Case study →Singapore Crypto License: MAS Payment Services Act Advisory
Licensing analysis for exchange, custody, payments and stablecoin activity under MAS regimes, and honest advice about what not to apply for.
Singapore’s Payment Services Act is the regime most crypto businesses land in. It covers digital payment token services: buying and selling tokens, running a platform where others trade them, transferring tokens for customers and holding them in custody, and it applies whether you describe yourself as an exchange, a wallet or a payments company. MAS licenses that activity at two tiers, Standard Payment Institution and Major Payment Institution, separated by the volume you process rather than the size of your team. Alongside it sits the DTSP regime under the Financial Services and Markets Act, which reaches Singapore-incorporated businesses serving customers only overseas, and a separate framework for stablecoin issuers.
Getting a crypto license in Singapore starts with working out whether you need one.
We run that analysis first: which of your activities are regulated, which exemptions apply, and what a realistic application looks like against the business you actually operate. Then we execute. MAS engagement, the application itself, and the follow-up questions that decide most outcomes.
What this covers
Analysis first, application second. In that order, deliberately.
PS Act & DTSP licensing analysis
Your flows mapped against the regulated activity definitions, one by one. Which entity performs which activity, where the customer sits, and whether the PS Act, the DTSP regime or neither applies.
- Activity-by-activity classification
- SPI or MPI tier assessment
- Cross-border and DTSP reach
Exemption mapping before you spend
Plenty of teams apply for a licence they don’t need. We check the exemptions and the structural options first, and tell you when the answer is to change the flow rather than file.
- Exemption and carve-out review
- Restructuring options assessed
- Written memo you can show investors
MAS engagement and applications
The filing, the supporting policies and the correspondence that follows. Most applications are decided in the follow-up questions, so that is where the work concentrates.
- Application drafted and filed
- Governance and AML policy pack
- Queries handled through to outcome
How this compares
Singapore crypto regulation, bought four different ways.
What to expect
Who does this work.
Real experts. Named.
Kenneth Thng
Legal Lead · Fundraising
15+ years across Singapore, US and UK corporate law.
Naomi
Legal Review · Regulatory
Specialises in MAS, MiCA and cross-border compliance.
General information on Singapore’s regulatory regimes, current as of October 2, 2026. Not legal advice, and not a substitute for an engagement. Thresholds, capital requirements and MAS timelines change; confirm against the primary sources above or ask us.
Every engagement is scoped to the activity you actually run, not the label on your website.
Two companies describing themselves the same way can land in different MAS regimes. The memo starts from your flows.
Straight answers
Which MAS regime does our activity fall into?
The Payment Services Act is where most crypto businesses land. It covers Digital Payment Token services, buying, selling and transferring tokens, and running the platforms that do it, and it applies whether you describe yourself as an exchange, a wallet or a payments company. However, depending on the utility of the tokens offered (if any), the nature of the services and other key considerations, the proposed activity may fall within the other MAS regimes.
Standard or Major Payment Institution, which tier applies?
The tiers are separated by the volume you process rather than the size of your team, so the answer moves as the business grows. We assess the tier against your projected flows and tell you what each one costs you in capital, safeguarding and compliance headcount before you commit to one.
Do we actually need a licence, or is there an exemption?
Plenty of teams apply for a licence they do not need. We check the exemptions and the structural options first, and where the better answer is to change the flow rather than file, we say so in writing, in a memo you can show investors. That review happens before you spend on an application.
Do you handle the MAS application, or just the analysis?
Both, in that order. The classification and exemption memo comes first. If it makes sense to proceed, we prepare and file the application with the governance and AML policy pack MAS expects, run the engagement with the regulator, and work the follow-up questions, which is where most applications are actually decided, through to outcome. Typical duration from engagement to a successful licence application is 2 years.