Singapore MAS digital token (DTSP/DPT) License Application Registration Guide

Singapore MAS digital token (DTSP/DPT) License Application Registration Guide

(Subject to the Payment Services Act(PSA)and the Financial Services and Markets Act(FSMA)Compliant encryption licensing with dual-track regulation)

Singapore Digital Payment Token (DPT) and Digital Token Service Provider (DTSP) licenses are authorized and supervised by the Monetary Authority of Singapore (MAS) in accordance with the law.。Authorize registered entities to legally conduct digital token transactions、Asset transfer and trusteeship business。The licensing system is based on the Payment Services Act(PSA) Regulate local and global business,and in 2025 Year 6 moon 30 Japan formally implements the Financial Services and Markets Act(FSMA) No. 9 department,Implement long-arm jurisdiction over compulsory licensing of pure offshore businesses。Statutory structure applies 17% Corporate income tax rates and capital gains tax exemption mechanism。Legal entry threshold requires actual payment 10 Wanzhi 25 Basic capital of S$10,000,A physical office with a local resident compliance officer and meeting physical presence requirements。Hong Kong Express provides applying entities with coverage of local corporate establishment、Executive fitness (Fit & Proper) review match、Compulsory legal opinion letter and external independent audit (EA) docking,As well as full-case legal agency services including MAS interview counseling。

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1. [Statutory Classification and Business Jurisdiction] of Singapore MAS Cryptocurrency License

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Standard payment institution license (SPI)

by"Payment Services Act》(PSA) regulate。Applicable to small and medium-sized businesses with monthly transaction volume of a single service ≤ S$3 million or multiple services ≤ S$6 million,Basic capital requirements 10 Wanxinyuan。

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Major payment institution license (MPI)

by"payment servicesLaw"(PSA) regulate。Applicable to large digital asset institutions that break through the above transaction volume restrictions,Basic capital requirements 25 Wanxinyuan,A deposit/guarantee of S$100,000-S$200,000 is required。

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Digital Token Service Provider (DTSP)

by"Financial Services and Markets Law》(FSMA) Regulation (effective from June 2025)。Implementing mandatory long-arm jurisdiction licensing for entities operating in Singapore but only servicing overseas customers。

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FATF standards and tax mechanisms

Comprehensively implement FATF international anti-money laundering standards and Travel Rule。Applicable to enterprises 17% income tax rate,Exemption according to lawCryptoassetsCapital gains tax on transactions。

2. Singapore MAS’s [Statutory Capital and Fee Standards] for DPT/DTSP Licenses

License plate type legal basic capital (Base Capital) Government application fee (Non-refundable) Government annual license fee
SPI (standardpayment institution) 100,000 Shingen 1,000 From SGD 5,000 Shingen
MPI (Major payment institutions) 250,000 Shingen
*A security deposit of S$100,000-S$200,000 is required.
1,500 From SGD 10,000 Shingen
DTSP (Only serving overseas customers) 250,000 Shingen 1,500 Shingen 10,000 Shingen (fixed)

Legal Notes:In addition to statutory basic capital,In MAS practice, it is mandatory for companies to prove that they have enough assets to cover the future. 6 to 12 Liquidity or capital buffer for monthly operating expenses。

3. [Statutory Requirements for Corporate Governance and Local Substantialization] stipulated by MAS

Physical reality and on-site office:Must have a permanent physical place of business to securely maintain books and records。It is mandatory to arrange for at least one employee to be on-site at least once a month 10 working days,at least every day 8 Hour,Handle customer inquiries。

Nationality allocation of executive directors:The board of directors needs at least 1 Singapore Citizen or Permanent Resident (PR) Serve as Executive Director;or adopt 1 employment pass holders (EP) of executive directors 1 Citizen/PR non-executive director combination。

Local Compliance Officer:In view of the high risk nature of digital asset business,Applicants must establish an independent compliance function locally in Singapore,and hire a full-time internal compliance officer (Compliance Officer)。

Fit and proper review (Fit & Proper):All executive directors、CEO、Partners and major shareholders must pass strict scrutiny by MAS,and must have sufficient experience in the financial or payment services industry (usually 5 years and above)。

4. [List of statutory registration documents and external reports submitted to MAS for review]

File category Submission details of statutory requirements and interpretation of regulatory core (2024New regulations in August)
Mandatory legal opinion
(Legal Opinion)
Must be issued by a Singapore law firm with experience in PSA。Clearly summarize the business model and token attributes,Accurately map whether the services to be provided are regulated,Demonstrate in detail whether exemption clauses apply。
Independent external auditor assessment
(EA Assessment)
A qualified independent external auditor must be hired to issue an independent assessment report on AML/CFT and the consumer asset segregation protection mechanism。The report issuance date must be before submitting the application 3 within months。
Compliance and Technology Risk Dossier
(TRM)
Include 3 Annual financial forecast business plan。Technology risk management (TRM) frame、System penetration testing before going online (Penetration Testing) Reports and proof of high-risk vulnerability remediation。

5. [Statutory Application and MAS Approval Process] for Singapore DPT License

first stage:Entity construction and mandatory report acquisition (2-6 week)

Complete local company registration、Physical office leasing and executive/compliance officer recruitment。Obtain the law firm’s Legal Opinion and the EA evaluation report from the external independent auditor。

second stage:Submit application and multiple rounds of inquiries

Submit Form via MAS Online System 1 and supporting documentation。MAS Case Manager (Case Officer) intervention,Issued multiple rounds of rigorous written inquiries,Failure to reconsider within the time limit shall be deemed to have been withdrawn.。

The third stage:Executive interviews (No external consultants)

MAS arranges in-person interviews with CEO and Compliance Officer,To examine its risk control and management capabilities。Legally required external counsel、Lawyers and other third parties are not allowed to accompany you to attend。

Stage 4:shelving mechanism (Trigger conditions apply)

If core executives change during the approval period、Reorganization or major overhaul of business model,MAS reserves the right to put an application on hold 6 months。No extension possible,If the deadline is not met, it will be cancelled.。

The fifth stage:IPA approved and officially licensed (total cycle 6-14 months)

Issue in-principle approval (IPA)。After meeting additional conditions such as capital injection and trust account establishment,,Obtained a formal license to commence operations。DPT business approval time usually takes 12 more than months。

6. Customer asset protection、Technical Risk Control and [Legal Compliance Operation Red Line]

Asset trust custody and 90% cold wallet:Client assets must be strictly separated from own assets and stored in legal trust accounts。It is mandatory to at least 90% of customer digital assets are stored offline in cold wallets,and must perform daily balance reconciliation。

No red lines for retail customers (break the lever):Any form of credit to retail customers is strictly prohibited、Leverage or margin trading。It is prohibited to use credit cards issued in Singapore to buy coins,It is prohibited to use retail assets for lending or pledging (Staking) Habitat。

Anti-money laundering (Travel Rule) with cash ban:It is absolutely prohibited to pay or receive cash and bearer bills ≥ S$20,000。Crypto transfers > S$1,500 must strictly comply with the FATF “Travel Rules”,Collect and verify detailed identity information of both sending and receiving parties。

System down 4 Hourly red line:MAS stipulates that unplanned downtime of critical systems shall be 12 The total within a month must not exceed 4 Hour (RTO ≤4 hours)。Major security incidents must be 1 Report to MAS within hours,14 Submit root cause analysis within days。

7. Hong Kong Huitong's Singapore DPT/DTSP license legal agency services

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Local entity establishment and executive placement

handleSingapore Private Limited Company RegistrationAnd open a public bank account。Legally matched to MAS eligibility (Fit & Proper) Reviewed Singaporean executive director and local full-time internal compliance officer。

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Core external audit reports and compliance documents

Issued with 3 Annual financial and capital adequacy forecast business letter。Seamlessly connect with Singapore’s qualified law firms to issue mandatory Legal Opinions,Liaise with external audit institutions to issue EA AML/CFT assessment reports。

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MAS case file submission and interview guidance

Fully authorized agent submits to MAS Form 1 Case files and responses to multiple rounds of written inquiries。Provide 1V1 mock Q&A and practical guidance on risk control logic for senior executives in the MAS independent interview session。

8. Singapore Cryptocurrency and Payment Services License Core Legal Questions and Answers (FAQ)

Advantages:What statutory tax and business privileges apply for a Singapore cryptocurrency license?+

Applicable to enterprises 17% Income tax rate and exempt from capital gains tax by law。The regulatory framework is fully compliant with FATF international standards,The license is highly recognized by global financial institutions,Significantly reduce the resistance to cross-border financing and bank account opening。

category:What are the legal transaction volume limits and classification standards for SPI and MPI licenses?+

SPI (Standard payment institution) Applicable to monthly transaction volume of a single service ≤ S$3 million or multiple services ≤ S$6 million。MPI (Major payment institutions) Applicable to large platforms that exceed the above limits,And MPI needs to pay an additional security deposit。

offshore:Do non-local entities that only serve overseas customers have to apply for a license?+

Must apply。in accordance with 2025 Year 6 moon 30 FSMA comes into effect on,Even if an entity is registered or operating in Singapore 100% Only for overseas customers,Must also obtain a DTSP license,No transition period and extremely difficult to obtain approval。

entity:Can I just register a shell company in Singapore and implement remote working for all employees overseas?+

Absolutely prohibited。The applicant must have a fixed physical business location for safe keeping of account books。It is mandatory to stay at least once a month 10 sky,every day 8 Hours of response to regulatory review,Cannot operate purely overseas。

personnel:What are the mandatory statutory requirements for the nationality of the board of directors and the localized configuration of the compliance officer?+

The board of directors must have at least 1 Singapore Citizen/PR as Executive Director (or 1 famous EP match 1 famous citizen/PR)。Digital asset businesses must hire locally on a full-time basis、Independent internal compliance officer。

funds:What is the statutory base capital required to apply for a license and the operating buffer required by MAS?+

SPI minimum basic capital 10 Wanxinyuan;MPI and DTSP are 25 Wanxinyuan。also,In practice, MAS mandates that companies must prove that they have enough assets to cover the future. 6 to 12 Liquidity reserves for estimated monthly operating expenses。

cost:How much are the government application fees and annual license fees required to submit a case file to MAS?+

The official application fee for DPT business is 1,000 Shingen (SPI) or 1,500 Shingen (MPI/DTSP),are non-refundable。The annual fee after approval is:SPI per year 5,000 Shingen;MPI and DTSP annually 10,000 Shingen。

material:What external independent review reports must be included when submitting a DPT license application to MAS?+

in accordance with 2024 Year 8 New rules every month,It is mandatory to submit a legal opinion issued by a senior law firm (Legal Opinion),and by a qualified external auditor in the near future 3 AML/CFT and consumer protection assessment reports issued within months (EA)。

cycle:How long does it take from the formal application submission to the final issuance of the MAS license?+

Due to digital payment tokens (DPT) Is a high-risk area,There are external audits and repeated rounds of questioning.,Routine license review usually requires 6-12 months,In practice, the end-to-end implementation cycle is usually as long as 9-14 months。

review:Can a third-party external legal counsel attend the defense on my behalf during the MAS interview session?+

Absolutely not。MAS will arrange interviews directly with the CEO and Compliance Officer,Outside consultants are expressly prohibited、Any third party such as a lawyer will accompany you。Senior executives must personally prove to regulators their independent compliance literacy。

condition:What regulatory procedures will be triggered if there is a change in equity or senior management during the application period?+

extremely dangerous。In the event of major reorganization or changes in core executives,MAS reserves the right to refer applications into 6 months of "on hold" (Case-on-Hold)"process。This period cannot be extended,If it is not resolved within the period, it will be invalidated or forced to withdraw.。

Compliance:Are there any mandatory legal red lines for customer encrypted asset custody and cold wallet ratios?+

Client assets must be deposited in legal trust accounts,It is strictly prohibited to mix it with the company’s own assets.。It is mandatory to at least 90% Customer digital assets must be stored offline in cold wallets,and perform rigorous daily reconciliations。

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