy for how a manager’s MAS licence class feeds into fund structuring. On the tax side, IRAS treats digital payment tokens as property rather than currency for most purposes; see Singapore Crypto Tax 2026: How IRAS Treats Digital Payment Tokens.
FAQs
Does a DPT licence let me also offer e-money or remittance services? Only if those services are separately listed on the same licence; each payment service in the First Schedule is licensed individually, though one licence can cover multiple services.
Can a foreign-incorporated exchange apply? The applicant must be a company incorporated in Singapore or a foreign company registered as a branch; a purely offshore entity cannot hold the licence directly.
What happens if I operate before approval? Providing a payment service without a licence or applicable exemption is an offence under the Payment Services Act 2019.
Is there a lighter-touch option for early-stage projects? MAS’s regulatory sandbox may allow limited live testing before full licensing, subject to conditions and a defined exit plan.
Do directors need to be Singapore citizens? No, but MAS expects at least one director or the CEO to be resident in Singapore, and all directors must meet fit-and-proper criteria.
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.