Singapore VCC insights

Stablecoin Regulation Singapore: What MAS’s Proposed PS Act Changes Mean for Family Offices and VCCs

By VCC Editorial Team · Published 19 October 2026

Short answer: Singapore regulates stablecoin issuers and service providers, not holders. MAS finalised its single-currency stablecoin framework on 15 August 2023 and consulted from 1 September to 16 October 2026 on Payment Services Act 2019 amendments to give it legal effect. Family offices and VCCs are affected indirectly through custodian choice, valuation, AML/CFT and CARF reporting.

This article is general information only and is not legal, tax or investment advice. For matters needing legal advice, we work with a panel of experienced Singapore law firms.

Stablecoin regulation in Singapore is moving from policy to statute. Single family offices (SFOs) and variable capital companies (VCCs) that hold stablecoins for settlement or liquidity need to know which coins, counterparties and controls will satisfy a bank, an auditor and the Inland Revenue Authority of Singapore (IRAS) once the new regime takes effect. We checked every source cited here on 19 October 2026. Anything that is still a proposal is labelled as one.

What does stablecoin regulation in Singapore cover today?

Today the Monetary Authority of Singapore (MAS) regulates stablecoins mainly as digital payment tokens under the Payment Services Act 2019, and it has a finalised stablecoin issuer framework waiting to be put into law. Holders are not licensed. Regulation sits with the businesses that issue, exchange, transfer or safeguard tokens.

Two layers apply. The first is the existing DPT regime. MAS lists the digital payment token service as one of seven regulated payment services: buying or selling DPTs, operating a platform to exchange them, transmitting them, providing custodian wallet services and actively facilitating DPT trades without holding the money or tokens. A provider of these services in Singapore must hold a licence unless exempted.

The second layer is the single-currency stablecoin framework that MAS finalised on 15 August 2023. It applies to single-currency stablecoins issued in Singapore and pegged to the Singapore dollar or a G10 currency. Issuers must meet requirements on four things:

• Value stability: reserve assets must meet rules on composition, valuation, custody and audit.
• Capital: issuers must hold minimum base capital and liquid assets.
• Redemption at par: par value must be returned within five business days of a redemption request.
• Disclosure: issuers must publish their stabilising mechanism, holders’ rights and the audit results of reserve assets.

Only issuers that meet all requirements may have their coins recognised as “MAS-regulated stablecoins”. MAS stated in 2023 that anyone who misrepresents a token as a MAS-regulated stablecoin may face penalties.

What did MAS propose in the September 2026 consultation?

On 1 September 2026 MAS published consultation paper P015-2026, which proposes Payment Services Act 2019 amendments to put the 2023 framework into law and to add new requirements. The comment period closed on 16 October 2026. As at 19 October 2026 no amending Act has been passed, so everything in the right-hand columns below is proposed.

The MAS media release of 1 September 2026 describes the core of the proposal. Only issuers licensed under the MAS Single-Currency Stablecoin (MAS-SCS) framework may describe themselves as licensed MAS-regulated stablecoin issuers and call their coins “MAS-regulated stablecoins”. Stablecoins outside the framework will be treated as DPTs and will carry the same consumer protection safeguards that apply to DPTs.

Area	2023 framework (policy finalised)	2026 consultation (proposed)	Status at 19 October 2026
Scope	Single-currency stablecoins issued in Singapore, pegged to SGD or a G10 currency	Same scope, given legal effect in the Payment Services Act 2019	Consultation closed 16 October 2026; amendments not enacted
Label	“MAS-regulated stablecoin” only for issuers meeting all requirements	Label reserved for licensed MAS-SCS issuers	Proposed
Issuance with a foreign issuer	Not addressed	Stablecoins jointly issued by a Singapore and a foreign issuer may carry the label if risks are mitigated	Proposed
Foreign-issued coins	Not addressed	Recognition of a limited number of foreign-issued stablecoins regulated under a comparable foreign framework, for cross-border wholesale use	Proposed
Interest to holders	Not addressed	Prohibition of interest being paid on MAS-regulated stablecoins	Proposed
Resilience	Capital and liquid assets	Adds stress testing and plans for recovery and orderly wind-down	Proposed
Customer monies	Not addressed	Safeguarding of customer monies received before stablecoins are issued	Proposed
Non-MAS stablecoins	Remain DPTs	Treated as DPTs with DPT consumer protection safeguards	Existing DPT regime applies

The paper and draft amendments are on the MAS consultation page. Commencement depends on the amending legislation, which had not been published by 19 October 2026.

Is a family office or VCC that holds stablecoins regulated as a result?

Not directly. The framework and the 2026 proposals impose duties on issuers and, through the DPT regime, on service providers. Nothing in MAS’s 1 September 2026 release proposes licensing or registration for persons who simply hold stablecoins.

The effect on a family office or VCC is indirect but real. Three consequences matter.

• Counterparty quality becomes easier to tell apart. Once in force, the “MAS-regulated stablecoin” label will mark coins with statutory reserve, redemption and disclosure duties, and an investment policy can require it.
• The proposed ban on interest changes the economics. If enacted, a MAS-regulated stablecoin will not itself pay interest to holders. Any yield offered on a position will come from a separate arrangement, such as lending, and should be assessed as such rather than as cash.
• Non-MAS stablecoins stay inside DPT conduct rules. MAS lists these as risk-awareness checks, no incentives to trade, no financing, margin or leverage, and no locally issued credit card payments.

A structure that transfers or safeguards tokens for other people must be checked against the DPT service definitions before it starts. Since 30 June 2025, Part 9 of the Financial Services and Markets Act 2022 (FSMA) has also required a licence for Singapore-based or Singapore-incorporated digital token service providers that serve only customers outside Singapore. In its 6 June 2025 clarification, MAS said it “will generally not issue a licence” for that model. A family vehicle that services third parties’ tokens offshore carries real licensing risk.

How should a family office choose a stablecoin custodian or counterparty?

Choose a provider that is licensed for the specific DPT services you will use, and record why the coin and the custody arrangement meet the family’s policy. The regulatory status of the provider matters more than the brand of the coin.

1. Confirm the provider’s licence and services on the MAS Financial Institutions Directory. Match the services listed to what you need, such as custodian wallet services, transmission or dealing.
2. Ask how customer assets are segregated. In July 2023 MAS announced requirements for DPT service providers to hold customer assets under a statutory trust, segregate them from their own assets, reconcile them daily and keep the custody function operationally independent. Ask for the provider’s written description of how it complies.
3. Classify each coin you will hold. Is it a MAS-regulated stablecoin, a coin recognised under the proposed foreign recognition route (once enacted), or a non-MAS stablecoin treated as a DPT? Record the issuer, reserve disclosures and redemption terms.
4. Test redemption. The 2023 framework requires MAS-regulated issuers to pay par within five business days. Coins without that duty need their own liquidity analysis.
5. Agree wallet controls and recovery. Set signatories, address whitelisting and a tested recovery procedure. Our wallet recovery drill for digital-asset VCCs sets out a practical runbook.
6. Put the policy to the board. Record approved coins, concentration limits, approved providers and escalation triggers, such as a depeg or a provider’s licence being revoked.

The licence check is not a formality: in May 2026 MAS revoked a DPT service provider’s major payment institution licence, ending its ability to provide DPT services in Singapore.

How should a VCC value stablecoins for its net asset value?

Value stablecoins like any other digital asset: at a documented price source, with a written policy on depegs and redemption costs. Do not assume a coin is worth exactly one unit of its reference currency.

A MAS-regulated stablecoin carries a statutory par redemption right within five business days, reserve audits and disclosure. That supports a policy of valuing at par less any redemption fee, with a trigger to switch to market price if the secondary market moves away from par or redemption is suspended. A non-MAS stablecoin has no Singapore statutory redemption right. The policy should start from observable market prices, with haircuts for thin liquidity or concentrated exposure.

For a VCC, the board and the fund manager should document in the valuation policy:

• the price sources and the time of day used for each coin, matched to the dealing calendar;
• the depeg threshold that moves a coin from par to market valuation, and who decides;
• how redemption fees, gas costs and transfer delays are reflected;
• how stablecoins received as staking or lending income are recognised and reconciled.

Our guide to reconciling staking rewards before VCC NAV covers the reconciliation step. Approve the policy before the first stablecoin balance appears in a NAV pack.

What AML/CFT rules apply when a family office holds stablecoins?

The service provider carries the main anti-money laundering and countering the financing of terrorism (AML/CFT) duties under MAS Notice PSN02. A VCC carries its own duties under MAS Notice VCC-N01. An exempt SFO meets AML/CFT expectations mainly through its banking and service-provider relationships.

MAS Notice PSN02 requires DPT service providers to assess and mitigate risk, conduct customer due diligence (including on beneficial owners), apply rules on reliance on third parties, correspondent accounts and wire transfers, keep records and report suspicious transactions. Expect the provider to ask for private-bank-level ownership and source-of-wealth evidence, plus wallet-level information.

A VCC is subject to MAS Notice VCC-N01. It must appoint an eligible financial institution to carry out the checks that let the VCC meet its AML/CFT requirements. It must also keep a register of beneficial owners and maintain controls on risk assessment, customer due diligence, record keeping and suspicious transaction reporting. When investors subscribe or redeem in stablecoins, the VCC’s eligible financial institution needs to see the wallet trail as well as the investor file.

For an SFO operating under the class exemption, our note on family office compliance in Singapore sets out the continuing obligations that apply without a licence.

How does CARF reporting treat stablecoins from 1 January 2027?

Singapore’s CARF Regulations take effect on 1 January 2027. Under them, Singapore-based crypto-asset service providers report users’ tax residence and transactions in “Relevant Crypto-Assets” to IRAS. Whether a given stablecoin is reportable depends on the definitions in IRAS’s CARF e-Tax Guide.

The IRAS e-Tax Guide on the Crypto-Asset Reporting Framework, published on 11 August 2026, sets out the following points.

• The CARF Regulations enter into force on 1 January 2027.
• The first exchange of information, covering calendar year 2027, takes place in September 2028.
• Reporting service providers must establish users’ tax residence and, for entity users other than active entities or excluded persons, identify their controlling persons.
• Reports are due to IRAS by 31 May of the following year.

A “Relevant Crypto-Asset” excludes central bank digital currencies and “Specified Electronic Money Products”. For a token to be a Specified Electronic Money Product, it must among other things represent a single fiat currency and be redeemable at par, at any time, because of regulatory requirements on the issuer. Whether a particular stablecoin meets that test is a technical question for the reporting provider and the family’s tax adviser. Do not assume it either way.

In practice, a family investment company, private trust company (PTC) or VCC that holds stablecoins with a Singapore provider should expect self-certification requests and controlling-person questions during 2027. For pre-existing users, the e-Tax Guide sets 31 December 2027 as the deadline after which providers must not process relevant transactions for users without a valid self-certification. Our earlier note on CRS 2.0 and CARF for family offices, trusts and VCCs explains how each entity type is classified.

Do stablecoins count towards 13O or 13U requirements?

Do not assume they do. The Section 13O and 13U tax incentive schemes under the Income Tax Act 1947 depend on the Designated Investments list, and any change to that list for digital payment tokens is for MAS to announce.

Neither the 2023 framework nor consultation P015-2026 addresses tax incentive treatment; MAS-regulated status is a separate question from designated investment status. Our analysis of designated investments under 13O follows MAS’s review of whether digital payment tokens may be added and what an SFO can prepare in the meantime. Until MAS publishes an updated list and implementation date, stablecoins held inside an incentivised fund should be reviewed with the fund’s tax adviser before each annual return.

Frequently asked questions

Is the MAS stablecoin framework in force?

The policy was finalised on 15 August 2023. The Payment Services Act 2019 amendments needed to give it legal effect were consulted on from 1 September to 16 October 2026 (P015-2026) and had not been enacted as at 19 October 2026.

Does a family office need a licence to hold stablecoins in Singapore?

The proposals do not license holders. Providing DPT services to others, such as custody, transfer or dealing, requires a Payment Services Act licence unless exempted, and FSMA Part 9 covers Singapore entities serving only overseas customers.

Will MAS-regulated stablecoins pay interest?

MAS has proposed to prohibit the payment of interest on MAS-regulated stablecoins. This is a proposal in consultation P015-2026 and not yet law.

Can a foreign stablecoin become MAS-regulated?

MAS has proposed two routes, neither yet enacted: joint issuance by a Singapore and a foreign issuer, and recognition of a limited number of foreign-issued stablecoins regulated under a comparable framework.

Which AML notice applies to a VCC that accepts stablecoin subscriptions?

MAS Notice VCC-N01 applies to the VCC, which must appoint an eligible financial institution to carry out its AML/CFT checks. The DPT service provider that handles the tokens is subject to MAS Notice PSN02.

Sources

• MAS, Consultation on Proposed Amendments to the Payment Services Act 2019 for Stablecoins Regulation (P015-2026), 1 September 2026
• MAS media release, MAS Consults on Legislative Amendments to Implement Stablecoin Regulatory Framework, 1 September 2026
• MAS media release, MAS Finalises Stablecoin Regulatory Framework, 15 August 2023
• MAS Notice PSN02, Prevention of Money Laundering and Countering the Financing of Terrorism: Digital Payment Token Service
• IRAS e-Tax Guide, Crypto-Asset Reporting Framework (first edition, 11 August 2026)

Raffles Corporate Services helps family offices and fund managers with VCC incorporation, family office set-up and ongoing compliance, including board policies for digital asset and stablecoin holdings. For company secretarial support for a family holding company or SPV, see Singapore Secretary Services. Email hello@rafflescorporateservices.com or Call/SMS/WhatsApp +65 8501 7133, or visit Raffles Corporate Services.

Last reviewed: 19 October 2026. The Editorial Team, Variable Capital Companies Act.