On 1 September 2026, the Monetary Authority of Singapore opened a public consultation on draft legislative amendments to the Payment Services Act 2019 that would, for the first time, write Singapore’s stablecoin regulatory framework into the statute book. The consultation closes on 16 October 2026. Nothing in it is settled law yet, and MAS has said it will consult separately on the accompanying subsidiary legislation, the part that will carry much of the fine detail on reserve composition and redemption timeframes, at a later date.
For most Singapore business owners this will read like a niche fintech development. It is not niche for everyone. If your fund vehicle, family office or corporate treasury holds, transacts in, or is thinking about accepting payment tokens (what most people simply call crypto or stablecoins), the direction MAS is signalling matters now, well before any of it becomes law. This article sets out what is actually being proposed, who among Singapore’s fund, VCC and family office community should be paying attention, and what a sensible “watch and prepare” posture looks like while the consultation is still open.
We deal with this as a live regulatory process, not a finished rulebook. Where MAS has carried over a position it already finalised in 2023, we say so. Where it is proposing something genuinely new, we flag that too, because the two categories carry different levels of certainty.
Background: How We Got Here
MAS first consulted on a regulatory approach for stablecoin-related activities in October 2022, then finalised its policy positions in a consultation response published in August 2023. That 2023 response set the core architecture: full reserve backing, redemption rights, and a restriction to single-currency stablecoins. What has been missing since then is the legislative machinery to actually bring it into force, machinery that industry had expected as early as the fourth quarter of 2025.
The 1 September 2026 consultation paper finally supplies that machinery, in the form of draft amendments to the Payment Services Act 2019. It does two things at once: it legislates the positions MAS already settled in 2023, and it opens a fresh round of consultation on a number of new policy proposals that respond to how the stablecoin market and overseas regulation have moved on since then. Read the full announcement on MAS’s media release if you want the primary source rather than our summary of it.
The Core Requirements Being Carried Into Law
The requirements below are not new. They were finalised in principle back in 2023. What changes now is that they move from stated MAS policy into enforceable statute, with criminal penalties attached to entities that hold themselves out as “MAS-regulated” without the licence to back it up.
100 Per Cent Reserve Backing, At All Times
An issuer of an MAS-regulated single-currency stablecoin (SCS) must hold reserve assets at least equal to the par value of the stablecoins it has in circulation, valued on a marked-to-market basis, continuously rather than as a periodic snapshot. Under the draft legislation this requirement now appears on the face of the Act itself, together with attestation and audit obligations, and the reserves must sit in segregated trust accounts with permitted custodians rather than commingled with the issuer’s own working capital.
Redemption at Par Within Five Business Days
Holders of an MAS-regulated stablecoin who redeem directly with the issuer are entitled to receive the par value of their holding, in the pegged currency or an equivalent, within five business days of a legitimate redemption request. This was the standard MAS set out in its 2023 policy response, and the current consultation is the vehicle for turning that timeline from guidance into a statutory obligation, with the precise operational detail expected to follow in subsidiary legislation.
Restricted to Singapore Dollar or G10 Currency Pegs
The MAS-regulated stablecoin label is only available to single-currency stablecoins pegged to the Singapore dollar or to a G10 currency. Stablecoins pegged to other currencies, algorithmic stablecoins with no reserve backing, and multi-currency tokens fall outside the MAS-regulated category altogether. They do not become illegal; they simply continue to be treated as ordinary digital payment tokens (DPTs) under the existing DPT licensing regime, without the “MAS-regulated” badge and without the consumer protections that come with it.
What Else Is New in the September 2026 Package
Beyond legislating the 2023 positions, MAS is using this consultation to test several genuinely new ideas. None of these are decided. They matter because they show where the regulatory perimeter is likely to move, and because several would directly affect how a Singapore fund or family office structures any exposure to payment tokens.
| Proposal | What it would do | Status |
|---|---|---|
| Interest prohibition | Bars MAS-regulated stablecoin issuers from paying interest or other returns to holders, to keep stablecoins positioned as payment instruments rather than investment products | New proposal |
| Quarterly stress testing | Requires issuers to stress test reserves and operations at least quarterly, with board-level review and results shared with MAS | New proposal |
| Recovery and wind-down plans | Requires board-approved recovery and orderly wind-down plans, reviewed at least annually and independently verified | New proposal |
| Multi-jurisdictional issuance | Would allow, on a case-by-case exemption basis, the same stablecoin to be co-issued out of Singapore and a foreign jurisdiction sharing a reserve pool, reversing the 2023 position | New proposal |
| Recognition of foreign-issued stablecoins | Would let MAS recognise a limited number of foreign-regulated stablecoins for use in Singapore, distinct from the “MAS-regulated” label | New proposal |
| Systemic stablecoin designation | Gives MAS power to designate any stablecoin, wherever issued, as systemically important and subject to enhanced requirements | New proposal |
Notice the throughline: MAS is not simply importing a 2023 framework unchanged. It is responding to a genuinely global wave of stablecoin legislation, including the United States’ GENIUS Act, the European Union’s MiCA regime, the United Kingdom’s stablecoin rules, and Hong Kong’s Stablecoins Ordinance, all of which have moved since 2023. Singapore’s approach still differs from most of these in one respect: it remains an opt-in labelling regime. A stablecoin that never seeks the “MAS-regulated” badge can continue to circulate as an ordinary DPT, subject to the existing DPT licensing rules our earlier walkthrough of MAS Digital Payment Token licensing covers in detail.
Consultation Timeline: What Happens Next
The key dates worth diarising are straightforward:
- 1 September 2026: Consultation paper published, alongside draft legislative amendments to the Payment Services Act 2019
- 16 October 2026: Consultation closes; this is the deadline for submissions
- To be announced: Subsidiary legislation, covering reserve composition detail, exact redemption mechanics, stress testing parameters and recognition conditions, to be consulted on separately
- Not yet set: A timeline for the amendments to actually be enacted and take effect
In practical terms this means nothing changes for anyone today. What it does mean is that any structure being set up now, or any treasury policy being drafted now, that anticipates holding or dealing in payment tokens should be built with an eye on where this framework is heading, not just where it currently sits. You can read the underlying statute that is being amended on Singapore Statutes Online if you want to see exactly which provisions of the Payment Services Act 2019 the draft amendments touch.
Who Among Singapore Fund and Family Office Structures Should Care
VCCs and Section 13O/13U Funds With Payment-Token Exposure
Variable Capital Companies and funds relying on the Section 13O or 13U tax incentive schemes are not, in themselves, stablecoin issuers, and nothing in this consultation licenses a fund vehicle to issue tokens. What does matter is exposure on the asset side: a fund holding stablecoins as part of its cash management or as a settlement instrument for digital asset trades needs to understand whether the coin it holds will ultimately sit inside or outside the “MAS-regulated” perimeter, because that affects counterparty risk, valuation practice and disclosure to investors. Fund managers structuring under the framework our guide to the MAS streamlined fund manager framework covers should also note that stablecoin exposure sits alongside, not instead of, their existing licensing analysis. Funds relying on the Section 13D offshore fund exemption should likewise revisit our Section 13D offshore fund scheme FAQ, since the tax treatment of any payment-token gains sits on top of, and does not override, the underlying scheme conditions.
Family Offices With Digital Asset Allocations
Single family offices that have added a digital asset sleeve, whether directly or through a fund, should treat this consultation as an early signal rather than a compliance deadline. If your family office structure was set up under the process our Single Family Office (SFO) setup FAQ describes, and the underlying fund entity carries any stablecoin or payment-token position, it is worth asking your fund administrator now which coins in the portfolio would qualify as MAS-regulated stablecoins under the proposed definitions, and which would remain ordinary DPTs. That answer will shape how conservatively the position should be valued and disclosed pending the framework’s finalisation.
Fund Managers and Corporates Using Stablecoins for Settlement
A smaller but growing group of RCS clients use stablecoins operationally, for example to settle cross-border invoices or manage working capital between related entities, rather than as an investment position. For this group the interest prohibition and the redemption-at-par timeline are the two provisions worth watching most closely, since they directly affect whether a given stablecoin can sensibly be used as a working-capital instrument at all. Groups already registered for GST that route payment-token transactions through a Singapore fund vehicle should also keep an eye on how any GST treatment interacts with existing rules; our note on GST remission for Singapore funds and the fixed recovery rate is a useful starting point for understanding how the current GST mechanics work, pending any consequential guidance MAS or IRAS may issue alongside the finalised stablecoin framework.
Practical Steps While the Consultation Is Still Open
Because nothing here is final, the sensible response is preparation rather than restructuring. A few concrete steps for affected clients:
- Map any existing payment-token holdings against the proposed SGD/G10 peg restriction, so you know today which of your positions would and would not qualify as MAS-regulated stablecoins if the framework passed unchanged.
- Flag any arrangement that currently pays or receives interest on a stablecoin holding, since the proposed interest prohibition would require that arrangement to be unwound or restructured if the coin in question becomes MAS-regulated.
- Review treasury and settlement policies that assume same-day or next-day redemption, and stress test them against a five-business-day redemption window.
- Consider whether your fund, VCC or family office structure should make a submission to the consultation before it closes on 16 October 2026; MAS explicitly invites views from market participants, not just prospective issuers.
- Hold off on any irreversible structuring decision that depends on a specific reading of the draft provisions until the subsidiary legislation is published, since MAS has said the operational detail on redemption timeframes and reserve composition will follow separately.
None of this requires urgent action by 16 October 2026 unless you intend to respond to the consultation itself. It does mean that funds, VCCs and family offices with genuine payment-token exposure should have this on their radar as a live watch item for the rest of 2026 and into 2027.
Conclusion
Singapore’s stablecoin framework has been “finalised in policy” since August 2023 and “law” only from 1 September 2026 onward, and even now it remains a consultation, not an enacted statute. For the ordinary Singapore SME this changes nothing. For fund managers, VCCs and family offices with any payment-token exposure, it is worth understanding now what MAS is proposing, rather than waiting for the framework to be finalised and discovering an existing arrangement no longer fits.
If your fund, VCC or family office structure holds or transacts in stablecoins or other digital payment tokens, and you want a clear-eyed read on how the proposed framework might affect your structure, speak with Raffles Corporate Services. We help Singapore fund vehicles, VCCs and family offices stay ahead of regulatory change rather than scrambling to react to it.
The Editorial Team, Raffles Corporate Services