MAS Digital Payment Token (DPT) licensing — Timeline and processing benchmarks
Published on: 12 Jul, 2026

MAS Digital Payment Token (DPT) licensing — Timeline and processing benchmarks

Raffles Corporate Services works with a panel of corporate and employment law firms; this article is general information, not legal advice.

MAS Digital Payment Token (DPT) licensing is the Monetary Authority of Singapore’s authorisation regime for firms dealing in or facilitating the exchange of digital payment tokens. In practice, a straightforward application takes about 4 to 12 months from submission to grant, with base capital and AML/CFT readiness the main gating factors.

Understanding Mas digital payment token

The sections below break down mas digital payment token step by step, covering what it is, who it applies to, the numbers that matter, the process, and the mistakes practitioners see most often.

What a MAS Digital Payment Token licence is

A Digital Payment Token service is a licensable payment service under the Payment Services Act 2019, which consolidated payments regulation in Singapore into a single activity-based framework. A firm that deals in DPTs, or facilitates the exchange of DPTs, ordinarily needs a payment institution licence unless a specific exemption applies. Section 5 of the Payment Services Act 2019 establishes that no person may carry on a business of providing a payment service in Singapore unless licensed or exempt.

DPT services sit alongside the other payment services in the Act, and most token businesses apply for the Major Payment Institution (MPI) class because DPT flows are not subject to the same transaction thresholds that separate a Standard Payment Institution from an MPI for other services.

For a related perspective, see VCC Act 2018 — Section 17 legal personality — Costs and fees breakdown.

Who needs to apply

The regime captures centralised exchanges, over-the-counter desks, custodial wallet providers that move tokens on a customer’s instruction, and firms that facilitate token transfers. Wealth managers and family offices that merely hold tokens as principal for their own account generally fall outside the licensable perimeter, but the analysis is fact-specific and turns on whether a service is being provided to third parties.

Firms structuring a token venture alongside a fund vehicle should map the regulated activity carefully before incorporation, because the licence applicant, its controllers and its permanent place of business must all be established in Singapore.

See also our guide on MAS Digital Payment Token (DPT) licensing — Costs and fees breakdown.

Eligibility and key requirements

An applicant must be a Singapore-incorporated company (or a foreign corporation registered here) with a permanent place of business, at least one executive director resident in Singapore, and a fit-and-proper board and senior management. MAS expects a credible anti-money-laundering and countering-the-financing-of-terrorism (AML/CFT) framework, a compliance function, technology risk controls, and a clear safeguarding arrangement for customer money and assets.

DPT service providers are also subject to enhanced consumer-protection measures introduced from 2023 to 2024, including restrictions on offering incentives to retail customers and requirements to segregate customer assets.

Related reading: Singapore bank account opening — DBS, OCBC, UOB, Wise, Aspire — Timeline and processing benchmarks.

Cost and timeline benchmarks

See the numerical block below. As a planning rule, budget two to three months to assemble a submission-ready application and a further four to twelve months for MAS review, longer where the business model is novel or the ownership chain is complex.

The application process step by step

The typical path runs: (1) scope the regulated activity and confirm the licence class; (2) incorporate and capitalise the applicant; (3) build the compliance, AML/CFT and technology-risk frameworks; (4) appoint an external auditor and, where required, an independent assessor; (5) submit the application through MAS’s online portal with the prescribed forms and supporting documents; (6) respond to MAS queries; and (7) satisfy pre-grant conditions such as base capital confirmation and key-appointment approvals.

Common mistakes and gotchas

The most frequent causes of delay are an under-resourced compliance function, a safeguarding arrangement that has not been agreed with a bank or custodian, and a controller who cannot satisfy the fit-and-proper test. Applicants also underestimate the technology-risk-management expectations, which MAS assesses against its published guidelines. Submitting before the AML/CFT policy is operational, rather than merely drafted, is a common misstep.

Documents and information you will need

A DPT licence application is document-heavy. MAS expects a detailed business plan, a description of the DPT services and token flows, group and ownership charts down to the ultimate beneficial owners, curricula vitae and fit-and-proper declarations for directors and key personnel, audited or management financial statements, and evidence of base capital. Applicants must also submit their AML/CFT policies and procedures, a technology-risk-management framework, a business-continuity plan, and details of the proposed safeguarding arrangement for customer money and tokens. Preparing these in parallel, rather than sequentially, is the single most effective way to compress the overall timeline. Incomplete or inconsistent submissions are the most common reason MAS issues extensive queries, each of which can add weeks to the assessment.

How the timeline breaks down in practice

In practice the clock has three phases. The first is preparation, typically two to three months, spent incorporating, capitalising, hiring compliance staff and drafting the frameworks. The second is the MAS assessment, during which the regulator reviews the submission, issues written queries and may meet management; this is where most of the elapsed time sits and where novelty and complexity extend the schedule. The third is the pre-grant conditions phase, where the applicant confirms base capital, finalises safeguarding arrangements and secures key-appointment approvals. Firms that treat the application as live only from submission underestimate the front-loaded preparation effort that determines how smoothly the assessment runs.

Ongoing obligations after you are licensed

A licence is the beginning, not the end, of the compliance journey. DPT service providers must maintain base capital, safeguard customer assets, file periodic regulatory returns, submit to annual audit, and keep their AML/CFT programme current as MAS guidance evolves. The consumer-protection measures introduced from 2023 to 2024 impose additional conduct obligations toward retail customers. Boards should schedule regular compliance reviews and ensure the technology-risk framework keeps pace with the firm’s growth, because supervisory expectations rise with transaction volumes and customer numbers.

How Raffles Corporate Services can help

Raffles Corporate Services supports applicants with incorporation, corporate secretarial set-up, and coordination with the panel of law firms and compliance specialists who prepare licensing submissions. Early structuring advice, before the applicant is incorporated, often saves months later by ensuring the corporate vehicle, ownership chain and governance are licence-ready from day one.

Fees, capital and timelines at a glance

  • Application fee: payable per payment service under the Payment Services Regulations; confirm the current DPT-service fee against the MAS fee schedule before filing.
  • Base capital (MPI): S$250,000.
  • Base capital (SPI): S$100,000.
  • Realistic timeline: 2 to 3 months to prepare, 4 to 12 months for MAS assessment.
  • Annual ongoing: audit, compliance staffing and MAS annual fees.

Figures are indicative for planning; the prevailing statutory fees are those published by MAS at the time of filing.

Official sources

FAQs

Is a DPT licence the same as a Capital Markets Services licence?
No. A DPT licence is granted under the Payment Services Act 2019. A Capital Markets Services licence is granted under the Securities and Futures Act 2001 and applies to regulated capital-markets activities such as fund management.

Can a foreign-owned company apply?
Yes, provided the applicant is incorporated or registered in Singapore, has a permanent place of business here and at least one Singapore-resident executive director.

How long does MAS take?
MAS does not guarantee a fixed timeline. Straightforward cases are often assessed within four to six months; complex or novel models can take a year or more.

What ongoing obligations apply after grant?
Continuing AML/CFT compliance, safeguarding of customer assets, periodic reporting, annual audit and maintenance of base capital.

Related guides

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.